2024-11-12; City Council; 08; Climate Action Plan Update — Carlsbad City Council, November 12, 2024 (part 3 of 3)

In considering the potential environmental impacts of the CAP Update, the c ity has determined that the EIR certified for the 2015 General Plan update and SEIR certified for the 202 4 Housing Element Implementation and Public Safety Element Update are of continuing informational value. The city also has determined that the potential environmental impacts (both direct and indirect impacts) of the CAP Update are within the scope of the previously certified EIR and SEIR and that none of the conditions requiring subsequent or supplemental environmental review under CEQA Guidelines section 15162 exists. Based on the information and analysis provided below, the city has determined that only minor or technical changes to the previously certified EIR are necessary and that that preparation of an Addendum pursuant to CEQA Guidelines section 15164 is appropriate.

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Overview of the CEQA Guidelines
Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 15 3 Overview of the CEQA Guidelines
Section 15160 of the CEQA Guidelines explains that there are several mechanisms, and variations in environmental documents, that can be tailored to different situations and intended uses of environmental review. Specifically, Section 15160 states that the “… variations listed [including Subsequent EIRs, Supplemental EIRs, and Addendums] are not exclusive. Lead agencies may use other variations consistent with the Guidelines to meet the needs of other circumstances.” This provision allows Lead agencies to tailor the use of CEQA mechanisms (such as this Addendum) to fit the circumstances presented to the Lead agency by a project. Here, the city has opted to prepare an Addendum to assess the minor modifications of the Project that have transpired since preparation of the EIR.

Public Resources Code Section 21166 and California Environmental Quality Act (CEQA) Guidelines Sections 15162 and 15164 set forth the criteria for determining the appropriate additional environmental documentation, if any, to be completed when changes are proposed to a project that has a previously certified Environmental Impact Report (EIR). When considering the need for additional environmental review, the fundamental determination a lead agency must make is whether the previously certified EIR retains some informational value or whether changes in the project or circumstances have rendered it wholly irrelevant. If the previously certified EIR has continuing informational value, the lead agency then must determine whether the proposed changes in the Project require additional environmental review under Public Resources Code Section 21166 and CEQA Guidelines Section 15162.

CEQA Guidelines Section 15164 states that a lead agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary, but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred. CEQA Guidelines section 15162(a) states that no Subsequent or Supplemental EIR shall be prepared for a project with a certified EIR unless the lead agency determines, based on substantial evidence in the light of the whole record, one or more of the following:

1. Substantial changes are proposed in the project that will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

2. Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

3. New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete, shows any of the following:

A. The project will have one or more significant effects not discussed in the previous EIR.

B. Significant effects previously examined will be substantially more severe than shown in the previous EIR.

C. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative.

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City of Carlsbad
Climate Action Plan Update

16 Addendum
D. Mitigation measures or alternatives that are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

The analysis pursuant to Section 15162 demonstrates whether the lead agency can approve the activity as being within the scope of the existing certified EIR, that an addendum to the existing EIR would be appropriate, and no new environmental document, such as a new EIR, would be required. The addendum need not be circulated for public review but can be included in or attached to the final EIR, and the decision-making body shall consider the addendum with the final EIR prior to deciding on the project.

The City of Carlsbad has prepared this Addendum, pursuant to CEQA Guidelines Sections 15162 and 15164, to evaluate whether the Project’s environmental impacts are covered by and within the scope of the Housing Element Implementation and Public Safety Element Update Supplemental Environmental Impact Report ( State Clearinghouse Number 2022090339, dated Ju ly 2023). The following Addendum details any changes in the Project, changes in circumstances under which the Project is undertaken, and/or “ new information of substantial importance ” that may cause one or more significant effects to environmental resources.

The responses herein substantiate and support the City of Carlsbad’s determination that the potential environmental impacts of the CAP Update measures and actions are within the scope of the Housing Element Implementation and Public Safety Element Update S EIR, do not require subsequent or supplemental environmental review under CEQA Guidelines Section 15162 and, in conjunction with the SEIR, preparation of an Addendum pursuant to CEQA Guidelines Section 15164 is appropriate.

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Enviro nmental Effects and Determinations
Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 17 4 Environmental Effects and Determinations
The subject areas checked below were determined to be new significant environmental effects or to be previously identified effects that have a substantial increase in severity either due to a change in Project, change in circumstances, or new information o f substantial importance, as indicated by the checklist and discussion on the following pages.
■ NONE
□ Aesthetics □ Air Quality □ Biological Resources
□ Energy, Greenhouse Gas Emissions,
and Climate Change
□ Geology, Soils,
and Seismicity
□ Hazards and Hazardous
Materials, Airport Safety, and
Wildfires
□ Historical, Archaeological, and
Paleontological Resources (includes
Tribal Cultural Resources)
□ Hydrology and
Flooding
/Water Quality
□ Land Use Planning, Housing,
and Population
□ Noise □ Public Facilities
and Services
□ Utilities and Service Systems
□ Transportation □ Agriculture &
Forestry
Resources
□ Impacts Not Potentially
Significant: Mineral
Resources
Determination
Based on this analysis, the 2024 Housing Element Implementation and Public Safety Element Update SEIR has continuing informational value and:
□ Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous EIR due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or, there is “new information of substantial importance, ” as that term is used in CEQA Guidelines Section 15162(a)(3). Therefore, a SUBSEQUENT or SUPPLEMENTAL EIR is required. ■ No substantial changes are proposed in the project and th ere are no substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous EIR due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Also, there is no “new information of substantial importance” as that term is used in CEQA Guidelines Section 15162(a)(3). Therefore, the preparation of an Addendum to the previously certified SEIR (City of Carlsbad, Housing Element Implementation and Public Safety Element Update Supplemental Environmental Impact Report (SEIR) (State Clearinghouse Number 2022090339, dated July 2023) is adequate and appropriate.

Signature: _________________________________ Date: __________________________ Printed Name: ______________________________ Title: __________________________ Eric Lardy
May 2, 2024
City Planner
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t
-g
~
City of Carlsbad
Climate Action Plan Update

18 Addendum
5 Addendum Methodology
The city has previously prepared and certified an EIR for the 2015 General Plan, an Addendum for the CAP Amendment (2020), an Addendum for the Housing Element (2021) , and a SEIR for the Housing Element Implementation and Public Safety Element Update (2024). Collectively, these CEQA reviews are known as the “Previous CEQA Documents .” No legal actions were filed challenging the Previous CEQA Documents and thus are presumed valid.

Since the adoption of the Previous CEQA Documents, there have been no substantial changes in the city’s policies that relate to actions in the CAP Update; neither has there been new information, or a change of circumstances which would invalidate the Previous CEQA Documents. In addition, the city adopted ordinances in 2019 that amended the Carlsbad Municipal Code related to energy efficiency, renewable energy, alternative water heating, electric vehicle charging infrastructure and transportation demand management, which further mitigate environmental impacts.

The CAP Update is a programmatic planning document which catalogues the priorities of the city for reducing energy use and greenhouse gas emissions to meet State reduction targets. The CAP Update does not approve or authorize a project that could potentially alter the environment. Rather, it outlines the need for future work to advance each of the separate measures and actions.

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Addendum Evaluation

Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 19 6 Addendum Evaluation
Aesthetics
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

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City of Carlsbad
Climate Action Plan Update

20 Addendum CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

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Addendum Evaluation
Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 21 Previous CEQA Analysis Aesthetics Findings
The 2024 SEIR identified less than significant impacts for scenic vistas (AES-1), scenic resources within scenic highways (AES-2), visual quality (AES-3), and light and glare (AES-4) (Section 4.1, Aesthetics).

Addendum Analysis
The implementation of the CAP Update measures and actions would result in short -term and long- term changes related to aesthetics as described below.

Construction activities associated with the implementation of the CAP Update, such as equipment use and staging of materials, would result in short-term, temporary changes to aesthetic conditions in the city. The types of construction activities associated with the CAP Update would vary depending on the type of CAP Update measure. For example, Measures T-1, T-4, T-5, T-8, and T-9 would involve removing existing pavement; repaving roadway surfaces; painting or restriping pavement; modifying curbs; laying concrete, and installing traffic signals, lighting, landscaping, street furniture, and other amenities. Some of these improvements, such as M easure E -3.3, W -1, and W -2, would require limited ground disturbance. Construction activities would be short -term and temporary, and would not involve equipment of substantial height, bulk, or massing that would have substantial adverse effects on existing scenic vistas, scenic resources, or visual quality. Because duration of these activities would be limited to relatively short periods, their temporary effects on aesthetic resources would not be substantial.

Construction activities would also incrementally increase sources of light and glare in the city, for example from outdoor lighting sources associated with construction of transportation improvements and glare from construction vehicles and equipment. Construction activities would generally occur during daytime hours and would comply with applicable lighting requirements including the City’s Zoning Ordinance and Title 24 of the California Building Code that reduce light spillover. Furthermore, construction activities would be located in developed areas with existing sources of outdoor lighting and glare, characteristic of developed urban and suburban environments. Thus, the CAP Update would not create temporary new source s of substantial light or glare that would adversely affect day or nighttime views in the city.

Implementation of Measures T-1, T-4, T-5, T-8, and T -9 would also result in the installation of new sidewalks, new and upgraded bikeways and walkways along existing developed roadways and rights- of-way in the city, and the installation of roundabouts or control traffic within the intersections of existing developed roadways. The CAP Update would not result in new features of substantial height, bulk, or massing that would result in substantial long-term damage to scenic vistas, scenic resources, or visual quality. Additionally, the increase in planted trees and the development of new landscaping (Measure CS-1) would offer long-term visual improvement to the local surrounding area and would not result in a substantial effect to scenic vistas, scenic resources, or visual quality.

Transportation measures and actions included in the CAP Update would include improvements to the city’s existing pedestrian, bicycle, and transit network that may introduce new short term light sources. In addition, i nstallation of solar carports (Measure E -3.3) would introduce new sources of glare from sunlight reflecting off of solar photovoltaic panels.

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City of Carlsbad
Climate Action Plan Update

22 Addendum

These types of improvements would comply with applicable lighting requirements including the city’s Zoning Ordinance and Title 24 of the California Building Code that reduce light spillover. Improvements resulting from implementation of the CAP Update would be located in developed areas with existing sources of outdoor lighting and glare, characteristic of developed urban and suburban environments.

Thus, the CAP Update would not create new long-term sources of substantial light or glare that would adversely affect day or nighttime views in the city.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to aesthetics.

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Addendum Evaluation
Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 23 Agriculture and Forestry Resources
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

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City of Carlsbad
Climate Action Plan Update

24 Addendum

CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the
Proposed
Changes
Involve a New
or Substantial
Increase in
the Severity
of Previously
Identified
Impacts?
Are There New Circumstances
Involving a New or
Substantial Increase in the
Severity of Previously
Identified Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Are Only Minor
Technical
Changes or
Additions
Necessary or
Did None of
the Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
c. Conflict with existing zoning for, or
cause rezoning of, forest land, as
defined in Public Resources Code
Section 12220 (g)), timberland (as
defined by Public Resources Code
Section 4526), or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))?
No Impact None No No No Yes Yes
d. Result in the loss of forest land or
conversion of forest land to non-forest
use?
No Impact None No No No Yes Yes
e. Involve other changes in the exiting
environment which, due to their
location or nature, could result in the
conversion of Farmland, to non-
agricultural use or conversion of forest
land to non-forest use?
No Impact None No No No Yes Yes
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Addendum Evaluation
Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 25 Previous CEQA Analysis Agriculture and Forestry Resources Findings The 2024 SEIR identified no impacts for converting Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) ; for conflicting with existing zoning for agricultural use or a Williamson Act contract or with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)); timberland (as defined by Public Resources Code Section 4526); or timberland zoned Timberland Production (as defined by Government Code Section 51104(g)); and for resulting in the loss of forest land or conversion of forest land to non-forest use; or involving other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non -agricultural use or conversion of forest land to non- forest use (Section 4.16.1, Agriculture and Forestry Resources).

Addendum Analysis
Implementation of the CAP Update would not result in the conversion of Important Farmland or forest land to urban or other uses. M easures and actions included in the CAP Update may include construction activities, such as equipment use and staging of materials ; however , construction activities would occur in previously disturbed, developed areas not currently used for agricultural uses or under a Williamson Act contract. There are currently no Williamson Act contracts in the city and the CAP Update does not propose land use changes that would affect the status of any Williamson Act contracts ( DOC 2024). Additionally, there are no areas in the city zoned as forest or timberland, therefore, implementation of the CAP Update would not conflict with existing zoning or cause rezoning any forest land, timberland, or timber land zoned for timberland production . Therefore, the CAP Update would not involve other changes in the exiting environment which, due to their location or nature, could result in the conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 202 4 SEIR identified to reduce impacts related to agriculture and forestry resources.

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Climate Action Plan Update

26 Addendum Air Quality
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 27 Previous CEQA Analysis Air Quality Findings
The 2024 SEIR identified a less than significant impact related to a conflict with or obstruction of the San Diego Regional Air Quality Strategy or State Implementation Plan (AQ-1) with implementation of mitigation measure AQ -1. The 202 4 SEIR identified that although mitigation measure AQ -2 would reduce operational emissions from future development, it would be speculative to quantify such emissions until details of the individual projects are known and concluded impacts to be significant and unavoidable (A Q-2). The 202 4 SEIR identified a less than significant impact related to exposing offsite sensitive receptors to substantial pollution concentrations (AQ -3) with implementation of mitigation measure AQ -3 and mitigation measure AQ -4. The 202 4 SEIR also identified a less than significant impact related to creating objectional odors (AQ-4) (Section 4.2, Air Quality).

Addendum Analysis
The implementation of the CAP Update measures and actions would result in short -term and long- term changes related to air quality as described below.

Construction activities associated with the implementation of the CAP Update, such as equipment use, construction of new facilities or retrofitting of existing facilities, would result in construction-related air quality emissions. The types of construction activities associated with the CAP Update would vary depending on the type of CAP Update measure. Examples of activities that would result from implementation of the CAP Update measures include construction of new EV charging stations, public zero emission vehicle and bicycle charging infrastructure, building efficiency retrofits, roundabouts or traffic circles, new and improved bicycle infrastructure, new solar carports, and water and wastewater system improvements (e.g., Measures T-1, T-2, T-3, T-4, T-5, T-8, T-9, E-3.3, W-1, and W -2). These construction activities would involve using construction equipment and vehicles to remov e existing pavement; repav e roadway surfaces; paint or restrip e pavement; modify curbs; lay concrete, and install traffic signals, lighting, landscaping, street furniture, and other amenities . These construction activities would be completed by workers located in the city and surrounding areas in the San Diego region.

Construction activities resulting from implementation of the CAP Update would generate emissions of ROG, NOX, PM10, and PM 2.5 associated with off-road equipment use (i.e. excavators, front loaders, pavers, dump trucks, cranes, and backhoes), material and equipment delivery trips, worker commute trips, and other miscellaneous activities. Construction activities would be relatively small in scale, occur intermittently in different locations throughout the city, last for only short periods of time, and would not require substantial relocation of construction workers from areas outside of the city and the San Diego region . The CAP Update includes measures that would reduce air pollutant emissions during construction activities. For example, measure OR-2 would increase the use of renewable and alternative fuel construction equipment, while Measure T-9 would establish city fleet regulations for idling, thus reducing construction vehicle idling time and further reducing construction related air pollutant emissions. Due to the non- intensive, sporadic, and dispersed nature of these construction activities, emissions of criteria air pollutan ts would not occur in concentrations which would exceed SDAPCD thresholds and would therefore be consistent with the goals of the San Diego Regional Air Quality Strategy or State Implementation Plan . Therefore, mitigation measure AQ-1 identified in the SEIR would not apply to the construction related air pollutant emissions of the CAP Update. Mitigation measure AQ-1 identified in the SEIR applies specifically to the construction impacts associated with housing development projects permitted under implementation of the Housing Element Update, and would therefore not apply to the CAP Update.

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Climate Action Plan Update

28 Addendum The CAP Update includes several measures (T-4, T -5) that would reduce GHG and vehicle miles traveled (VMT) through the expansion of bicycle infrastructure, and increased connectivity of sidewalk networks. Although there would be a temporary , nominal amount of vehicle trips related to construction worker commute and equipment delivery associated with bike and sidewalk improvements and other construction activities resulting from CAP Update implementation , the CAP Update would not result in r esult in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard. Therefore, mitigation measure AQ -2 identified in the SEIR would not apply to the CAP Update.

Measures that would result in new zero emission vehicle and bicycle charging stations (T-8), roundabouts (T-1), improved bicycle infrastructure (T-4), solar carports (E-3.3) would result in minor criteria air pollutant and TAC emissions during construction. It is unlikely that these types of activities would be of the size, intensity, or duration to exceed SDAPCD thresholds of significance or to emit substantial TAC concentrations. Measure WD -1 would increase the diversion of solid and organic waste from landfills which could lead to increased haul truck trips to and from composting and recycling facilities; however, it is an ticipated that these trips would displace the haul truck trips that would be diverted from the landfill. A substantial net increase in the number of haul truck trips and associated criteria air pollutant emissions within the city would not be anticipated. Furthermore, these haul truck trips would likely be infrequent and would not involve the trucks idling for extended periods of time near sensitive receptors. As such , implementation of the CAP Update would not expose off- site sensitive receptors to substantial pollution concentrations. Therefore, mitigation measures AQ-3 and AQ-4 identified in the SEIR would not apply to the CAP Update.

Construction activities that would occur under CAP Update implementation would result in temporary generation of odorous emissions. However, consistent with the less than significant impact determination of the 202 4 SEIR, given the temporary and intermittent nature of the impacts, and dissipation of odor, construction-related odor impacts would be minor . Furthermore, construction activities would be required to comply with SDAPCD Rule 51 (Nuisance), which regulates nuisance odors (SDAPCD 1976).

Long-term changes resulting from implementation of the CAP Update would reduce GHG emissions generated within the city by implementing numerous transportation -, water -, waste -, and energy - related measures. For example, the implementation of the CAP Update would encourage the use of alternatively fueled vehicles through measures such as Measure T-8 which would involve installing and incentivizing public zero emission vehicle and bicycle infrastructure. This would reduce overall gasoline and fuel consumption, therefore reducing air pollutant emissions related to fossil fuel comb ustion.

Other transportation-related measures such as Measures T-5, T-7, and T-10 would reduce VMT in the city by improving street connectivity, provide resources and incentives for alternative commutes, such as a carpool matching, and implement parking management strategies. Reducing VMT would reduce the emission of air pollutants b y decreasing the consumption of fossil fuel in vehicles and reducing emissions related to tire and brake wear.

Actions aimed at diverting and eliminating solid waste from disposal in landfills would generate compostable materials and demand for compost products (e.g., Measure WD-1), which would lead to a need for haul trucks to transport these materials. Truck trips for hauling of organic waste to processing facilities would be offset by reductions in truck trips to landfills. Organic waste collected in the city is recycled at a Republic Services composting facility in Otay (City of Carlsbad 2024).

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Addendum Evaluation

Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 29 Energy-related measures such as Measure E-3.1 would continue to implement and enforce the city’s reach code which is focused on requiring solar photovoltaic (PV) and other energy efficiency measures for new and existing nonresidential buildings, while Measure E-3.3 focuses on the installation of solar carports at city-owned parking lots. While these reduction measures were formulated to reduce GHGs, they would also improve overall air quality by reducing the emission of criteria air pollutants. A higher proportion of buildings powered by more efficient and /or renewable electric systems due to implementation of Measure E-3.1 would reduce natural gas combustion at non residential land uses within the city , which would also reduce local criteria air pollution. The effects associated with the reduction of air pollutant emissions in the city and SDAPCD would be largely beneficial and would, by nature, reduce the concentration of air pollutants. Therefore, operational activities under implementation of the CAP Update would not result in the exceedance of SDAPCD thresholds and would be considered consistent with the goals of the San Diego Regional Air Quality Strategy or State Implementation Plan. Operational activities would also not violate air quality standards or contribute to an existing air quality violation because project -related emissions would not exceed SDAPCD thresholds or result in a cumulatively considerable net increase of criteria pollutants for which the region is nonattainment under applicable federal or State ambient air quality standards.

The operation of the measures and actions in the CAP Update would not expose off -site sensitive receptors to substantial pollution concentrations. Measure WD-1 would result in increased odors from the anaerobic decomposition of composted waste and haul truck trips to composting facilities. These impacts would be avoided through implementation of an Odor Impact Minimization Plan (OIMP) as required by State regulation. Therefore, the CAP Update would not result in new emissions (such as those leading to odors) adversely affecting a substantial number of people.

Applicable Mitigation Measures from the SEIR
The SEIR iden tified mitigation measures AQ-1 through AQ -4 for air quality impacts. None of these mitigation measures are applicable to the CAP Update.

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City of Carlsbad
Climate Action Plan Update

30 Biological Resources
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

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Addendum Evaluation
Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 31 CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

32 Previous CEQA Analysis Biological Resources Findings The 2024 SEIR identified a less than significant impact related to a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or US Fish and Wildlife Service (BIO-1) with implementation of mitigation measures BIO- 1 and BIO -2. The 2024 SEIR identified a less than significant impact to any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or US Fish and Wildlife Service (BIO-2) with implementation of mitigation measures BIO-1, BIO-3, and BIO-4. The 2024 SEIR identified a less than significant impact to State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) (BIO-3) with implementation of mitigation measures BIO -1, BIO-3, BIO-4, and BIO -5. The 2024 SEIR identified a less than significant impac t to interfering substantially with the movement of any native resident or migratory fish or wildlife species or with established native res ident or migratory wildlife corridors, or imped ing the use of native wildlife nursery sites (BIO-4) with implementation of mitigation measures BIO-1, BIO-3, and BIO-4. The 2024 SEIR identified a less than significant impact related to conflicts with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance (BIO-5) with implementation of mitigation measure BIO-6. The 2024 SEIR identified a less than significant impact related to conflicts with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan (BIO-6) with implementation of mitigation measures BIO-1, BIO-2, BIO-3, BIO-4, BIO-7 and BIO-8 (Section 4.3, Biological Resources).

Addendum Analysis
Implementation of the CAP Update would include measures and actions that involve construction and ground disturbing activities, including minor grading and excavation. For example, Measures T-1, T-4, T- 5, T -8, and T -9 would involve removing existing pavement; repaving roadway surfaces; painting or restriping pavement; modifying curbs; laying concrete, and installing traffic signals, lighting, landscaping, and trees. Some of these improvements, such as Measures E-3.3, W-1, and W-2, would require limited ground disturbance from construction activities. The CAP Update consists of minor improvements and building retrofits within the city and construction activities would occur in previously disturbed, developed areas such as roadways and parking lots that lack natural habitat and where candidate, sensitive, or special-status species or their habitats are not present. Therefore, implementation of the CAP Update would not cause a substantial adverse direct or indirect effect to special-status species.

Because implementation of the CAP Update would occur in previously disturbed, developed areas, implementation of the CAP Update would not occur in areas where riparian habitat or other sensitive natural communities, protected wetlands, wildlife corridors, and protected biological resources are present. Furthermore, implementation of mitigation measure BIO -2 would reduce any impacts to candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or US Fish and Wildlife Service because the pre-construction bird surveys would ensure that active nests are identified and as necessary avoided. Implementation of mitigation measure BIO-2 would also reduce conflicts with the city’s Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or S tate habitat conservation plans because it would assure compliance with the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code (CFGC) Section 3503. I mplementation of mitigation measure BIO -6 would reduce any conflicts with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance because it would require a project-specific tree survey to determine measures to address impacts such as avoidance, minimization, restoration, or compensation.

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Addendum Evaluation

Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 33 Because duration of construction activities would be limited to relatively short periods, their temporary effects on biological resources would not be substantial.

Long-term changes resulting from implementation of CAP Update measures would include improvements at or near grade level of existing roadways, as well as minor changes to traffic intersections and walkways (through implementation of Measures T -1, T -4, T -5, T -8, and T -9), improvements to water and wastewater systems (Measures W-1 and W-2), planting of trees (through implementation of Measure CS-1). Implementation of Measures T-1, T-4, T-5, T-8, and T-9 would also result in the installation of new sidewalks, new and upgraded bikeways and walkways along existing developed roadways and rights-of-way in the city, and the installation of roundabouts or control traffic within the intersections of existing developed roadways. The CAP Update would not result in physical improvements or effects that would result in substantial long-term damage to biological resources.

Conclusion
There are no changes in circumstances or new information of substantial importance that would require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in the severity of previously identified effects related to biological resources. Implementation of mitigation measures BIO-1, BIO-3, BIO-4, BIO-5, BIO-7, and BIO-8 from the SEIR are not applicable to the CAP Update . Implementation of mitigation measure BIO-2 would ensure a less-than-significant impact to special- status biological resources . Implementation of mitigation measure BIO -6 would ensure a less -than-significant impact for conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. The CAP Update would not result in any new or substantially more severe significant impacts related to biological resources.

Applicable Mitigation Measures from the SEIR
The CAP Update would not result in more significant impacts related to biological resources. Mitigation Measures BIO-2 and BIO-6 from the 2024 SEIR would apply to the CAP Update and ensure CAP Update impacts related to biological resources are less than significant.

BIO-2 Pre-Construction Bird Surveys, Avoidance, and Notification If construction activities are initiated during the bird nesting season (February 1 – August 31) involving removal of vegetation or other nesting bird habitat, including abandoned structures and other man - made features, a pre -construction nesting bird survey shall be conducted no more than three days prior to initiation of ground disturbance and vegetation removal activities. The nesting bird pre - construction survey shall be conducted on foot and shall include a 300-foot survey buffer around the construction site. The survey shall be conducted by a biologist familiar with the identification of avian species known to occur in southern California coastal communities (i.e., qualified biologist). If active nests are found, an avoidance buffer shall be determined by a qualified biologist in coordination with the city. The avoidance buffer width will depend upon the species, the proposed work activity, and existing disturbances associated with land uses outside of the site, which shall be demarcated by the biologist with bright orange construction fencing, flagging, construction lathe, or other means to demarcate the boundary. All construction personnel shall be notified as to the existence of the buffer zone and to avoid entering the buffer zone during the nesting season. No ground disturbing activities shall occur within the buffer until the biologist has confirmed that breeding/nesting is completed, and the young have fledged the nest. Encroachment into the buffer shall occur only at the discretion of the qualified biologist on the basis that the encroachment will not be detrimental to an active nest. A report summarizing the pre-construction survey(s) shall be prepared by a qualified biologist and shall be submitted to the city prior to the commencement of construction activities.

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34 BIO-6 Protected Tree and Tree Canopy Survey
Prior to the issuance of a grading permit, a tree survey shall be conducted by a certified arborist prior to project construction to tag and assess all trees subject to the c ity’s Trees and Shrubs Ordinance (Municipal Code Title 11.12) and/or CFMP. A city arborist will inspect the property and recommend approving or denying the application in a written report submitted to the City Manager. The city shall post a letter of notification and a non-removable marking upon the subject tree a minimum of 30 days prior to its removal. The letter will be posted in a prominent location, visible from a public street and will include, the location of the tree, the reason for the trees removal, the date of the scheduled removal, the species of tree to be replanted, the size of the tree to be replanted, the date by which an appeal must be made to the parks and recreation commission, and a description of the appeal process.

The following measures shall be implemented in addition to those required under the c ity’s permits required for tree removal and maintenance ordinance Guidelines (Municipal Code Title 11.12.090) to avoid and/or compensate for potential indirect impacts to preserved sensitive natural communities and protected trees within Carlsbad before, during, and following construction activities.

PRE-CONSTRUCTION
• Fencing. Protective fencing at least three feet high with signs and flagging shall be erected around all preserved sensitive natural communities where adjacent to proposed vegetation clearing and grubbing, grading, or other construction activities. The protective fence shall be installed at a minimum of five feet beyond the tree canopy dripline. The intent of protection fencing is to prevent inadvertent limb/vegetation damage, root damage and/or compaction by construction equipment. The protective fencing shall be depicted on all construction plans and maps provided to contractors and labeled clearly to prohibit entry, and the placement of the fence in the field shall be approved by a qualified biologist prior to initiation of construction activities. The contractor shall maintain the fence to keep it upright, taut and aligned at all times. Fencing shall be removed only after all construction activities are completed.
• Pre-Construction Meeting. A pre-construction meeting shall be held between all site contractors and a registered consulting arborist and/or a qualified biologist. All site contractors and their employees shall provide written acknowledgement of their receiving sensitive natural community protection training. This training shall include, but shall not be limited to, the following information: (1) the location and marking of protected sensitive natural communities; (2) the necessity of preventing damage to these sensitive natural communities; and (3) a discussion of work practices that shall accomplish such.

DURING CONSTRUCTION
• Fence Monitoring. The protective fence shall be monitored regularly (at least weekly) during construction activities to ensure that the fencing remains intact and functional, and that no encroachment has occurred into the protected natural community; any repairs to the fence or encroachment correction shall be conducted immediately. • Equipment Operation and Storage. Contractors shall avoid using heavy equipment around the sensitive natural communities. Operating heavy machinery around the root zones of trees would increase soil compaction, which decreases soil aeration and, subsequently, reduces water penetration into the soil. All heavy equipment and vehicles shall, at minimum, stay out of the fenced protected zones, unless where specifically approved in writing and under the supervision of a registered consulting arborist and/or a qualified biologist.

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Addendum Evaluation

Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 35 • Materials Storage and Disposal. Contractors shall not store or discard any construction materials within the fenced protected zones and shall remove all foreign debris within these areas. The contractors shall leave the duff, mulch, chips, and leaves around the retained trees for water retention and nutrient supply. Contractors shall avoid draining or leakage of equipment fluids near retained trees. Fluids such as gasoline, diesel, oils, hydraulics, brake and transmission fluids, paint, paint thinners, and glycol (anti-freeze) shall be disposed of properly. The contractors shall ensure that equipment be parked at least 50 feet, and that equipment/vehicle refueling occur at least 100 feet, from fenced protected zones to avoid the possibility of leakage of equipment fluids into the soil. • Grade Changes. Contractors shall ensure that grade changes, including adding fill, shall not be permitted within the fenced protected zone without special written authorization and under supervision by a registered consulting arborist and/or a qualified biologist. Lowering the grade within the fenced protected zones could necessitate cutting main support and feeder roots, thus jeopardizing the health and structural integrity of the tree(s). Adding soil, even temporarily, on top of the existing grade could compact the soil further, and decrease both water and air availability to the tree roots. Contractors shall ensure that grade changes made outside of the fenced protected zone shall not create conditions that allow water to pond.
• Trenching. Except where specifically approved in writing beforehand, all trenching shall be outside of the fenced protected zone. Roots primarily extend in a horizontal direction forming a support base to the tree similar to the base of a wineglass. Where trenching is necessary in areas that contain roots from retained trees, contractors shall use trenching techniques that include the use of either a root pruner (Dosko root pruner or equivalent) or an Air-Spade to limit root impacts. An International Society of Arboriculture (ISA) certified arborist or American Society of Consulting Arborists (ASCA) registered consulting arborist shall ensure that all pruning cuts shall be clean and sharp, to minimize ripping, tearing, and fracturing of the root system. Root damage caused by backhoes, earthmovers, dozers, or graders is severe and may ultimately result in tree mortality. Use of both root pruning and Air-Spade equipment shall be accompanied only by hand tools to remove soil from trench locations. The trench shall be made no deeper than necessary. • Erosion Control. Appropriate erosion control best management practices (BMPs) shall be implemented to protect preserved sensitive natural communities during and following project construction. Erosion control materials shall be certified as weed free. • Inspection. An ISA certified arborist or ASCA registered consulting arborist shall inspect the preserved trees adjacent to grading and construction activity on a monthly basis for the duration of the grading and construction activities. A report summarizing site conditions, observations, tree health, and recommendations for minimizing tree damage shall be submitted by the registered consulting arborist following each inspection.

POST-CONSTRUCTION
• Mulch. The contractors shall ensure that the natural duff layer under all trees adjacent to construction activities shall be maintained. This would stabilize soil temperatures in root zones, conserve soil moisture, and reduce erosion. The contractors shall ensure that the mulch be kept clear of the trunk base to avoid creating conditions favorable to the establishment and growth of decay causing fungal pathogens. Should it be necessary to add organic mulch beneath retained oak trees, packaged or commercial oak leaf mulch shall not be used as it may Nov. 12, 2024
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36 contain root fungus. Also, the use of redwood chips shall be avoided as certain inhibitive chemicals may be present in the wood. Other wood chips and crushed walnut shells can be used, but the best mulch that provides a source of nutrients for the tree is its own leaf litter.

Any added organic mulch added by the contractors shall be applied to a maximum depth of 4 inches where possible.
• Watering Adjacent Plant Material. All installed landscaping plants near the preserved sensitive natural communities shall require moderate to low levels of water. The surrounding plants shall be watered infrequently with deep soaks and allowed to dry out in-between, rather than frequent light irrigation. The soil shall not be allowed to become saturated or stay continually wet, nor should drainage allow ponding of water. Irrigation spray shall not hit the trunk of any tree. The contractors shall maintain a 30-inch dry-zone around all tree trunks. An above ground micro-spray irrigation system shall be used in lieu of typical underground pop- up sprays.
• Monitoring. An ISA certified arborist or ASCA registered consulting arborist shall inspect the trees preserved on the site adjacent to construction activities for a period of two years following the completion of construction. Monitoring visits shall be completed quarterly, totaling eight visits. Following each monitoring visit, a report summarizing site conditions, observations, tree health, and recommendations for promoting tree health shall be submitted to the city.

Additionally, any tree mortality shall be noted and any tree dying during the two -year monitoring period shall be replaced at a minimum 3:1 ratio on-site in coordination with the city.

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Addendum Evaluation
Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 37 Cultural Resources
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

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38 Previous CEQA Analysis Cultural Resources Findings
The 2024 SEIR identified a significant and unavoidable impact related to a substantial adverse change in the significance of a historical resource pursuant to §15064.5 and identified no feasible mitigation measures (CUL-1). The 2024 SEIR identified a less than significant impact related to a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5 (CUL-2). The 2024 SEIR also identified a less than significant impact for disturbing any human remains, including those interred outside of formal cemeteries (CUL-3) (Section 4.4, Cultural and Tribal Cultural Resources).

Addendum Analysis
Implementation of the CAP Update would result in physical changes to the environment that could occur in proximity to or involve encountering historical resources. For example, some improvements that result from the CAP Update, such as Measures T-1, T-4, T-5, T-8, T-9, CS-1, E-3.3, W-1, and W-2, would require limited ground disturbance . Energy efficiency improvements and building retrofits (Measure E-6) would involve minor changes to the exterior (e.g., rooftop solar panels) or interior (e.g., water heating and space heating and cooling systems) of existing buildings, and would not otherwise involve features with substantial height, bulk, or massing that would cause a substantial adverse change to a historic resource. Adherence to the relevant General Plan policies, the Historic Preservation Ordinance, and the relevant elements of the Carlsbad Cultural Resource Guidelines would protect historical resources from substantial adverse changes during CAP Update implementation.

Because ground disturbance associated with the implementation of CAP Update Measures T-1, T-4, T- 5, T-8, T-9, CS-1, E-3.3, W-1, and W-2 would be limited to shallow depths, comprised of artificial fill or previously disturbed soils, archaeological resources are unlikely to be encountered. In addition, construction activities associated with CAP Update implementation would occur in already disturbed developed areas such as roadways and parking lots. Zero emission vehicle charging stations (Measure T-8) would be installed in new and existing developments, and roadway improvements such as roundabouts, traffic circles, walkways, and bicycle infrastructure would occur along existing developed roadways. In addition, tree planting associated with Measure CS-1 would likely occur within city parks and public rights-of-way. Furthermore, the Carlsbad Cultural Resource Guidelines addresses treatment of cultural resources to avoid substantial adverse effects should they be encountered during ground disturbance activities associated with the CAP Update. Therefore, with adherence to the Carlsbad Cultural Resource Guidelines , implementation of the CAP Update would not cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5.

The Carlsbad Cultural Resource Guidelines Standard Treatment 11: Post -Review Discoveries section addresses treatment of human remains should they be disturbed as a result of ground disturbing activities. Moreover, human burials, in addition to being potential archaeological resources, have specific provisions for treatment in Public Resources Code ( PRC) Section 5097. The California Health and Safety Code (Section 7050.5, 7051, and 7054) has specific provisions for the protection of human burial remains. Existing regulations address the illegality of interfering with human burial remains, and protect them from disturbance, vandalism, or destruction. They also include established procedures to be implemented if Native American skeletal remains are discovered. PRC Section 5097.98 also addresses the disposition of Native American burials, protects such remains, and provides for the establishment of the NAHC to resolve any related disputes. All development projects are also subject to State of California Health and Safety Code Section 7050.5 which states that, if human remains are unearthed, no further disturbance can occur until the county coroner has made the necessary findings as to the origin and disposition of the remains pursuant to the PRC Section 5097.98.

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 39 If the remains are determined to be of Native American descent, the coroner has 24 hours to notify the Native American Heritage Commission which will determine and notify a most likely descendant (MLD). The MLD shall complete the inspection of the site and make recommendations to the landowner within 48 hours of being granted access. With adherence to these existing regulations as well as the Carlsbad Cultural Resource Guidelines, implementation of the CAP Update would not disturb any human remains, including those interred outside of formal cemeteries.

Applicable Mitigation Measures from the SEIR
There are no feasible mitigation measures from the 202 4 SEIR to reduce impacts related to cultural resources.

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40 Energy
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 41 Previous CEQA Analysis Energy Findings
The 2024 SEIR identified no impact for the wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation or for conflicts with or obstruct ion of a State or local plan for renewable energy or energy efficiency (Section 4.16.2, Energy).

Addendum Analysis
Construction activities associated with implementation of the CAP Update measures and actions would result in short-term consumption of energy resulting from the use of construction equipment.

The types of construction activities associated with the CAP Update would vary depending on the type of CAP Update measure. Examples of activities that would result from implementation of CAP Update measures include construction of new public zero emission vehicle and bicycle charging infrastructure, building efficiency retrofits, roundabouts or traffic circles, bicycle infrastructure, new solar carports, and water and wastewater system improvements (e.g., Measures T-1, T-2, T-3, T-4, T-5, T-8, T-9, E-3.3, W-1, and W-2). These activities would consume energy resources such as electricity, fuels, and non - renewable resources during construction. In addition, construction materials require energy to be produced, and would likely be used in projects that involve new construction or replacement of older materials. The California Green Building Standards Code (CALGreen) includes specific requirements related to recycl ing, construction materials, and energy efficiency standards, which would apply to construction projects envisioned by the CAP Update and help to minimize waste and energy consumption. Although implementation of the CAP Update would result in short -term construction activities that would consume energy resources, standard best management practices would discourage unnecessary idling and the operation of poorly maintained equipment during construction. In addition, the CAP Update includes measures that would reduce nonrenewable energy consumption during construction activities. For example, M easure OR-2 would increase the use of renewable and alternative fuel construction equipment, while Measure T-9 would establish city fleet regulations for idling, thus reducing construction vehicle idling time and further reducing construction related energy consumption.

Implementation of the CAP Update would improve operational energy efficiency and reduce the use of fossil fuels, for example through measures which reduce VMT (Measure T-2) and encourage zero emission vehicle use (Measure T-8), as well as measures which facilitate the increased generation and utilization of renewable energy Measures E-1 through E-6). The measures and actions in the CAP Update reduce GHG emissions, primarily by improving energy efficiency and decreasing consumption of fossil fuels and nonrenewable energy consumption. Thus, implementation of the CAP Update would not result in wasteful, inefficient, or unnecessary consumption of energy, consistent with the SEIR findings.

Where applicable, measures and actions associated with the CAP Update would be required to comply with CALGreen, the latest California Building Code (CBC) requirements, including CBC Energy Efficiency Standards, as well as all federal, S tate, and local rules and regulations pertaining to energy consumption and conservation. Through implementation of c ity policies as delineated in the c ity’s General Plan, and concurrent implementation of the CAP Update, measures and actions would support the San Diego Regional Energy Strategy renewable energy goals and would not conflict with any applicable plan, policy, or regulation adopted regarding renewable energy or energy efficiency.

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42 Conclusion
There are no changes in circumstances or new information of substantial importance that would require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in the severity of previously identified effects related to energy. The 2024 SEIR did not identify significant energy impacts and did not identify mitigation measures. The CAP Update would not result in any new or substantially more severe significant impacts related to energy.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to energy.

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Addendum Evaluation
Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 43 Geology and Soils
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

Less than
Significant None No No No Yes Yes
ii. Strong seismic ground shaking?
Less than
Significant None No No No Yes Yes
iii. Seismic-related ground failure,
including liquefaction?
Less than
Significant None No No No Yes Yes
iv. Landslides? Less than
Significant None No No No Yes Yes
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44 CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
b. Result in substantial soil erosion or the
loss of topsoil?
Less than
Significant None No No No Yes Yes
c. Be located on a geologic unit or soil
that is unstable, or that would become
unstable as a result of the project, and
potentially result in on- or off-site
landslide, lateral spreading,
subsidence, liquefaction, or collapse?
Less than
Significant None No No No Yes Yes
d. Be located on expansive soil, as
defined in Table 1-B of the Uniform
Building Code (1994), creating
substantial direct or indirect risks to
life or property?
Less than
Significant None No No No Yes Yes
e. Have soils incapable of adequately
supporting the use of septic tanks or
alternative wastewater disposal
systems where sewers are not
available for the disposal of
wastewater?
Less than
Significant None No No No Yes Yes
f. Directly or indirectly destroy a unique
paleontological resource or site or
unique geologic feature?
Less than
Significant None No No No Yes Yes
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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 45 Previous CEQA Analysis Geology and Soils Findings
The 2024 SEIR identified less than significant impacts for the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault (GEO-1); and for the risk of loss, injury, or death involving strong seismic ground shaking, seismic-related ground failure, including liquefaction or landslides (GEO-2). The 202 4 SEIR also identified less than significant impacts for substantial soil erosion or the loss of topsoil (GEO-3) and for on or off -site landslide, lateral spreading, subsidence, liquefaction or collapse , and location on expansive soils creating substantial direct or indirect risks to life or property (GEO-4). The 2024 SEIR identified less than significant impacts for soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater (GEO-5) and for the project to directly or indirectly destroy a unique paleontological resource or site or unique geologic feature (GEO-6) (Section 4.5, Geology and Soils).

Addendum Analysis
Measures and actions associated with the CAP Update include improvements to energy infrastructure (Measures E- 1 through E -6), development of roundabouts (Measure T -1), bicycle infrastructure (Measure T-4), pedestrian infrastructure (Measure T-5), and improvements to water and wastewater infrastructure (Measures W-1, W-2). The measures identified in the CAP Update do not propose new housing nor do they propose changes to policies or regulations related to land use or residential zoning.

Therefore, the CAP Update would not result in the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault or result in the risk of loss, injury, or death involving strong seismic ground shaking, seismic-related ground failure, including liquefaction or landslides. The CAP Update would not result in substantial soil erosion or the loss of topsoil or result in on or off -site landslide, lateral spreading, subsidence, liquefaction or collapse, and location on expansive soils creating substantial direct or indirect risks to life or property.

The measures and actions in the CAP Update would not require use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater.

Implementation of the CAP Update would include measures and actions (Measures T-1, T-4, T-5, T-8, T- 9, CS -1, E- 3.3, W -1, and W -2) that involve ground disturbing activities which could encounter paleontological resources in areas with moderate to high sensitivity. While encountering paleontological resources is possible during CAP Update implementation, it is unlikely because of the shallow depth of below ground disturbance associated with activities such as trenching to install zero emission vehicle and bicycle charging infrastructure and making improvements to public roadway rights -of-way to support walking and biking. For measures and actions requiring ground disturbance in areas underlain by sensitive geologic units, the Carlsbad Cultural Resource Guidelines require a review of primary literature and online databases, a paleontological assessment of the project area (plus a one-mile radius) by the San Diego Museum of Natural History, and a field survey to determine if paleontological resources or potentially fossiliferous sediments are present (if the sensitive sediments are exposed at the surface).

The results of these analyses are used to create a Paleontological Assessment Report which will provide recommendations to mitigate impacts to paleontological resources, if necessary. The Carlsbad Cultural Resource Guidelines set forth mitigation measures.

Additionally, General Plan policies 7 -P.7 through 7 -P.11 of the Arts, History, Culture, and Education Element would reduce impacts to paleontological resources by implementing the Carlsbad Cultural Resource Guidelines; requiring monitoring of ground- disturbing activities in areas known to contain Nov. 12, 2024
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46 paleontological resources; and ensuring proper treatment and consultation of paleontological resources discovered during ground-disturbing activities. With compliance with these guidelines and General Plan policies, implementation of the CAP Update would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to geology and soils.

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 47 Greenhouse Gas Emissions
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

48 Previous CEQA Analysis Greenhouse Gas Emissions Findings The 202 4 SEIR identified a significant and unavoidable impact for generating greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment and for conflicting with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases (GHG -1). It identifies Mitigation Measure GHG-1, which requires the preparation of this CAP Update to reduce the GHG emissions impacts identified in the 202 4 SEIR (Section 4.6, Greenhouse Gas Emissions).

Addendum Analysis
The CAP Update establishes measures and actions that would reduce GHG emissions in Carlsbad to levels that achieve its GHG reduction targets, which are aligned with the State’s GHG reduction goals.

The city’s 2035 target requires GHG emissions to be reduced 50 percent below 2016 levels (aligned with and extrapolated from SB 32) and reduced to 85 percent below 2016 levels by 2045 (aligned with AB 1279). The CAP Update measures and actions would meet the city’s GHG reduction targets.

In addition, implementation of the CAP Update would result in physical changes to the environment that would involve short -term physical changes that could result in GHG emissions . Several of the measures and actions identified in the CAP Update promote construction of new facilities or retrofitting of existing facilities that would generate construction -related GHG emissions. Some examples of activities that would generate constru ction-related GHG emissions include retrofitting of existing buildings and developments to transition to renewable energy generation (Measures E-1, E-6, W-1, and W-2), constructing roundabouts or traffic circles (Measure T-1), installation of solar carports (Measure E-3.3), installation of zero emission vehicle charging stations (Measure T -8), improvements to pedestrian and bicycling infrastructure (Measures T-5 and T-4), and implementation of activities related to urban tree planting (Measure CS-1).

Implementation of the CAP Update would reduce overall GHG emissions generated within the city, for example by encouraging the use of alternative fuels in vehicles and equipment (Measures T-8, OR-1, and OR-2), reducing VMT (Measures T-5, T-7, and T-10), improving energy efficiency (Measures E-1 through E-6), reducing waste generation (Measure WD-1), and increasing carbon sequestration (Measure CS-1).

In addition, measures that support energy efficiency and renewable energy generation would reduce GHG emissions at power plants generating electricity that serve the c ity. Thus, any temporary GHG emissions would be offset by the overall net benefit of GHG emissions reduction after implementation of the CAP Update. Therefore, implementation of the CAP Update would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment , nor would implementation of the CAP Update conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs.

The CAP Update would not result in any new or substantially more severe significant impacts related to GHG emissions.

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 49 Applicable Mitigation Measures from the SEIR
The CAP Update satisfies the requirements of 2024 SEIR mitigation measure GHG-1; no other mitigation measures related to GHG emissions impacts are identified in the 2024 SEIR.

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50 Hazards and Hazardous Materials
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 51 CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

52 Previous CEQA Analysis Hazards and Hazardous Materials Findings The 2024 SEIR identified less than significant impacts for the routine transport, use, or disposal of hazardous materials and reasonably foreseeable upset and accident conditions involving the release of hazardous materials (HAZ-1 ); e mitting or handl ing hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school (HAZ-2); being located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and creating a significant hazard to the public or the environment (HAZ-3); being located within an airport land use plan or within two miles of a public airport or public use airport and resulting in a safety hazard or excessive noise for people residing or working in the project area (HAZ- 4); and for impairing implementation of or physically interfering with an adopted emergency response plan or emergency evacuation plan (HAZ-5) (Section 4.7, Hazards and Hazardous Materials).

Addendum Analysis
The implementation of the CAP Update measures and actions would result in short -term and long- term changes related to hazards and hazardous materials as described below.

Construction activities and routine maintenance associated with implementation of the CAP Update would result in short-term, temporary changes to hazards and hazardous materials conditions in the city. Although the types of construction activities associated with the CAP Update would vary depending on the type of CAP Update measure, they could result in an increase in the overall routine, transport, use and disposal of hazardous materials in the city for construction activities. For example, Measures T-1, T-4, T-5, T-8, and T -9 would involve removing existing pavement; repaving roadway surfaces; painting or restriping pavement; modifying curbs; laying concrete, and installing traffic signals, lighting, landscaping, st reet furniture, and other amenities. Construction activities would be short-term and temporary and would be required to comply with relevant federal, State, and local regulations that require strict adherence to guidelines regarding the safe use, transportation, and disposal of hazardous materials as well as ensuring the reduction of the potential for humans or the environment to be affected by an accidental release of hazardous materials. Enforcement of these regulatory standards would ensure that the measures and actions facilitated by implementation of the CAP Update would not create a significant hazard through reasonably foreseeable upset and/or accident conditions involving the release of hazardous materials into the environment . Compliance with applicable regulations would ensure that any hazardous materials used during the implementation of the CAP Update would not result in hazardous emissions within one -quarter mile of an existing or proposed school.

Some improvements as a result of the CAP Update , such as M easures E-3.3, W-1, and W -2, would require limited ground disturbance which could result in the release of contaminants into the environment, if they are present in the underlying soils and/or groundwater. In the event that CAP Update implementation results in ground disturbance, any residual contamination that is encountered would be remediated to allowable regulatory levels in accordance with applicable county and State regulations before any ground-disturbing activities are permitted to occur. Therefore, implementation of the CAP Update would not result in a significant hazard to the public or the environment due to being located on a hazardous materials site.

The McClellan–Palomar Airport is located near the center of the city and has a Land Use Compatibility Plan (ALUCP) developed and adopted by the San Diego County Airport Land Use Commission in 2010 and last amended in 2011 (San Diego County Regional Airport Authority 2011) . The CAP Update measures and actions would not result in new or relocated residential land uses, other types of noise- Nov. 12, 2024
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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 53 sensitive receptors, or new places of permanent employment where residents or workers could be exposed to a safety hazard or excessive no ise. Therefore, implementation of the CAP Update would not expose residents or workers to a safety hazard or excessive noise levels.

Long-term changes resulting from implementation of CAP Update measures and actions would include improvements at or near grade level of existing roadways, new and upgraded bikeways and sidewalks along existing developed roadways and rights -of-way in the city, the installation of roundabouts or traffic circles to control traffic within the intersections of existing developed roadways , and the installation of zero emission charging infrastructure (through implementation of Measures T-1, T-4, T- 5, T-8, and T-9). However, these improvements would not adversely affect the capacity of roadways during an emergency or evacuation. CAP Update Measure T-1, which encourages the installation of roundabouts, would reduce congestion, thus increasing traffic flow and the ability to evacuate during an emergency. Furthermore, the CAP Update measures and actions would comply with the San Diego County Emergency Operations Plan (EOP) and the California Fire Code. Therefore, implementation of the CAP Update would not impair or interfere with adopted emergency response or evacuation plans.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to hazards and hazardous materials.

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Climate Action Plan Update

54 Hydrology and Water Quality
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

Nov. 12, 2024
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Addendum Evaluation
Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 55 CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

56 CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

Nov. 12, 2024
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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 57 Previous CEQA Analysis Hydrology and Water Quality Findings The 2024 SEIR identified less than significant impacts related to the violation of water quality standards, waste discharge requirements (WDR’s ), or otherwise degradation of surface or ground water quality (HYD-1); decreasing groundwater supplies or interfering with groundwater recharge (HYD-2); altering the existing drainage pattern s through the alteration of the course of a stream or river or through the addition of impervious surfaces resulting in substantial erosion or siltation on- or off-site, increasing the rate or amount of surface runoff in a manner which would result in flooding on- or off-site, or creating or contributing runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff (HYD-3); impede or redirect flood flows or in flood hazard, tsunami, or seiche zones risk release of pollutants due to project inundation (HYD-4); conflicts with or obstruction of implementation of a water quality control plan or sustainable groundwater management plan (HYD-5) (Section 4. 8, Hydrology and Water Quality).

Addendum Analysis
The implementation of the CAP Update measures and actions would result in short -term and long- term changes related to hydrology and water quality as described below.

The CAP Update measures involving construction activity would require minor grading, excavation, and other ground disturbance associated with removing existing pavement; repaving roadway surfaces; painting or restriping pavement; modifying curbs; laying concrete, and installing traffic signals, lighting, landscaping, street furniture, and other amenities (through implementation of Measures T-1, T-4, T-5, T-8, and T-9). Measures E-3.3, W-1, W-2, and CS-1 would also involve ground- disturbing activities, which could, depending on their location, potentially cause soil erosion which in turn can contaminate nearby surface water. However, implementation of the measures and actions in the CAP Update would be required to comply with State and local water quality regulations designed to control erosion and protect water quality during construction. This includes compliance with the requirements of the State Water Resources Control Board ( SWRCB) Construction General Permit, which requires preparation and implementation of a Stormwater Pollution Prevention Plan (SWPPP) for projects that disturb one acre or more of land. Erosion and sediment controls identified in the SWPPP would substantially reduce the amount of soil disturbance, erosion, and sediment transport into receiving waters, and pollutants in site runoff during construction. The CMC also sets forth requirements and BMPs pertaining to the mitigation of erosion, sediment control and runoff as outlined in CMC Chapter 15.12 and Chapter 15.16. Through compliance with all applicable regulations and permits, implementation of the CAP Update would not violate any water quality standards or WDRs or otherwise substantially degrade water quality ; substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site, increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site, or create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

The CAP Update measures and actions involving ground disturbing activities (Measures T-1, T-4, T-5, T-8, T-9, E-3.3, W-1, W-2, CS-1) could require the use of water for dust abatement as needed via a water truck. However, the ground disturbing activities would be temporary and intermittent and would not involve the substantial use of groundwater or otherwise affect recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level.

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Climate Action Plan Update

58 Furthermore, implementation of the CAP Update would not involve development of residential land uses or other types of land development or induce population growth in an area that would increase water demand. In addition, the city requires new construction and redevelopment to use low impact development (LID) techniques. These techniques would ensure that pervious surfaces are incorporated into development that would be facilitated by the project. Therefore, implementation of the CAP Update would not decrease groundwater supplies or interfere with groundwater recharge.

Long-term changes resulting from implementation of the CAP Update measures would include improvements at or near grade level of existing roadways, as well as minor changes to traffic intersections and walkways (through implementation of Measures T-1, T-4, T-5, T-8, and T-9), improvements to water and wastewater systems (Measures W-1 and W-2), and the planting of trees (through implementation of Measure CS-1). The CMC requires BMPs to control the volume, rate, and potential pollutant load of stormwater runoff from new development and redevelopment projects as a requirement of the Municipal Stormwater Permit. Furthermore, the city’s LID ordinance in Chapter 15.12.080 aims to specifically reduce the amount of surface runoff and aid in groundwater recharge through techniques such as infiltration, evapotranspiration, bioretention and/or rainfall harvest and additional uses in accordance with the requirements set forth in the MS4 permit and the LID standards manual. Given compliance with the above regulations and requirements, implementation of the CAP Update would not alter the existing drainage patterns or contribute runoff water in a manner which would result in substantial erosion, siltation, or flooding, nor would it exceed the capacity of existing or planned stormwater drainage systems.

The CAP Update would not result in any new or substantially more severe significant impacts related to hydrology and water quality.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to hydrology and water quality.

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 59 Land Use and Planning
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

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Climate Action Plan Update

60 Previous CEQA Analysis Land Use and Planning Findings The 2024 SEIR identified no impact for physically dividing an established community (LU-1) and a less than significant impact for conflicts with any land use plan, policy, or regulation (LU- 2) (Section 4.9, Land Use and Planning).

Addendum Analysis
Implementation of the CAP Update would not result in physical improvements that could physically divide a community. For example, measures resulting in construction of roundabouts or traffic circles (T-1) and bikeways (T-4) would reduce vehicle congestion and encourage bicycle trips, which would increase community connectivity and access. Implementation of M easure T-5 would also increase community connectivity and access by ad ding 6.1 miles of sidewalk to existing infrastructure and increasing the connectivity of sidewalk networks. As such, the CAP Update measures and actions are intended to improve, rather than impair, community connectivity and access throughout the city.

Therefore, implementation of the CAP Update would not result in construction of physical barriers that would physically divide an established community.

The CAP Update measures and actions would include improvements to the city’s existing pedestrian, bicycle, and transit network within developed areas (Measures T-1, T-3, T-4, and T-5). Implementation of the CAP Update would not change existing land uses and would comply with all applicable land use plans, policies, and regulations, including SANDAG’s 2021 Regional Plan and the city’s 2015 General Plan. Therefore, implementation of the CAP Update would not c ause a significant environmental impact due to a co nflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to land use and planning.

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 61 Mineral Resources
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

62 Previous CEQA Analysis Mineral Resources Findings
The 2024 SEIR identified no impacts to the loss of availability of a known mineral resource that would be of value to the region and the residents of the State, or the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan (Section 4.16.3, Mineral Resources).

Addendum Analysis
Carlsbad does not have mineral resources of economic value or active mining sites ( City of Carlsbad 2015), therefore the 2024 SEIR identified no impacts to the loss of availability of a known mineral resource that would be of value to the region and the residents of the State, or the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan . Similarly, implementation of the CAP Update would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State, or result in the loss of availability of a locally -important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to mineral resources.

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 63 Noise
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve a
New or Substantial
Increase in the
Severity of
Previously
Identified Impacts?
Are There New
Circumstances
Involving a
New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP
Update:
a. Generation of a substantial
temporary or permanent
increase in ambient noise levels
in the vicinity of the project in
excess of standards established
in the local general plan or noise
ordinance, or applicable
standards of other agencies?
Significant and
Unavoidable
(construction)
Less than
Significant
(operation)
MM NOI-1 No No No Yes Yes
b. Generation of excessive
groundborne vibration or
groundborne noise levels?
Less than
Significant
with
Mitigation
MM NOI-2 No No No Yes Yes
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Climate Action Plan Update
64 c. For a project located within the
vicinity of a private airstrip or an
airport land use plan or, where
such a plan has not been adopted,
within two miles of a public
airport or public use airport,
would the project expose people
residing or working in the project
area to excessive noise levels?
Less than
Significant None No No No Yes Yes
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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 65 Previous CEQA Analysis Noise Findings
The 2024 SEIR identified that although mitigation measure NOI -1 would reduce construction noise impacts for projects located within 500 feet of noise-sensitive land uses, it conservatively concluded impacts to be significant and unavoidable related to construction activities generating a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies ( NOI-1). The 202 4 SEIR identified a less than significant impact related to operational activities generating a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies (NOI-2). The 202 4 SEIR identified a less than significant impact related to the generation of excessive groundborne vibration or groundborne noise levels (NOI- 3) with implementation of mitigation measure NOI -2. The 202 4 SEIR also identified a less than significant impact related to excessive noise levels within the vicinity of a private airstrip or an airport land use plan or (NOI-4) (Section 4.10, Noise).

Addendum Analysis
The implementation of the CAP Update measures and actions would result in short -term changes related to noise as described below.

Construction activities associated with the implementation of the CAP Update, such as equipment use, construction of new facilities or retrofitting of existing facilities, would result in construction -related noise in the city. The types of construction activities associated with the CAP Update would vary depending on the type of CAP Update measure. CAP Update measures that may result in the generation of noise associated with construction activities include construction of new public zero emission vehicle and bicycle charging infrastructure, building efficiency retrofits, roundabouts or traffic circles, bicycle infrastructure, new solar carports, and water and wastewater system improvements (e.g., Measures T -1, T -2, T -3, T -4, T -5, T -8, T -9, E- 3.3, W -1, and W -2). Construction activities associated with CAP Update measures and actions may involve using construction equipment and vehicles to remove existing pavement; repave roadway surfaces; paint or restripe pavement; modify curbs; lay concrete, and install traffic signals, lighting, landscaping, street furniture, and other amenities. Construction equipment that could be used includes concrete saws for hardscape removal, backhoes or mini excavators, skip loaders, smooth drum rollers, dump trucks, and striping and paving machines, depending on the CAP Update measure. Construction activities associated with the CAP Update would be short -term and would not involve equipment or activities, such as blasting or p ile driving that would result in the g eneration of a substantial temporary or permanent increase in ambient noise levels or the generation of excessive groundborne vibration or groundborne noise levels.

Construction activities associated with the implementation of the CAP Update would not include two subterranean levels or more (generally more than 20,000 cubic yards of excavated soil material), and would be short term, thus avoiding a construction duration of 18 months. Construction activities associated with the implementation of the CAP Update would not require u se of large, heavy -duty equipment types used in housing development projects or require pile driving, therefore, mitigation measures NOI-1 andNOI-2 identified in the SEIR that were specific to impacts associated with housing development permitted under implementation of the Housing Element Update would not apply to the CAP Update.

Implementation of the CAP Update would be subject to existing city noise policies and regulations and General Plan policies and programs, specifically those found in the Noise Element , and other local agency polices and regulations pertaining to noise at any development site. Compliance with Nov. 12, 2024
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66 Occupational Safety and Health Administration (OSHA) standards for worker safety would minimize exposure of workers to excessive noise levels . Therefore, implementation of measures and actions included in the CAP Update would not create a permanent increase in ambient noise levels or produce a new permanent source of noise, and construction-related noise impacts would be reduced through enforcement of applicable city or other local agency noise policies.

Long-term changes resulting from operation of the measures and actions in the CAP Update would not permanently introduce any new stationary sources of noise (e.g., machinery, pumps, fans, compressors, or other equipment) and would not generate new vehicle trips that would result in transportation- related noise. The transportation-related measures such as Measures T-5, T-7, and T-10 would reduce VMT in the city by improving street connectivity, provide resources and incentives for alternative commutes, such as a carpool matching, and implement parking management strategies. Reducing VMT would reduce transportation-related noise. Therefore, the CAP Update would not result in a substantial temporary or permanent increase in ambient noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies or in the generation of excessive groundborne vibration or groundborne noise levels.

The CAP Update does not propose any new sensitive receptors (e.g., residences, schools) that could be adversely impacted from noise associated with aircraft flyovers. T emporary construction workers would not be adversely affected by aircraft flyover as noise generated from construction equipment would be the dominant noise exposure to them, which is generally dealt with by wearing ear plugs to prevent hearing damage. Furthermore, long-term maintenance workers would not sleep on-site; thus, they would not be exposed to potential sleep disturbance from aircraft flyovers. Thus, implementation of the CAP Update would not expose people residing or working near an airport to excessive airport/aircraft noise.

Applicable Mitigation Measures from the SEIR
The SEIR identified Mitigation Measures NOI-1 and NOI -2 for noise impacts. Neither of these mitigation measures are applicable to the CAP Update.

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 67 Population and Housing
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

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Climate Action Plan Update

68 Previous CEQA Analysis Population and Housing Findings The 2024 SEIR identified less than significant impacts for unplanned population growth ( PH-1) and substantial displacement of existing people or housing, necessitating the construction of replacement housing elsewhere (PH-2) (Section 4.11, Population and Housing).

Addendum Analysis
Construction activities associated with the implementation of the CAP Update could require a temporary increase in the number of construction workers traveling into the city to perform construction work. These types of projects would be small, short-term, and temporary construction projects, which would not require a large construction crew. Furthermore, construction workers would likely be from Carlsbad or the greater San Diego region and permanent, substantial relocation of workers would not be required. Therefore, implementation of the CAP Update would not result in substantial population growth or employment growth in the city.

Implementation of the CAP Update would not displace people or housing because the measures and actions in the CAP Update would not require the removal of existing housing and would not propose changes to policies or regulations related to land use or residential zoning or otherwise increase population growth in the city or surrounding areas. Therefore, implementation of the CAP Update would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 202 4 SEIR identified to reduce impacts related to population and housing.

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 69 Public Services
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

70 Previous CEQA Analysis Public Services Findings
The 2024 SEIR identified less than significant impacts associated with the provision of new or physically altered government facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services , including fire protection services (PS-1), police protection services (PS-2), and schools (PS-3) (Section 4.12, Public Services and Recreation).

Addendum Analysis
The CAP Update would not generate new or increased demand for fire protection services or interfere with or modify the ability of police and fire protection services to meet performance objectives or response times outlined in the 202 4 SEIR. The CAP Update does not include development of new residences or the creation of substantial numbers of permanent jobs requiring increased fire or police services. The CAP Update would not induce population growth in the community that would require school services, new or expanded park facilities, other public facilities. The measures and actions from the CAP Update would not generate increased demand for public services such that construction of new or expanded facilities would be required to maintain adequate service ratios . Therefore, implementation of the CAP Update would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 202 4 SEIR identified to reduce impacts rela ted to public services.

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 71 Recreation
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

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Climate Action Plan Update

72 Previous CEQA Analysis Recreation Findings
The 2024 SEIR identified less than significant impacts associated with the provision of new or physically altered parks, or the need for new or physically altered parks, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives (PS-4). The 2024 SEIR identified less than significant impacts related to the increase in use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated and for including recreational facilities or requiring the construction or expansion of recreational facilities which might have an adverse physical effect on the environment (PS-4) (Section 4.12, Public Services and Recreation).

Addendum Analysis
The CAP Update would not generate new or increased demand for parks and recreation facilities .

Typically, this impact occurs when a project induces population growth, such as new development or a business that would necessitate a large number of new employees. The CAP Update does not include development of new residences or the creation of substantial numbers of permanent jobs. Therefore, implementation of the CAP Update would not result in substantial adverse physical impacts associated with the provision of new or physically altered park facilities. Implementation of the CAP Update would also not increase the use of recreational facilities to the extent that substantial deterioration would occur or require the construction or expansion of recreational facilities.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 202 4 SEIR identified to reduce impacts rela ted to recreation.

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 73 Transportation
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

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Climate Action Plan Update

74 Previous CEQA Analysis Transportation Findings
The 2024 SEIR identified a less than significant impact for conflicts with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities (T-1). The 202 4 SEIR identified that although mitigation measure T-1 would aim to achieve VMT reductions for development projects, it concluded impacts to be significant and unavoidable related to CEQA Guidelines Section 15064.3, subdivision (b) (T -2). The 2024 SEIR identified a less than significant impact related to substantially increasing hazards due to a geometric design feature (T -3) and for inadequate emergency access (T-4) (Section 4.13, Transportation).

Addendum Analysis
Overall, implementation of the CAP Update (e.g., Measures T-1 through T-7 and T-10) would result in lower total annual VMT levels in the city. However, short-term construction activities associated with the CAP Update would lead to minor, temporary disruptions to traffic circulation patterns during the period of construction. Projects that would require construction include retrofitting of existing buildings and developments to transition to higher energy efficiency and renewable energy generation (Measures E- 1, E-6, W -1, and W -2), constructing roundabouts or traffic circles (Measure T -1), installation of solar carports (Measure E-3.3), installation of zero emission vehicle charging stations (Measure T-8), improvements to pedestrian and bicycling infrastructure (Measures T-5 and T-4), and implementation of activities related to urban tree planting (Measure CS-1).

Long-term transportation changes could result from actions aimed at diverting and eliminating solid waste; for example, generation of more compostable materials and demand for compost products (Measure WD-1) would lead to a need for haul trucks to transport these materials. Truck trips for hauling of organic waste to processing facilities would be offset by reductions in truck trips to landfills. Organic waste collected in the city is recycled at a Republic Services composting facility in Otay (City of Carlsbad 2024). Other long-term transportation changes associated with the CAP Update could result from actions that increase transit use and reduce commuting and traffic congestion. Actions such as increasing the number of roundabouts or traffic circles (Measure T-1), and incentivizing people to use alternative modes of travel (Measures T-2 and T-8) would lead to reduced traffic congestion. Changes to circulation patterns for pedestrian and cycling mobility modes would result from implementation of new pedestrian and bicycling routes, as well as enhancement of existing infrastructure (e.g., a dding lanes, buffers, and sidewalks). Implementation of the CAP Update would improve the operation of the circulation system in several ways, including fewer vehicle trips on roadways and highways and higher numbers of transit riders. Therefore, implementation of the CAP Update would not adversely affect the performance of the circulation system and would not conflict with any applicable transportation plans, ordinances, or policies.

Implementation of the CAP Update would not induce substantial population or employment growth in the city that would in turn generate increased VMT. Construction activities associated with the CAP Update measures and actions would not require a large construction crew. Any temporary VMT increases associated with construction activities would be more than offset by the CAP Update’s overall effect of reducing the long-term rate of VMT in the city. Therefore, CAP Update implementation would not conflict or be inconsistent with CEQA Guidelines section 15064.3(b). SEIR mitigation measure T-1, which would reduce VMT levels of housing development identified in the SEIR, is not applicable to the CAP Update because the CAP Update would result in decreased levels of VMT in the city.

The city maintains improvement standards that guide the construction of new transportation facilities to minimize design hazards for all users of the system. Furthermore, General Plan policies 3 -P.10, 3- P.12, 3-P.13, and 3 -P.16 would reduce impacts related to safe ty. Therefore, implementation of the CAP Update would not substantially increase hazards due to a geometric design feature.

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 75 In the short-term, implementation of the CAP Update would have the potential to affect emergency access during construction of individual projects facilitated by the CAP Update. For example, construction pertaining to improving pedestrian and bicycle infrastructure and safety (Measures T-4 and T-5) could temporarily alter existing roadways that serve as emergency access routes. In the long-term, the CAP Update would not result in new development or land uses that would require installation of emergency access routes. Activities implementing the CAP Update would not be permitted to conflict with regulatory requirements to provide adequate accommodation of fire access to structure frontages, multiple access points to development, as well as adequate width, height, and turning radius of roadways and access points, pursuant to California Building Code and California Fire Code requirements. Activities implementing the CAP Update would be required to comply with city and San Diego County standards and requirements and would undergo review by public safety officials as part of the approval process.

Additionally, General Plan policies 3 -P.12, 3- P.29, 3- P.30, and 3 -P.33 would prevent CAP update implementation from resulting in physical effects that impede or obstruct emergency access. Therefore, implementation of the CAP Update would not result in inadequate emergency access.

Applicable Mitigation Measures from the SEIR
The 2024 SEIR identified Mitigation Measure T-1 for transportation impact T-2 . This mitigation measure is not applicable to the CAP Update.

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Climate Action Plan Update

76 Tribal Cultural Resources
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

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Climate Action Plan Update

78 Previous CEQA Analysis Tribal Cultural Resources Findings The 2024 SEIR identified less than significant impacts related to causing a substantial adverse change in the significance of a Tribal cultural resource as defined in Public Resources Code Section 21074 that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k) or pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1 (CUL-4) (Section 4.4, Cultural and Tribal Cultural Resources).

Addendum Analysis
Implementation of the CAP Update would result in physical changes to the environment that could occur in proximity to or involve encountering tribal cultural resources. For example, some improvements that result from the CAP Update, such as Measures T-1, T-4, T-5, T-8, T-9, CS-1, E-3.3, W- 1, and W-2, would require ground disturbing activities, including minor grading and excavation, during which, depending on their location, a tribal cultural resource could be encountered. The Carlsbad Cultural Resource Guidelines addresses identification and treatment of tribal cultural resources that may be impacted as a result of the CAP Update. Therefore, implementation of the CAP Update would not cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k). Since the CAP Update would adhere to the Carlsbad Cultural Resource Guidelines, it would not cause a substantial adverse change in the significance of a tribal cultural resource, pursuant to criteria set forth in subdivision (c) of Public Resources Code §5024.1.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 202 4 SEIR identified to reduce impacts related to tribal cultural resources.

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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 79 Utilities and Service Systems
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

Nov. 12, 2024
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Climate Action Plan Update

80 CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

Nov. 12, 2024
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Addendum No. 1
Housing Element Implementation and Public Safety Element Update SEIR 81 Previous CEQA Analysis Utilities and Service Systems Findings The 2024 SEIR identified less than significant impacts related to the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunication facilities (UTIL-1); sufficient water supplies during normal, dry and multiple dry years (UTIL-2); adequate wastewater treatment capacity (UTIL-3); the generation of solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals and compliance with federal, State, and local management and reduction statutes and regulations related to solid waste (UTIL-4) (Section 4.14, Utilities and Service Systems).

Addendum Analysis
Implementation of the CAP Update would not increase development or induce population growth directly or indirectly, because measures and actions do not propose new housing nor do they propose changes to policies or regulations related to land use or residential or nonresidential zoning. Although tree planting (Measure CS-1) would potentially increase demand for water used for irrigation, the CAP Update would be required to comply with General Plan policies 9 -P.3 through 9 -P.6, which would reduce impacts to water services and facilities by promoting water saving measures such as water sub- metering, using recycled water for landscape irrigation, and using on -site gray water and rainwater collection systems . Therefore, the CAP Update would not result in demand for new or expanded infrastructure, including water, wastewater treatment, stormwater drainage, natural gas or telecommunication facilities would not increase to serve new population or development.

The implementation of the CAP Update would incrementally increase electricity consumption, for example through measures that increase the installation zero emission infrastructure (Measure T -8), consume energy more efficiently within buildings and water systems (Measures E-3.1, E-3.2, E-4.2 E- 6, and W-2), and install solar carports (Measure E-3.3). However, as discussed in the San Diego Gas and Electric Company (SDG&E)’s Integrated Resource Plan, SDG&E has existing plans in place to solicit additional long -term renewable contracts, including conventional and long- duration storage technologies (SDG&E 2022). The CAP Update’s support for using more renewable energy and more efficient natural gas consumption would decrease demand for natural gas infrastructure .

The implementation of the CAP Update would not involve development of residential communities or other non- residential development or induce population growth in an area that would increase demand for wastewater treatment. Further, it would not involve the construction of restroom facilities. Implementation of the CAP Update would not result in new habitable structures (e.g., housing, nonresidential development) that would generate wastewater, therefore, implementation of the CAP Update would not exceed the capacity of any wastewater treatment provider.

Implementation of the CAP Update would not induce increased residential or non -residential development, or population growth directly or indirectly, and there would be no increase in solid waste production as a result of the CAP Update. Although some solid waste could be generated during construction activities or through retrofitting buildings (Measure E -6), the solid waste generated would be minimal due to the nature of construction activities and associated improvements, and therefore would not exceed th e capacity of local facilities. Measure WD -1 includes strategies to continue to increase the diversion of waste from landfills, which is consistent with and would further State solid waste statutes and goals Therefore, solid waste generated as a result of the CAP Update would not be generated in excess of local standards or capacity of local infrastructure.

Nov. 12, 2024
Item #8 Page 587 of 637
City of Carlsbad
Climate Action Plan Update

82 Conclusion
There are no changes in circumstances or new information of substantial importance that would require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in the severity of previously identified effects related to utilities and service systems. The 2024 SEIR did not identify significant utilities and service systems impacts and did not identify mitigation measures.

The CAP Update would not result in any new or substantially more severe significant impacts related to utilities and service systems.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to utilities and service systems.

Nov. 12, 2024
Item #8 Page 588 of 637
Addendum Evaluation
Addendum 83
Wildfire
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

Nov. 12, 2024
Item #8 Page 589 of 637
City of Carlsbad
Climate Action Plan Update

84 CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?

Nov. 12, 2024
Item #8 Page 590 of 637
Addendum Evaluation
Addendum 85
Previous CEQA Analysis Wildfire Findings
The 2024 SEIR identified less than significant impacts for wildfire emergency response, access, and evacuation (WF-1); and related to slope, prevailing winds, and other factors that could exacerbate wildfire risks, installation or maintenance of associated infrastructure that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment, exposing people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post- fire slope instability, or drainage changes; and exposing people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires (WF-2) (Section 4.15, Wildfire).

Addendum Analysis
The implementation of the CAP Update would result in short -term and long-term changes related to wildfire as described below.

Implementation of the CAP Update would result in alterations of public roadways. The CAP Update measures and actions would include improvements at or near grade level of existing roadways, new and upgraded bikeways and walkways along existing developed roadways and rights -of-way in the city, and the installation of roundabouts or traffic circles to control traffic within the intersections of existing developed roadways (through implementation of Measures T-1, T-4, T-5, and T-8). However, these improvements would not adversely affect the capacity of roadways during an emergency or evacuation. New Class II bike lanes and Class II buffered bike plan s implemented per Measure T -4 would be separately from vehicle lanes using paint and therefore would not impede the movement of emergency vehicles or vehicles during an e vacuation event. CAP Update Measure T- 1, which encourages the installation of roundabouts, would reduce congestion, thus increasing traffic flow and the ability to evacuate during an emergency. Therefore, implementation of the CAP Update would not impair or interfere with adopted emergency response or evacuation plans.

Although the city is located within a Local Responsibly Area Very High Fire Hazard Severity Zone and adjacent to a State Responsibility Area Very High Fire Hazard Severity Zone, the CAP Update measures and actions would not include the construction of new housing and do not propose changes to policies or regulations related to land use or residential zoning. The CAP Update would not introduce new occupants that could be exposed to pollutant concentrations from a wildfire or the uncontrolled spread of as wildfire or require the installation or maintenance of associated infrastructure (such as roads, fuel brakes, emergency water sources, power lines or other utilities). Action CS -1.a would continue implementation of the existing Community Forest Management Plan and therefore the CAP Update would not result in changes to the types of trees planted within fire hazard severity zones.

Furthermore, activities associated with implementation of the CAP Update measures would comply with the San Diego County Emergency Operations Plan (EOP) and be subject to the California Fire Code (CFC), which includes safety measures to minimize the threat of fire. Implementation of the CAP Update would also be required, where applicable, to meet CBC requirements, including CCR Title 24, Part 2, which includes specific requirements related to exterior wildfire exposure. Impacts related to downslope or downstream flooding or landslides, as a result of runoff, post -fire slope instability, or drainage changes would be reduced by compliance with the CBC and CMC, as well as applicable policies from the Public Safety Element Update (policies 6 -P.20 through 6 -P.31). Compliance with applicable policies, codes and regulations would reduce the risk of loss, injury, or death from wildfire and the CAP Update would not exacerbate wildfire risks.

Nov. 12, 2024
Item #8 Page 591 of 637
City of Carlsbad
Climate Action Plan Update

86 Conclusion
There are no changes in circumstances or new information of substantial importance that would require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in the severity of previously identified effects related to wildfire. The 2024 SEIR did not identify significant wildfire impacts and did not identify mitigation measures. The CAP Update would not result in any new or substantially more severe significant impacts related to wildfire.

Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to wildfire.

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Item #8 Page 592 of 637
Addendum Evaluation
Addendum 87
7 References
California Department of Conservation. 2024. California Williamson Act Enrollment Finder. Available:
https://gis.conservation.ca.gov/portal/home/webmap/viewer.html?webmap=18f7488c0a9d4d299f5e9c33 b312f312. Retrieved March 28, 2024.

City of Carlsbad. 2015. City of Carlsbad General Plan Draft Environmental Impact Report. Available:
https://www.carlsbadca.gov/departments/community- development/planning/general-plan/related- documents/-folder-773. Accessed March 20, 2024.

_________. 2020. An Addendum to the Previously Certified Program Environmental Impact Report for the 2015 General Plan Update and Climate Action Plan (PEIR 13-02). Available:
https://records.carlsbadca.gov/WebLink/DocView.aspx?id=5154824&dbid=0&repo=CityofCarlsbad.

Accessed April 15, 2024.

_________
. 2021. 2021 Housing Element Update Addendum. Available:
https://records.carlsbadca.gov/WebLink/DocView.aspx?id=5312802&dbid=0&repo=CityofCarlsbad&cr=

1. Accessed April 15, 2024.

_________. 2023. City of Carlsbad Housing Element Implementation and Public Safety Element Update Draft Supplemental Environmental Impact Report. Available: https://files.ceqanet.opr.ca.gov/281700- 3/attachment/_PFNFkSV8FCkmdU1hXlW25tF98n-
BZ_pdzLkWZUQ3Kc2CA6Q1LZ_Xp9kUhHB0NSwdr7p4ccqp_dRZJ4S0. Accessed March 20, 2024.

_________. 2024. Organic Waste Composting. Available: https://www.carlsbadca.gov/departments/environmental- sustainability/reduce-reuse-recycle/organic-waste-recycling. Accessed April 15, 2024.

DOC. See California Department of Conservation.

San Diego Gas and Electric Company. 2022. Individual Integrated Resource Plan of San Diego Gas & Electric Company. Available:
https://www.sdge.com/sites/default/files/regulatory/SDG%26E%202022%20Individual%20Integrated%20 Resource%20Plan%20%28PUBLIC%29_0.pdf. Accessed March 28, 2024.

SDG&E. See San Diego Gas and Electric Company.

Nov. 12, 2024
Item #8 Page 593 of 637
From: Randi Greene
To: Katie Hentrich
Subject: Climate action plan
Date: Monday, July 8, 2024 5:47:47 PM
Please consider disallowing the burning of wood or debris at residential properties. It is destroying our neighbourhood air quality.

Sent from my iPhone
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Exhibit 6
Nov. 12, 2024
Item #8 Page 594 of 637
From: Gregg Ferry
To: Katie Hentrich
Subject: Climate Action Plan
Date: Thursday, July 11, 2024 2:12:03 PM
A couple of things I saw that was of interest.

Divest any investments that support fossil fuels. Only invest in funds, stocks, bonds, etc. that guarantee they will not invest in fossil fuels.

Until electric utilities use no energy from fossil fuels, these investments should be on the list for divestment, too.

4. Solar, Microgrids and Virtual Power Plants (VPP)
Not mentioned here was energy storage at the solar and Microgrid locations. This will make for a more resilient community.
--
Gregg Ferry
3344 Appian Rd
Carlsbad CA 92010
(805) 743-3779
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Nov. 12, 2024
Item #8 Page 595 of 637
From: Brian Magner
To: Katie Hentrich
Subject: Draft Climate Action Plan comment - Leaf Blower timeline Date: Friday, July 12, 2024 12:38:51 PM
Katie -
Great to see the draft Climate Action plan. I'm proud of Carlsbad to be addressing this, in a transparent way.

I am particularly glad to see leaf blowers being addressed, but am also wildly disappointed to see the lack of action on the timeline. The California Air Resources Board is requiring all new small off-road engines be zero emission by 2024, this year (
link). At least 25 cities across California and more than 100 nationwide have enacted legislation to regulate or ban gas-powered leaf blowers, many cities much larger than Carlsbad (Oakland, Beverly Hills, Santa Barbara).

Encinitas banned gas powered leaf
blowers starting in Jan 2020 (>4 years ago!!). And yet Carlsbad hasn't. On top of that, this plan proposes to develop a plan by 2030 and implement that plan by 2035.

There is a statement at the beginning of the Climate Action Plan report that states "The City of Carlsbad (city) strives to provide a clean and safe environment for residents, workers and visitors by protecting natural resources and facing the challenge of climate change head on. With these goals in mind, Carlsbad has become a regional leader in climate action with early and sustained efforts to reduce its contribution to climate change.". The City's website indicates: "Environmental sustainability is a key priority for City Council.".

If those statements were true, the timeline for banning gas powered leaf blowers should be to
develop a plan by the end of 2024 and implement that plan for no more gas powered leaf blowers by 2025. The 2030 and 2035 timelines are a terrible failure to take action on something that should be considered easy / "low hanging fruit".

There are dozens of implementation plan examples to pull from other cities.

There are already state and local programs with incentives for landscapers to transition to zero emissions equipment. My weekly landscaping company has already voluntarily transitioned to battery powered backpack leaf blowers and I'd be happy to share their name with anyone looking for a quieter landscaping company.

Carlsbad is already WAY behind so many other CA cities on this topic. It's false for Carlsbad to declare itself a leader and not take action now, this year, to ban gas powered leaf blowers. Please consider revising these targets.

Thanks,
Brian Magner
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Nov. 12, 2024
Item #8 Page 596 of 637
From: Lynda Daniels
To: Keith Blackburn; Teresa Acosta; Priya Bhat-Patel; Carolyn Luna; [email protected]; Katie Hentrich
Subject: Synthetic Turf - Carlsbad CAP
Date: Tuesday, July 16, 2024 8:04:56 PM
Please, no synthetic turf in our parks
Synthetic Turf and GHG’s
Synthetic turf is a major contributor to GHG’s throughout its lifecycle and must be included in the CAP:

Manufacturing
Oil extraction/fracking, petrochemical refining and manufacturing synthetic turf & underlayment pads all produce significant amounts of GHG’s.

Use
Synthetic turf off-gases methane and other GHG’s during use, while natural grass is a carbon sink.

End of Life
Fifty tons/acre of synthetic turf hazardous waste off-gases methane and other GHG’s for up to 1000 years.

Replacing synthetic turf with natural grass provides significant reductions in GHG’s and is clearly a climate issue.

Lynda

Nov. 12, 2024
Item #8 Page 597 of 637
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Nov. 12, 2024
Item #8 Page 598 of 637
From: Lynda Daniels
To: Katie Hentrich; Teresa Acosta; Priya Bhat-Patel; PD; Keith Blackburn; Carolyn Luna; [email protected]
Subject: CLIMATE ACTION PLAN COMMENTS
Date: Saturday, August 3, 2024 8:21:38 PM

CLIMATE ACTION PLAN COMMENTS

MAYOR, CITY COUNCIL AND KATIE,
I am very pleased with the draft of our CAP!

It includes so many ways to help Carlsbad meet our
sustainability goals!

In six different areas!!

Very detailed and well done!

I have a few minor suggestions:
page 3-20 - add WORKSHOPS to be planned by staff to educate residents page 3-21 - building efficiency can be improved by specific benchmarking ordinances - San Luis Obispo - has a great one you can copy!
page 3-13 - Eliminate natural gas use at city facilities AT END OF LIFE ("FEASIBLE" IS TOO VAGUE)

Lastly, include ALL LAWN EQUIPMENT, not just leaf blowers in the phasing out goal! Thank you for all the hard work the staff has done to make this CAP so good~ Lynda Daniels
4547 Picadilly Court
Carlsbad
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Nov. 12, 2024
Item #8 Page 599 of 637

August 6, 2024
Ka.e Hentrich
Climate Ac.on Plan Administrator
City of Carlsbad
Sent via email

Subject: Comments on CAP Update
Dear Ms. Hentrich,
We appreciate the eﬀort that has gone into this CAP update—building on the work of the past while also responding to new requirements and changing condi.on.

We also realize that there is broad discre.on in selec.ng the ac.ons to reduce local GHG emissions.

While there is much to commend in this document, our objec.ve with these comments is to suggest areas where we think some modiﬁca.ons would result in a more accurate analysis and more eﬀec.ve results.

Community Wide Emissions Inventory
- There are some interes.ng diﬀerences in comparing the current 2016 inventory results to those from 2012 that were used for the prior CAP Update. While several of the sectors increased as a percentage of total emissions, others decreased. Transporta.on remains the largest single sector and is accoun.ng for an increasing share of total emissions. Oﬀ road equipment showed a substan.al increase, more than doubling from

1.4% to 3 %. Since this is one of the hard data comparison points, it might be helpful to add some comments about trend line, and does this demonstrate the amount of progress that was an.cipated?
- Total emissions increased from 977,000 MT in 2012 to 981,000 MT in 2016- or about 1 MT/year. This rate of increase drops to an average of .6 MT/year for the period 2016-2035. It then makes a drama.c increase to 3.1 MT/year from 2035-2045. Is there an explana.on for these diﬀerences?
5020 Nighthawk Way - Oceanside, CA 92056
www.preservecalavera.org
Nonproﬁt 501(c)3 ID#33-0955504
1 Nov. 12, 2024
Item #8 Page 600 of 637
'Preserve Ca avera
Coastal North San Diego County
- It would be helpful to iden.fy what is excluded from the community inventory and where those emissions would get counted. We believe that includes the airport and Poseidon plant and there may be others.
- There is a clear statement that the city wants to set the example for sustainability improvements. Yet there are several areas where the City has full control, but delays ac.on un.l 2030 or later, for example, solar covers over city parking lots, ﬂeet replacement schedule and TDM for employees. Please consider using early city adop.on as part of strategy to expand results throughout the city. - It would be helpful to provide good baseline data for percentage of trips by each transporta.on mode, and a monitoring system to track and report on this over .me.

This would help inform related ac.ons for bikes, pedestrians and transit and the overfall TDM program. This puts the focus on results (increasing use of alterna.ve transporta.on) and not just ac.ons (building x miles of Class 1 bike trails). - For mul.ple ac.ons addressing building energy improvements, it is not clear which ac.ons are just complying with changes to state Building Code, and those for which the city is really going beyond the state requirements. These also focus very much on non- residen.al buildings. While much of Carlsbad’s housing stock is rela.vely new, there remains substan.al opportunity for reduced energy use form residen.al buildings.

Ac4on Items
WD-1 Solid and Organic Waste Diversion
We realize that this is an area that is going through recent changes to comply with new state laws. The basic waste stream analysis was based on data for the city of Oceanside.

That showed the largest share of this waste comes from food and paper. It would be desirable to target some ac.ons around these speciﬁc categories of waste. And to develop local data to measure results. CalRecycle requires some standard repor.ng which could form the basis for this.

T2- TDM
This is an area that has high poten.al beneﬁt, much of which is not being realized. The TDM ordinance is limited to new non-residen.al uses. Other places have expended such programs to address all land uses, with diﬀerent goals and measures targeted to each land use. There is also tremendous opportunity to improve the use of alterna.ve transporta.on by exis.ng businesses. While these may not be mandatory, at least encouraging this, spotligh.ng those who are making progress, working with the Chamber of Commerce to recognized program par.cipants could all start to both raise awareness and par.cipa.on by the broader community. We encourage Carlsbad to take a more comprehensive approach to TDM.
2 Nov. 12, 2024
Item #8 Page 601 of 637
T-4 Bikeway system Improvements
Seems like ac.on T-4.e to explore microtransit does not belong here.

T-6 Transporta.on System Improvements
This men.ons the Mul.-Modal TIF’s that are s.ll being developed but includes no bench marks and no quan.ﬁca.on. While it is premature to quan.fy results, clearly comple.ng this study is a key benchmark that should be included.

T.9 ZEV
Delaying restric.ons on city ﬂeet idling un.l 2030 is another area where the city could be an early adopter. But beyond that there is value to more compressive idling ordinances and enforcement.

T-10 Parking Management
This men.ons the parking studies underway for the Village, Beach and Barrio but with no benchmarks. Adding benchmarks for comple.on of these studies would beler integrate these ac.ons with the CAP .

OR-1 Oﬀ Road Equipment
The city could set an example here by adding an ac.on to require conversion of all city equipment and mandate on city contractors to also eliminate gas powered leaf blowers.

Also leaf blowers are a small percentage of this category. There would be value to include some ac.ons for those that are larger sources- construc.on and industrial.

CS-1 Carbon Sequestra.on
The inventory and ac.on focuses only on city owned trees. It is unknown what % of the total tree canopy that these city trees represent. But the tree canopy cover (TCC) is a city-wide measure that includes all of the non-city owned trees. The descrip.on should also note the tree plan.ng program in Carlsbad schools. To make real progress on the city wide TCC it is essen.al to also include all of the non-city owned trees. Key ac.ons should include project condi.ons to increase the number of trees and require their replacement, as well as enforcement of condi.ons to maintain and replace trees that were part of an approved landscaping plan, especially within areas with HOA’s.

The City also has earned the designa.on of a Tree City, and should include maintaining that as part of their ac.ons.

Monitoring and Repor4ng
We would like to see the city establish a Sustainability Commission that could provide input, and expand the city’s reach for the CAP and other sustainability programs. 3 Nov. 12, 2024
Item #8 Page 602 of 637
Quan4ﬁca4on – Appendix C
- Electricity Table 6- It is not clear how the city specific emission factor of 545 lbs CO₂/ MWH was determined – and this is key to all of the other computa.ons and appears to be the only city speciﬁc quan.ﬁer.
- Oﬀ road equipment- It is clear that leaf blowers account for a small percentage of the total oﬀ-road vehicle emissions-yet this is the only one targeted in CAP ac.ons. It would be good to work toward the other sources like industrial in future updates. - T-6 Transporta.on system improvements is based on 53 intersec.ons having signals synchronized but the benchmark for the ac.on item only shows 20 intersec.ons. These need to be consistent.
- T-2 TDM quan.ﬁca.on does not seem to be consistent with the ac.on item in the CAP or growth projec.ons used elsewhere in the Appendix. Table 23 shows 22k new commuters with 40% of trips using alterna.ve transporta.on with 26 mi/RT for 255 days/year for a VMT reduc.on of 70,983,251 by 2045. But Table 2 shows jobs increase 19,139, not 22k. With 40 % alterna.ve transporta.on and same trip length and days that is only a reduc.on of 49,764,000 VMT.
- T-3 Safe Routes to School is based on city of San Diego data with an average 1 mi RT to walk and 2.5 miles to bike to school. But Carlsbad high schools do not have boundaries and we would expect the average trip lengths are much longer than what was used. - T-5 Pedestrian System (and bike system improvements). Demographics show an aging popula.on with fewer of school age and high increases in the over 65 yr old age groups.

It would seem these changes in demographics would tend to reduce walking and biking trips and that is not reﬂected in the quan.ﬁca.on.

Thank you for considering our comments.

Sincerely,
Diane Nygaard, President
On behalf of Preserve Calavera
4 Nov. 12, 2024
Item #8 Page 603 of 637

August 12, 2024

To: Katie Hentrich, CAP Administrator

Dear Katie,

On behalf of the Sierra Club’s Coaster group, I’d like to share some insights with the Climate Action Plan (CAP) update you prepared. Our local Carlsbad Sierra Club team has had a chance to review and discuss the measures presented within this current update.

This update is a vast improvement over the original 2015 CAP . It is much more readable and comprehensive than the original. Staﬀ has done an excellent job of covering just about all potential areas for reducing greenhouse gas (GHG) emissions. We appreciate the eﬀort put forward by Ms. Hentrich to engage our team in her outreach to address our concerns.

Before addressing speciﬁc measures, we’d like to make some general comments:
• It’s unfortunate that the best GHG inventory for transportation we have is from 2016. Our city needs to work with SANDAG to get more current data and have it done regularly on a bi-annual basis. With this sector accounting for 50% of our emissions it’s critical that timely, reliable inventories are available to make informed decisions.
• Factored into our targets are the contributions from state and federal actions to lower our GHG emissions. For 2035 those combined actions account for 53% of our emissions, for 2045, 72% (calculated from Table 2-3, page 2-8). Very few agencies are meeting their targets in a timely manner and, therefore, the city should be aggressive in its goals to account for greater future costs and potential shortcomings by the state and national governments.
• While outreach to speciﬁc groups, including us, has been helpful, the general public knows little about the climate crisis and what the city is doing to mitigate it. Community workshops would be helpful to educate the public and encourage them to take positive actions in their own lives. Make “How you can help” a prominent link to the higher order Environmental Sustainability webpage with includes the CAP . • Somewhere within the CAP the city should set a target date for zero carbon that is at least as aggressive as the state of 2045.
• The city should expand its commuter mode shift goals citywide with targets to meet or exceed 50 percent walk/bike/roll/transit by 2035.

Energy measures:

E-1 – For municipal facilities consider opting up to 100% renewable energy with the Clean Energy Alliance (CEA) sooner than later. Also, replace, at end-of-life gas appliances with electric as much as possible.

E-2 – The target date for CEA to supply all its customers with 100% renewable energy is 2035. As with the amendment to the ﬁrst CAP , clean energy through CEA is one of the best ways of meeting our emission targets so consider a target for the city to have its default program for our residents be Green Impact (=100% clean energy) by 2030.

Nov. 12, 2024
Item #8 Page 604 of 637
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E-3.2 (non-residential) and E-4.2 (residential) – For new construction, now that the Berkeley case has been ﬁnalized, proceed with reach codes that apply high-performance, electric-preferred buildings. Encinitas is ﬁnalizing their ordinance and San Luis Obispo passed theirs last fall. Such ordinances look to optimize energy eﬃciency while still allowing for gas. Because the life span for new buildings is decades, Carlsbad should update its building codes now to get the most emissions savings by encouraging electriﬁcation.

E-5 – The Building Energy Benchmarking program is being taken over from the state. We need to ensure that the energy consumption reporting is accurate and timely and shared with building owners to help them make decisions about becoming more energy eﬃcient.

E-6 – Decarbonizing existing buildings will be a challenge. Therefore, aside from a target for 100% clean electricity, steps need to be taken to reduce or eliminate gas use in our current building stock. This means encouraging moving away from gas appliances AT LEAST at the end of their life span, if not sooner. As mentioned earlier, most residents don’t know much about climate actions including alternatives to gas water heaters, HVAC and cooking. Education and outreach are critical for this. The city should consider incentives to promote and track electriﬁcation installs when pulling permits.

Transportation measures:

This sector, accounting for 50% of our GHG emissions, is the most intractable with our southern California love of cars and independence. Bike lane and pedestrian improvements help and traﬃc calming measures promote road safety and lower emissions. But getting folks out of there cars will be diﬃcult without some incentives.

T-2 – The Transportation Demand Management (TDM) program for businesses was part of the original CAP and didn’t have much of an impact because it only addressed new businesses. In addition, it had a somewhat high threshold (average daily trips of >110 for employees) so only a few new businesses were mandated to have a TDM plan. There is room to lower that threshold to include more businesses, as pointed out in the CAP update.

Also, existing businesses, particularly those large ones, should somehow be included in the program. Again, the sooner the recruitment is increased the greater the impact on our GHG reductions. The public should get an annual update on this program as part of the annual CAP reporting.

T-3 – While the Safe Routes to Schools doesn’t speciﬁcally cover idling, it should. Because Carlsbad Uniﬁed School District has no school buses, the majority of our students drive themselves (high school) or have parents drop oﬀ and pick them up. This latter group often encounters lines at the schools resulting in excess idling which contributes to both GHG emissions and other air pollutants impacting student health. The city should be working with our school districts to implement anti-idling at our school sites and/or promoting much higher alternative modes of transport to and from schools.

T-7 – It’s good to see the TDM program being expanded to include city facilities/employees. The city should be a role model for businesses in our region and this is a good way to do that.

T-8 – To increase the use of EVs the expansion of charging infrastructure is important. While the city updates its EV Siting Plan, staﬀ should look at the Public EV Charging Infrastructure Playbook i f they haven’t already done so.

T-9 – Updating the city ﬂeet to all electric vehicles should be the target. Last summer the majority of the council voted to purchase 40 all gas-powered police cruisers rather than consider alternatives. Let’s hope this measure does a better job at addressing the problem of transportation emissions even in public service vehicles than we’ve seen recently. EVs will also have a payback in reduced maintenance costs as the ﬂeet ages.

T-10 – Proper parking management can be a valuable tool to incentivize employees not to drive. It should be included within the TDMs for both businesses and the city (T-2/T-7). As worded in the CAP update, this is a Nov. 12, 2024
Item #8 Page 605 of 637
rather vague measure and primarily addresses actions through existing plans like the Village and Barrio Parking Plan rather than a city-wide business approach to reduce employee trips. Free parking is not free and the city needs to look to the future in evaluating its parking strategies.

Oﬀ-Road Equipment Measure:

OR-1 – As written this measure only addresses gas-powered leaf blowers. As much as possible it should include all lawn equipment. To prevent a ﬁnancial hardship to landscapers, phase in this measure over 1-2 years, like Encinitas did, to allow for end-of-life conversion to electric equipment.

Carbon Sequestration Measure:

CS-1 – Community Forest Management which includes a replacement of 2:1 for city trees should be expanded to include HOAs which may have CC&Rs covering tree replacements. Oftentimes, our informal survey of some HOAs in Oceanside found that tree replacement policies are not be followed. Hopefully, Measure CS-1.c, the 5- year urban canopy study will include this.

In closing, we support all the measures present in the CAP update with our suggestions for improvements. The most critical component is this: the sooner the measures are implemented the greater the GHG savings. Global action isn’t happening fast enough. Every level of government should be doing their utmost to address the problem. Carlsbad has the opportunity to lead by example.

Thank you for your consideration.

Paige DeCino
Paige DeCino
Coasters Executive Committee member
Nov. 12, 2024
Item #8 Page 606 of 637
Nov. 12, 2024
Item #8 Page 607 of 637

NORTH COUNTY

TRANSIT DISTRICT
Bl0MissionAvenue August 15, 2024
Oceanside, CA 92054
(760) 966-6500
(760) 967-2001 (fax)
GoNCTD.com Katie Hentrich
Climate Action Plan Administrator
City of Carlsbad
1635 Faraday Ave
Carlsbad, CA 92008
Sent Via Electronic Mail: katie.hentrich@carlsbadca .gov Re: Carlsbad - Draft Climate Action Plan Update - July 2024 Dear Ms. Hentrich:

The North County Transit District (NCTD) appreciates the opportunity to provide input on the City of Carlsbad's Draft Climate Action Plan (CAP) Update, based on Notice of Draft Availability via Citywide email published on July 8, 2024. NCTD commends the dedicated efforts of the City staff in updating the CAP. Additionally , we recognize that the successful implementation of this plan will require ongoing collaboration among various stakeholders , including City officials, community members, and regional partners.

As a partner agency , NCTD plays a major role in the region's climate action efforts through our comprehensive public transit services. Since 1975, NCTD has served Northern San Diego County, reducing reliance on single-occupancy vehicles and lowering greenhouse gas (GHG) emissions . In FY18, our transit system saved 46 million auto miles traveled and reduced GHG emissions by 14,000 short tons. By 2050, NCTD anticipates saving 123 million auto miles traveled and reducing GHG emissions by 54,000 short tons (NCTD Public Benefits Study, 2021 ).

NCTD's recently adopted Sustainability and Climate Action Plan (SCAP) sets a strategic framework for achieving carbon neutrality by 2050. This includes transitioning to zero-emission vehicles, diversion of waste from landfill, and reducing emissions from electricity consumption . Supported by a recent grant from the California Department of Transportation (Caltrans), NCTD is also developing a Climate Adaptation and Infrastructure Resiliency Plan. NCTD is committed to collaborating with the City of Carlsbad and other stakeholders to enhance sustainability and resilience in our transportation system , creating a cleaner future for our region.

Nov. 12, 2024
Item #8 Page 608 of 637
Re: Carlsbad - Draft Climate Action Plan Update - July 2024 August 15, 2024

Page 2 of 3 ends

NCTD emphasizes that mode shifting to public transit, such as fixed-route bus and rail, is vital for reducing vehicle miles traveled (VMT) and overall carbon emissions.

By prioritizing the expansion and improvement of public transit infrastructure, public transportation options would be more accessible and attractive to residents . This effort not only supports our environmental goals and promotes equity by ensuring diverse and underserved communities benefit from reliable and affordable transit solutions, but it also meets the requests of the public feedback captured and presented in the CAP.

NCTD recommends the City include the following in the Final CAP:
• Measure T-5: Pedestrian System Improvements
o Prioritize Americans with Disability Act (ADA) sidewalk installation and improvements connecting to public transit services and bus stops. It is essential as it enhances accessibility, making it safer for residents to reach transit stops and to board our wheelchair accessible vehicles (WAV). Improved pedestrian infrastructure encourages more people to use public transit, thereby reducing reliance on single-occupancy vehicles, decreasing traffic congestion, and lowering greenhouse gas emissions .
o NCTD recommends adding the following sentence under Measure T- 5: "Equity Considerations :"
■ Prioritize sidewalk improvements around transit services and stops to ensure safe and accessible pathways for all residents, particularly for youth, and those from underserved, disabled, low-income, or older adult communities.
• Measure T-6: Local Transportation Improvements
o Modify the language in Action T-6.a: "Explore local transportation improvements to provide sustainable on-demand, flexible fleet transit and first-mile last mile solutions" to "Explore local transportation improvements to provide sustainable on-demand, flexible fleet transit and first-mile last mile solutions that complement existing fixed route bus and rail transit services."
■ This would reflect the sentiments of the community and stakeholders , as gathered through the CAP Update outreach. o Designate Action T-6.d: "Coordinate with regional and local agencies and partners on influencing transportation improvements throughout the region and within Carlsbad", as a primary implementation action. ■ To this action, NCTD recommends adding the following
language: " ... such as supporting fixed-route frequency increases, ensuring sidewalk infrastructure allows for ADA boarding/alighting , improvement of bus stop amenities to encourage ridership, and pursuing transit-supportive
infrastructure ."
Nov. 12, 2024
Item #8 Page 609 of 637
Re: Carlsbad - Draft Climate Action Plan Update - July 2024 August 15, 2024

Page 3 of 3 ends

o NCTD recommends adding the following content under Measure T-

6.d: Equity Considerations":
■ ''Engage transit riders and community leaders from
underrepresented or disadvantaged groups to provide input on transit projects."
■ "Ensure transit services are accessible to older adults and individuals with disabilities ."
Thank you again for allowing NCTD to review and comment on the City's CAP Update. Should you have any questions, feel free to contact me at (760) 966-6683 or via e-mail at kpersons@nctd .org.

Sincerely ,
Katie Persons
Director of Service Planning
cc: Chris Orlando, Chief of Planning, Marketing , & Communications , NCTD Nick Sofoul, Director of Strategic Planning & Transit Systems , NCTD Lillian Doherty, Director of Planning & Development , NCTD loni Tcholakova , Senior Transit Planner, Service Planning, NCTD Mary Balderrama , Senior Transit Planner, Service Planning, NCTD From: Vanessa Forsythe
To: Katie Hentrich
Subject: Carlsbad CAP Update Support & Comments
Date: Friday, August 16, 2024 10:42:33 AM
Greetings Katie
I support overall the updates to the Carlsbad Climate Action Plan. It is much improved in readability and indicating avaialable data and goals.

In addition I believe these also need to be brought forward: #1 a REACH code that indicates electric preferred to gas on new building construction, #2 incentives to replacing gas appliances with electric ( informing public existing rebate / tax incentives / longer term cost savings) particularly for electric/ induction stoves, electric water heaters and HVAC heating/ cooling systems; # ahead of state mandates prepare business and builders expected regulations # inform public with forums / workshops by staff addressing the CAP measures, need to reduce GHG locally related to climate shift included in upcoming city's 5 year plan at libraries, community centers and Carlsbad School District Office of Esucation; # have Community Communications Board on line that addresses CAP impacts including measures as where to where we are through EPIC ( as we get out in years realizing it will be harder to meet goals

- need to do more in short term)# doing well in parks except for south west but also need more trees ( always ) removal of invasive plants at parks and lagoons with planting of more native plants and natural ( grass) turf # no to synthetic turf ( releases VOCs and is plastic that ends up being incinerate more toxins in air) # put

solar over all parking lots and
municipal structures # post how much tonnage ( going to landfills) reduced by doing community food / green waste collection, # incentives with recognition businesses being electric and reducingTDM outside of working from home; # set 100% renewable through default CEA by 2030 , work with school district for posting of no idling signs ( doesn't require police enforcement). Lastly I concur with the recommendations presented in Paige DeCino's August 12 letter as member of Coastals Committee.

Thank you
Vanessa

Vanessa Forsythe RN MSN
She/Her
California Nurses for
Environmental Health & Justice
Leadership Council
https://climatehealthnow.org/
Clean Earth 4 Kids
Board Member
https://cleanearth4kids.org/

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Nov. 12, 2024
Item #8 Page 610 of 637
From: Colleen Blackmore
To: Katie Hentrich
Cc: Jeff Murphy; Paul Klukas; Colleen Blackmore
Subject: RE: Reminder - Draft Climate Action Plan Update available Date: Friday, August 16, 2024 11:48:00 AM
Attachments: CRC Summary of CAP Issues Tenant Imp.doc
Hi Katie,

We have reviewed the Draft CAP Update document and are surprised to discover that there is no mention of the Carlsbad Research Center’s Board of Director’s (CRC BOD) input and comments regarding the increased costs to CRC business and property owners that these policies produce.

TI thresholds in the document are still dollars-based $200,000 and $1 million, even though the CRC finds that there is no direct relationship between cost of TI improvements and pollutant emissions, and that the CRC is already observing that routine building improvements and updates in Carlsbad’s premier business park are being curtailed as the result of the penalizing costs associated with the added solar and transportation-demand improvements.

We see no mention of the CRC BOD’s recommendation to use “change in intensity of use” or “percentage of floor area increase” as thresholds for the CAP-required improvements, rather than assessed value.

There is no mention of the economic costs to business, which is ultimately borne by the community in the form of higher costs of products and services.

We also expected that our memo sheet provided to City Staff (copy attached), which included a few recommendations, would at least be included in the Appendix.

Please let us know why
our input was not considered in your Draft CAP Update.

Thank you.

Colleen M. Reilly
President
Carlsbad Research Center Owners’ Association

THE BLACKMORE COMPANY
1811 Aston Avenue
Suite 102
Carlsbad, CA 92008
760.804.9600

From:

Katie Hentrich <[email protected]>
Sent: Monday, August 12, 2024 9:08 AM
To: Katie Hentrich <[email protected]>
Subject: Reminder - Draft Climate Action Plan Update available Nov. 12, 2024
Item #8 Page 611 of 637

Good morning,

I wanted to send a reminder about providing feedback on the public draft of the city’s Climate Action Plan Update.

A Planning Commission workshop will be held on September 4, 2024. This workshop is open to the public. This will be an informational item only; the Planning Commission will not be making a recommendation to the City Council.

Staff will then present the Draft Climate Action Plan Update to the Planning Commission at the October 2, 2024 meeting.

Staff anticipate a presentation to the City Council later in the fall.

If you are interested in providing input, you can:

Review the executive summary here (English / español)
Review the public draft here
Submit a comment to staff to be included in the Planning Commission workshop materials
Please send comments to [email protected] by Friday, August 16 Comment in writing or in person to the Planning Commission for the September 4 workshop
I’d like to also offer my time to go over any questions or comments you may have. If you’d like to meet or have a larger group you would like me to share this information with, please let me know and we can set something up.

All comments submitted for the Planning Commission workshop will be included in the upcoming Planning Commission and City Council staff reports. Following the Planning Commission workshop, we will send more information on how to participate at the other upcoming meetings.

If you have already submitted a comment or scheduled a meeting with me, please ignore this message and thank you very much for your time.

Please do not hesitate to reach out if there are any questions.

Do you need an interpreter or
any other assistance in order to participate? Please call me at 442-339-2623. ¿Necesitas un intérprete o cualquier otra asistencia para participar? Comunícate al 442-339-2623.

Thank you very much for your consideration and participation,

Katie Hentrich
she | her | hers
Climate Action Plan Administrator
Environmental Sustainability
City of Carlsbad
1635 Faraday Ave.

Carlsbad, CA 92008
www.carlsbadca.gov

442-339-2623 | [email protected]
Nov. 12, 2024
Item #8 Page 612 of 637
•
•
•
• • •
•
0 City of
Carlsbad

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Nov. 12, 2024
Item #8 Page 613 of 637
Carlsbad
Research Center

1530 Faraday Avenue Suite 100 • Carlsbad, CA 92008 • (760) 931- 0780 • (760) 931-5744 Fax

CAP DISCUSSION ITEMS – TENANT IMPROVEMENTS

Subject. Carlsbad Research Center R&D/Office Building Tenant Improvements (TI’s)

Problematic City of Carlsbad CAP Requirements. The new City of Carlsbad CAP requirements state that all TI projects in existing buildings must comply with the following;

(a) TI projects valued at over $200,000 or adding 1,000 sf or more in floor area must address consistency with the Energy Efficiency and Transportation Demand Management factors identified in the CAP Checklist; and,

(b) TI projects over $1 million valuation must also address increased Energy Efficiency factors, and increased Transportation Demand Management considerations.

Our experience on how the above CAP requirements negatively affect the CRC tenant improvements fall into two main categories, as follows:

ISSUE #1:

Using the Cost of TI Improvements as a Threshold is Unrelated to Reduced GHG’s. The threshold valuation limits adopted by the City are so low that even very minor TI’s, where no substantive change in use or intensity of the floor area is proposed, trigger additional costly energy efficiency and complex transportation demand analysis and improvements. In the CRC, it is not unusual for a simple tenant change to result in over $200,000 or over $1 million valuation of TI’s. This is particularly true in today’s inflationary financing and construction climate.

Recommendation. An improved approach could be considered, such as “change in use” or “percentage of floor area increase”. In our experience, these factors (whether enforced through substantive policy refinements or as interpretive guidelines) more directly result in a tenant’s ultimate contribution to energy demand and commuter GHG emissions. Using a percentage, rather than a minimal finite limitation, would allow relatively minor TI’s that simply re-arrange [or reduce the intensity] of the same uses to be undertaken without enduring the costly CAP improvements.

ISSUE #2:

The Existing Thresholds Discourage Improvements . As mentioned, virtually all TI’s in existing buildings in the CRC are appraised in excess of the $200,000 limit. TI’s costing this amount require installation of solar panels and transportation demand requirements and improvements.

The cost of the added expense of the solar and transportation improvements frequently discourages the improvements, as they make the TI’s cost prohibitive. Further, many building owners request TI’s in order to upgrade a vacant floor area in advance leasing, in the hopes that the improvements will upgrade the building and attract a high-quality tenant. Accepting costly solar panel requirements or preparing a TDM plan without specific knowledge of the tenant or their operating procedures is largely imprecise guesswork, and most likely to be inaccurate.

Reconfiguration of floor area does not automatically denote increased CAP emissions. So, this lack of accurate assumptions in the CAP analyses and resulting conditions; (a) are likely to be erroneous, (b) engender resistance from potential tenants, and (c) put Carlsbad at a disadvantage in the R&D and office leasing market.

Nov. 12, 2024
Item #8 Page 614 of 637
Carlsbad
Research Center

1530 Faraday Avenue Suite 100 • Carlsbad, CA 92008 • (760) 931- 0780 • (760) 931-5744 Fax

Recommendation. An improved approach could be considered for these generic TI’s that improve Carlsbad’s look and business climate. This approach could involve deferring identification of the specific CAP-required improvements until some later point in the business- authorizing process, such as a condition of business license issuance. This will allow the required analysis of the business to be conducted by the entities who are most knowledgeable of the business operations. Premature analysis of business operations and resulting GHG emissions results in confusion, and distorted requirements.

ISSUE #3
Energy producing equipment on existing buildings is too expensive. Solar or alternative energy producing equipment is too costly to achieve on existing buildings. The updated building codes already require increased energy efficiency (energy efficient HVAC units, LED lighting, Title 24 controls, reduced water flow plumbing fixtures, etc.). Solar panels or other alternative energy facilities necessitate expensive structural and mechanical retrofits of existing buildings, making routine TI improvements cost prohibitive.

Recommendation. TI compliance with the updated building codes should be considered satisfactory mitigation for energy efficiency with regard to CAP compliance.

ISSUE #4
Insignificant increases of “demand” should not trigger CAP upgrades. It does not seem equitable to require costly improvements when no relationship exists between the projected emissions “demand” resulting from the proposed TI’s and the CAP requirements.

Recommendation. TI’s that result in minimal or less intensity of CAP emissions should be considered exempt from the CAP requirements. The removal of existing TI improvements should be credited against any corresponding increase in intensity for purposes of analyzing and applying CAP upgrades. Thus, if the net balance of emission generation (increase of x number/size vs. removal of x number/size) is positive, the CAP requirements would be prescribed. If the net balance between increase vs. decrease is even or negative, no CAP improvements should be required.

Nov. 12, 2024
Item #8 Page 615 of 637
From: Zachary Zeilman
To: Katie Hentrich
Cc: Mitch Silverstein; Jasmine Mikesell
Subject: Comments for Carlsbad Climate Action Plan Update Date: Friday, August 16, 2024 1:39:47 PM
Hi Katie,
Thank you and Aidan for meeting with us a few weeks ago to discuss the Carlsbad CAP and other related climate items.

Please see below for comments from Surfrider San Diego Chapter that we would

like
considered

the update. Apologies that the formatting is a little off.

1. Water

1. Decrease ornamental turf beyond state law requirements and incentivize native and/or drought tolerant lawns through a “xeriscaping” requirement

2. Energy

1. Develop a reach code for electrification with different standards for residential and commercial, recognizing that residential contributes an outsized share of GHG but that financial burden may be excessive on households, particularly lower and middle-income

2. Conduct a study for implementing solar-covered carports or increase solar in other ways on City-owned properties or partner with/incentivize private landowners where appropriate

3. Conduct outreach and pilot programs to decarbonize existing buildings voluntarily
i.

Apply square footage to existing reach codes

ii.

Develop an incentive program such as appliance trade-outs

3. Nov. 12, 2024
Item #8 Page 616 of 637
Solid Waste

1. Create a fee structure based on how much waste households dispose of based on volume or weight (Consider examples from other cities, such as proposed updates to the City of San Diego People’s Ordinance or Dresden, Germany)

2. Mandate and measure organic recycling diverted from landfills. Develop a program to provide organics compost to farms for soil or consider plans to send to or construct an anaerobic digestion facility

4. Transportation

1. Develop a percentage goal for VMT reduction that harmonizes with the 2022 CARB Scoping Plan which calls for a 25% reduction

2. Fund electric schools buses (or any school buses) to reduce emissions and VMT for individual households dropping kids at school, while also being more equitable

3. Implement a bike sharing program that could be regional between Oceanside and Encinitas to immediately help first/last-mile difficulties

4. Parking Management Strategies
i.

Eliminate or reduce parking minimums for development

ii.

Shared or unbundled parking for new developments, commercial & residential

iii.

Quantify the Parking Management Plan (2017) adopted for downtown area and approve by-right

5. Adopt and implement a Safe Routes to School Plan that incorporates safe walking and biking infrastructure between neighborhoods, schools, and other Nov. 12, 2024
Item #8 Page 617 of 637
public facilities

5. Other
Community Forestry Plan - Look into feasibility of native plant ordinance too that are drought tolerant. Remove palms and eucalyptus from preferred trees.

Thanks again!
Zack
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Nov. 12, 2024
Item #8 Page 618 of 637
August 16, 204
Mayor Blackburn and Council,
City of Carlsbad
1635 Faraday Ave, Carlsbad, CA 92008
Via Email
Re: Climate Action Campaign recommendations for Carlsbad’s Climate Action Plan Update
Dear Mayor Blackburn and Council,
Climate Action Campaign (CAC) is a San Diego based nonprofit organization with a simple mission: create a zero carbon future through effective and equitable policy action. We have played an active role in the development of Climate Action Plan’s (CAP) throughout the region since 2015.

Climate Action Plan Administrator Katie Hentrich reached out to us to ask that we provide comments on your draft CAP . Here are our comments and recommendations:

What we Applaud in the CAP Update:
● Ensuring the City reaches 100% clean energy is crucial for reducing emissions and ensuring a just, climate-safe future. The draft CAP update has strong goals in Measure E-2 to set 100% renewable electricity as the default option for Clean Energy Alliance customers in the City. This is a critical step towards the clean energy future we need and are pleased to see Carlsbad incorporating this as a priority in the CAP .

Upgrade Clean Energy Measures
With natural gas being responsible for 14% of Carlsbad’s greenhouse gas (GHG) emissions, electrifying new and existing buildings are essential actions for reducing pollution and improving air quality.
● Measures E-3 and E-4: Measures E-3 and E-4 address methane gas in new construction and identify ways to update existing reach codes to further reduce the impacts of gas in residential and nonresidential buildings, though stronger and more detailed timelines for implementation are needed. Once the new state building code is Nov. 12, 2024
Item #8 Page 619 of 637

CAMPAIGN

SAN DIEGO/ ORANGE COUNTY/ LOS ANGELES
adopted next year, Carlsbad can choose the voluntary option to ensure new buildings are safe, healthy, and climate resilient.
● Measure E-5:The current draft CAP update includes an important foundational step to modernize and make existing buildings safe and energy-efficient in Building Energy Benchmarking in Measure E-5, but benchmarking only supports critical information-gathering and analysis. The CAP update is missing a Building Performance Standard which is necessary to regulate pollution from existing buildings. Without a standard, Carlsbad will not be protecting their residents from dangerous exposure to fossil fuel pollution.
● Add this Missing Measure: A measure should be established for developing and implementing a Building Performance Standard and should include scope, scale, estimated costs, specific planning and implementation timelines, and an outline for community and stakeholder engagement. It is also essential that equitable electrification for Communities of Concern and new job opportunities for fossil fuel workers be key elements in all building electrification strategies.

Upgrading Transportation Measures
The CAP’s cumulative measures to address GHG emissions from transportation are woefully insufficient. By the City’s own projections, transportation emissions will still be the highest sector for GHGs by 2045.

On August 23, 2023, the City of Carlsbad declared a local state of emergency regarding a 233% increase in collisions involving bikes and ebikes between 2019 and August 2022. As the use of e-bikes increases it necessitates the adoption of safe transportation infrastructure to help facilitate safe streets for everyone, especially near and around schools. ● Measure T-3: We commend the City of Carlsbad on their initiative to address Safe Routes to Schools to help promote safe walking and biking. However, the emphasis needs to be on engineering and redesigning streets with safe infrastructure since education and enforcement are not elements that address the lack of safety in the built environment where streets are built for high speed and cut through traffic. ● Measure T-1, T-3 and T-5: The CAP’s Safe Routes to School is missing important pedestrian safety components for safe crossing such as speed tables and flashing beacons for mid-block crossings. Sidewalks are not enough because at some point folks need to cross fast and dangerous streets.
● Measure T-4: Paint is not enough. The City of Carlsbad needs to take a Class IV approach where biking is secure, safe and separated from fast, free flowing traffic. We commend the City on their plans for Class I bike lanes, but the need for a network of safe and protected bike lanes requires a Class IV approach in addition to multiuse bike trails.

Nov. 12, 2024
Item #8 Page 620 of 637
● Measure T-3, T-6 and T9: The reduction of speed is a missing tool in the CAP . Utilizing AB 43 to slow streets will be essential to ensuring Safe Routes to School. AB 43 is also a powerful tool to create a network of streets that are 35 MPH or less for NEV/LSV for residents, staff and tourists alike. Carlsbad is the perfect city for street-legal golf carts and neighborhood electric vehicles. In fact, the City’s fleet conversion to all electric can include NEVs.

Centering Equity and Green Jobs
Overall, equity has been thoughtfully and clearly integrated throughout the CAP update. We acknowledge and appreciate the effort Carlsbad has made with reaching out to communities, especially tribes, as well as the efforts put into engaging communities through workshops, listening sessions, and events. Here are some recommendations for improvements. ● The City of Carlsbad needs to prioritize Communities of Concern, who are first and foremost impacted by the climate crisis, by identifying funding to create tools such as the Climate Equity Index that cities like Chula Vista and San Diego have. ● The City of Carlsbad should partner with universities, schools, and labor unions to ensure access to apprenticeship programs and other pipelines for high-paying jobs within renewable energy or circular economy sectors.
● Finally, we encourage the City of Carlsbad to consider community residents who may not be residents due to lack of affordability, but are still vital members of the community as workers or are tribal members who have been displaced from their ancestral coastal homelands.
○ Examples include ensuring that workers have access to rebates or home-owner purchased electric leaf blowers (to account for bans on gas-powered leaf blowers) as well as access to affordable and accessible renewable energy-based transportation options. This access should include education about alternatives to gas-powered appliances, as well as potential travel vouchers or rebates for electric vehicles or bicycles.
○ Other examples include working with tribes to ensure renewable energy-based transportation from the reservations to the coast through electric shuttles or vouchers for public transportation options.

Thank you for the opportunity to weigh in on the development of this critically important document.

Sincerely,
Anthony Dang
Policy and Community Outreach Manager
Climate Action Campaign
Nov. 12, 2024
Item #8 Page 621 of 637
NAIOP San Diego
BOMA San Diego
San Diego Regional Chamber of Commerce
California Apartment Associa=on
Southern California Rental Housing Associa=on
California Restaurant Associa=on
Building Industry Associa=on of San Diego
San Diego County Lodging Associa=on
Associated General Contractors San Diego

TRANSMITTED ELECTRONICALLY
August 16, 2024
Ka/e Hentrich, CAP Administrator
Environmental Sustainability
City of Carlsbad
1635 Faraday Ave.

Carlsbad, CA 92008
RE: DRAFT Climate Ac/on Plan Update Comments
Dear Ka/e:

On behalf of the undersigned coali/on, please accept our comments on the draP Climate Ac/on Plan (CAP) Update documents the City has posted on its website. As previously communicated, much of the draP iden/ﬁes goals and thema/c requirements, but does not provide suﬃcient detail to determine what would actually be required of Carlsbad property owners.

Unfortunately, numerous jurisdic/ons have taken the same approach, which seems by design, to build momentum for yet to be iden/ﬁed implementa/on measures that could be costly and unachievable. Our coali/on has strong concerns about this approach because this masks the true costs and actual implementa/on challenges, and obfuscates for the public what might be required of them to achieve these new standards.

Targets WILL be met WITHOUT the need to adopt more stringent requirements Nov. 12, 2024
Item #8 Page 622 of 637
It should also be noted that the city’s own analysis shows that you are going to achieve the state required targets by 2035. The measures to achieve this are already extremely onerous, and going beyond them will have signiﬁcant impacts to the city’s ability to create housing and jobs.

Longer term goals are so far out that it would be prudent to hold oﬀ on new and more onerous mandates on private property owners, par/cularly in these uncertain economic /mes.

State requirements are only geHng STRONGER
Given the stated desire to address longer term target “trajectories,” it’s important to consider that the State of California, both through the legisla/ve process, as well as the regulatory process, through its triennial building code updates, is constantly ratche/ng up its energy conserva/on and GHG reduc/on requirements. This applies to both the built environment, through Title 24, among others, as well as in transporta/on for both commercial and personal vehicles. In fact, the State of California will soon be releasing its new statewide building code before the end of the year, which promises an even more stringent set of energy conserva/on and GHG reduc/on requirements. The City should wait un/l these new rules are published and then analyze their beneﬁcial impacts on further reducing GHG emissions to determine what, if any, delta to the targets would exist.

Transporta=on is the MAIN driver of GHG, not the built environment As the greenhouse gas inventory conducted by city staﬀ demonstrates, the vast majority of climate emissions are from transporta/on. This is an area where the state is making big strides, par/cularly with recent mandates to phase out sales of gas combus/on consumer and business vehicles. On the local level, our coali/on believes the best way to control transporta/on emissions is to increase job crea/on adjacent to where people live. In Carlsbad, while there has been excellent planning to try and balance jobs and housing, more could be done on this front to improve the distance between where people live, where they work and where they seek their services. Adding new and onerous burdens to construc/on will only work against this kind of meaningful co-loca/on that balances jobs-housing-services.

Carlsbad property owners and jobs creators are PARTNERS in the eﬀort The ability to achieve these ever increasing and stringent goals are an indica/on of the strong partnership with the business community and your residents. Our coali/on has invested millions of dollars in upgrading for energy eﬃciency, and building new structures that are some of the “greenest” on the planet. Rather than pursuing aspira/onal and economically debilita/ng “REACH” codes, the City should instead look at incen/ves to help further promote GHG reducing ac/ons by the private sector. The City should celebrate the greenest developments.

INCENTIVES work when seeking more than what is already required Nov. 12, 2024
Item #8 Page 623 of 637
An excellent example is in the installa/on of photovoltaic as well as the acquisi/on of electric vehicles and installa/on of EV chargers. When incen/ves, like tax credits, are applied, acceptance and adop/on increase exponen/ally. When they stop or are reduced, like the recent decision by the CPUC to change net metering rules, adop/on drama/cally drops. The City should focus on incen/ves for change, rather than mandates which only harm small businesses and divert limited investment capital.

Costs to the private sector were never fully analyzed
The City did a good job of analyzing the impact of the proposed CAP requirements to itself. This included an analysis of the cost to the city of improving all city buildings and the vehicle ﬂeet, as well as the cost of city staﬀ /me to implement and regulate the CAP . Unfortunately, the city did not similarly detail the impact to the private par/es who are subject to these poten/al new and signiﬁcant requirements. We would respecfully ask that staﬀ be directed to do a meaningful cost impact analysis and one that takes into considera/on the investment cycle for businesses. We have seen, when these kinds of analysis are done, the consultants oPen refer back to extremely long /meframes for amor/za/on of the cost, similar to a mortgage type ownership length. Businesses assess investments in capital improvements over a much shorter period of /me, usually about 5 years. Despite the comments in the staﬀ report that these improvements “save money”, the poten/al requirements are expensive investments that will lead to higher costs for goods, services and housing in the near and mid-term. These costs should not be given short shriP.

The City should take ac=on to LEAD in the mean=me
In addi/on to incen/ves, the City should take ac/on to address its own greenhouse gas emissions. Leading by example and inves/ng in its own eﬀorts, as detailed in the staﬀ report, would be a signaling message and provide addi/onal reduc/ons not contemplated under the city’s currently approved plan. Those ac/ons include:
• Wastewater energy eﬃciency improvements
• Water recycling expansion and energy eﬃciency improvements • Renewable energy expansion at city facili/es, including solar carports at city facili/es • Energy eﬃciency improvements at city facili/es
• Expansion of clean vehicle ﬂeets for city vehicles
Addi=onal comments
With these general thoughts in mind, we oﬀer the following comments on the theme areas included in the draP plan:
• Energy eﬃciency in non-residen=al and residen=al buildings - as stated above, any addi/onal requirements should be delayed un/l the requirements of the new state Nov. 12, 2024
Item #8 Page 624 of 637
building code can be reviewed. REACH codes cost money, which results in higher rents and, in many cases, a movement of investment outside the city. Statements that these improvements “save money” are overstated and incorrect. This is basically a new tax on jobs creators, small businesses and city residents. In the interim, the city should ﬁnd incen/ves to spur energy eﬃciency improvements in exis/ng buildings. • Energy performance requirements for both non-residen=al and residen=al buildings - this is electriﬁca/on by another name. Our coali/on would like to point out that a lawsuit brought against the City of Berkeley successfully blocked the manda/ng of building electriﬁca/on. Seing performance standards that can only be met through electriﬁca/on would essen/ally create the same mandate. Staﬀ has noted that there may be other ways to achieve the performance standards, but it’s unclear how the performance standards would be applied to diﬀerent types of buildings, and, as such, the total reduc/on sought could end up crea/ng de facto requirements that would be economically prohibi/ve, impac/ng your businesses and your homeowners. This should not be adopted. • Emissions benchmarking reports - state law already requires this repor/ng. Our coali/on feels this is duplica/ve and unnecessary. That said, other jurisdic/ons, like the City of San Diego, also have overlapping requirements for these reports. We would strongly recommend, like how the City of San Diego addressed this same concern, that the required reports mirror those already provided to the state. Energy Star Porfolio Manager is the tool used, and we’d recommend that tool be used here, if a duplica/ve requirement is adopted.
• Decarboniza=on of exis=ng buildings - it’s unclear what this means, but like the comments on energy performance requirements, if the net result of this are new requirements to ban natural gas, then there are legal concerns to consider. If there are other requirements being contemplated, these will likely signiﬁcantly increase costs. As noted previously, the City will more than meet its goals in the next ten years. The City, rather than crea/ng new legal risk, or raising the cost for City residents and employers, should look at incen/ves, not new mandates.
• Waste diversion - the diversion of organic waste, while laudable, creates the poten/al for unintended consequences. Any program should be phased in, and, most importantly, be considered against other City requirements that might prevent implementa/on. An example would be parking requirements. Most proper/es do not have the space to place addi/onal dumpsters for newly diverted waste, crea/ng a compliance issues if parking were to be taken up to place those receptacles.
• Transporta=on Demand Management - Transporta/on demand management is a cau/onary tale. In some cases, mandates under a TDM program that drive either opera/onal changes or impact employees from a cost or convenience standpoint could drive businesses out of Carlsbad, which harms your economic development eﬀorts, as well Nov. 12, 2024
Item #8 Page 625 of 637
as conﬂicts with the greatest means of reducing emissions, which is having jobs adjacent to homes in your community. Voluntary programs, coupled with ﬁnancial incen/ves to pay for ride sharing are something to be used and expanded. Addi/onal analysis should also be completed to determine the opportuni/es and impacts. Given COVID-era driven changes in work habits, a number of employers are allowing an even greater share of work from home opportuni/es, which may mean that these goals are already being readily met.

Focus should also be paid to improving the area’s transit services, including shukle services to and from rail sta/ons. Convenience drives behavior, so that could assist greatly in reducing auto trips. Lastly, the State of California has already mandated the phasing out of combus/on vehicle sales. There should be much less concern about vehicle emissions, given the /me horizons for these mandates.
• Transporta=on - the City should focus on ways it can improve its circula/on network and expand transit service rather than mandate expensive new requirements on jobs creators.

If electric vehicle requirements from the state, including the phasing out of combus/on vehicle sales in the near term, are not enough, then the focus should be to work with NCTD and AMTRAK to create beker transit service to be an eﬀec/ve and desirable alterna/ve.
• EV charging and photovoltaic mandates should be carefully considered - these are extremely expensive requirements that are not easily achieved, par/cularly in commercial seings, and not always eﬀec/ve when usage is factored in. Serving those addi/onal loads on a property-by-property basis can be challenging, and expensive. In most instances where they have been installed, chargers sit vacant and unused. In others, they are targets for theP and vandalism. The other considera/on is the ability of the u/lity to serve this increased load, and on a property by property basis, the ability of the equipment providing electrical service to also serve the on-site load. When it can’t, the cost to install new equipment to serve the expansion of EV charging will be signiﬁcant. As in other comments, these mandates add to the cost of doing business or the cost of housing, and our coali/on believes the cost-beneﬁt should be a factor in these decisions. • Parking Demand Management - Village and Barrio parking management studies are being conducted, so no ac/on should be taken un/l those are done. Again, similar to the TDM discussion, cau/on should be used in crea/ng rules or requirements that make it diﬃcult to develop or maintain a business within your community. Many of the ideas discussed under TDM in this leker could be considered for this as well. We do support the reduc/on of parking standards in areas where alterna/ve means of transporta/on are readily accessible.
• Construc=on vehicles - mandates of this nature, where the equipment is either not available or extremely costly will only create compliance issues and place housing and jobs space creators in an untenable posi/on. Even if the equipment were available, it is expensive and results in higher costs of construc/on, which means more costly housing Nov. 12, 2024
Item #8 Page 626 of 637
and commercial space, neither of which should be acceptable, par/cularly given the current economic environment. The City should instead focus on leading by example and focusing its eﬀorts on its own ﬂeets and ac/vi/es.

In closing, we’d like to thank staﬀ for hearing our call last year for beker outreach. We have had the opportunity to meet with your team and discuss the draP plan. We are hopeful that these important concerns are taken seriously, and that the partnership the City prides itself on with the business and property-owning community is honored.

Thank you for your /me and considera/on of these thoughts. Our organiza/ons are willing to con/nue to discuss these issues as you proceed with more speciﬁc update proposals.

Sincerely,
Craig Benedeko, NAIOP San Diego & BOMA San Diego
Jus/ne Murray, San Diego Regional Chamber of Commerce
Melanie Woods, California Apartment Associa/on
Molly Kirkland, Southern California Rental Housing Associa/on Chris Duggan, California Restaurant Associa/on
Lori Holt Pfeiler, Building Industry Associa/on of San Diego Fred Tayco, San Diego County Lodging Associa/on
Dus/n Steiner, Associated General Contractors San Diego CC: Paz Gomez, Deputy City Manager
James Wood, Director, Environmental Sustainability
Carlsbad City Councilmembers
Nov. 12, 2024
Item #8 Page 627 of 637
From: Bob Wilcox
To: Katie Hentrich; Planning
Subject: Comment on draft CAP for Planning Commission
Date: Tuesday, September 10, 2024 10:30:35 AM
Members of the Carlsbad Planning Commission,
I encourage you to endorse the draft Climate Action Plan prepared by city staff,

without
watering down, delaying or eliminating initiatives. As a Carlsbad homeowner and father of two (1 and 3 years old), I am encouraged that Carlsbad has such a thorough plan to reduce a large portion of its carbon emissions through many different

avenues in the future.

One area that I think could use more attention is further upzoning and approving more housing in our dense commercial districts like the Village, as well as along transit corridors and near the Poinsettia train station. This is something that might be best addressed through the Housing Element of the General Plan, but these zoning changes would likely have a larger impact on our region's long-term transportation emissions than many of the other proposed (and worthwhile!) initiatives. I understand that there are political challenges with such changes, but the potential benefits are too great to ignore.

I want to express my thanks to the staff for all of their hard work on this comprehensive plan.

Regards,
Bob Wilcox
CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content is safe.

Nov. 12, 2024
Item #8 Page 628 of 637

TRANSMITTED ELECTRONICALLY
September 3, 2024
Carlsbad Planning Commission
1635 Faraday Avenue
Carlsbad, CA 92008
RE: Climate Action Plan Update
Dear Planning Commissioners:

I am writing to share Biocom California’s input on the draft Climate Action Plan (CAP) being considered by Planning Commission on September 4.

Biocom California is the state’s life science association, headquartered in San Diego. We represent over 1,800 members in California and beyond with 614 of them having a presence in the San Diego region.

Our members range from one person research operations to large-scale manufacturing – all working to better the human condition by developing treatments and cures.

The life science industry shares the city’s goal of reducing greenhouse gas emissions. Our facilities are generally newer and comply with a wide variety of regulatory requirements related to sustainability. In some cases, these facilities are not able to operate with 100% electric service due to specific needs. It is important to keep in mind the requirements of research laboratories as reach codes are being proposed.

One consideration is the use of gas-powered backup generators needed to ensure that research continues in the case of a power outage. Research happens around the clock, and backup battery technology does not exist to operate laboratories during an outage. Additionally, some technologies such as boilers have very precise temperature needs that can only be achieved using gas power. Finally, we echo the concerns of others in the building community that we have not received confirmation from electric providers that the grid can handle all facilities operating 100% electric.

Given these limitations, we urge the city to consider alternative compliance in its enactment of any potential reach codes. We have participated in several meeting with city staff regarding the CAP and remain available to give input on behalf of the life science community as the city develops implementing regulations related to the plan.

Thank you,
Melanie Cohn
Senior Director, Regional Policy & Government Affairs
Biocom California
Nov. 12, 2024
Item #8 Page 629 of 637
t Biocom California
Biocom California
BOMA San Diego
Building Industry Associa:on of San Diego
San Diego Regional Chamber of Commerce
California Apartment Associa:on
San Diego County Lodging Associa:on
San Diego North Economic Development Council
Southern California Rental Housing Associa:on
California Restaurant Associa:on
Associated General Contractors San Diego
NAIOP San Diego

TRANSMITTED ELECTRONICALLY
October 1, 2024
Planning Commission
City of Carlsbad
1635 Faraday Avenue
Carlsbad, CA 92008
RE: DraG Climate AcHon Plan Update
Dear Members of the Planning Commission:

On behalf of the undersigned coaliHon of jobs and housing providers, we are wriHng today in support of Items 1 and 2 on the list of staﬀ recommendaHons and in opposiHon to Items 3, 4 and 5. Under Item 2, we would request some minor modiﬁcaHons, to remove the requirement for electriﬁcaHon of construcHon equipment, as well as the expansion of the “transportaHon demand management” or TDM requirements.

By adopHng RecommendaHons 1 and 2 with these modiﬁcaHons, you are sHll not only meeHng your near-term goals of aZainment by 2035, you will also do so for the 2045 Hmeframe. RecommendaHons 1 and 2 allow Carlsbad to be a leader on reducing greenhouse gas emissions (GHG), while also balancing the cost and consequences to your residents and businesses. It also helps protect against legal risk to the City in moving forward with a de facto electriﬁcaHon mandate through a Reach Code.

In terms of the concerns regarding the other opHons, the coaliHon is opposed to the adopHon of a separate Reach Code. The state code, including the recently ﬁnalized triennial building code, is one of the most stringent in the world. And the new measures under the code would conHnue to ratchet up Nov. 12, 2024
Item #8 Page 630 of 637
Octob
er 2, 2024
To: Carlsbad Planning Commission
Dear Planning Commissioners:

On behalf of the Sierra Club’s Coaster group, I’d like to share some insights with the Climate Action Plan (CAP) update coming before you. The Coasters group includes the cities of Del Mar, Solana Beach, Encinitas, Carlsbad and Oceanside. Our local Carlsbad Sierra Club team has had a chance to review and discuss the measures presented within this current update.

Th is
update is a vast improvement over the original 2015 CAP . It is much more readable and comprehensive than the original. It will guide the city as it moves to meeting both its 2035 and 2045 greenhouse gas (GHG) emission reduction targets.

Energy measures:

E-2 –
The t
arget date for CEA to supply all its customers with 100% renewable energy is 2035. As with the amendment to the ﬁrst CAP , clean energy through CEA is one of the best ways of meeting our emission targets so consider a target for the city to have its default program for our residents be Green Impact (=100% clean energy) by 2030.

Nov. 12, 2024
Item #8 Page 631 of 637
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COUNTY coAS1P..'-
Explore, Enjoy &
Protect the Planet
E-3.2 (non-residential) and E-4.2 (residential) – For new construction, now that the Berkeley case has been ﬁnalized, proceed with reach codes that apply high-performance, electric-preferred buildings. Encinitas is ﬁnalizing their ordinance and San Luis Obispo passed theirs last fall. Such ordinances look to optimize energy eﬃciency while still allowing for gas. Because the life span for new buildings is decades Carlsbad should update its building codes now to get the most emissions savings by encouraging electriﬁcation.

Transportation measures:

T-7 – It’s good to see the TDM program being expanded to include city facilities/employees. The city should be a role model for businesses in our region and this is a good way to do that.

T-10 – Proper parking management can be a valuable tool to incentivize employees not to drive. It should be included within the TDMs for both businesses and the city (T-2/T-7). As worded in the CAP update, this is a Nov. 12, 2024
Item #8 Page 632 of 637
rather vague measure and primarily addresses actions through existing plans like the Village and Barrio Parking Plan rather than a city-wide business approach to reduce employee trips. Free parking is not free and the city needs to look to the future in evaluating its parking strategies.

Oﬀ-Road Equipment Measure:

Carbon Sequestration Measure:

CS-1 – Community Forest Management which includes a replacement of 2:1 for city trees should be expanded to include HOAs which may have CC&Rs covering tree replacements. Our informal survey of some HOAs in Oceanside found that tree replacement policies are not be followed. Hopefully, Measure CS-1.c, the 5-year urban canopy study will include this.

Global action isn’t happening fast enough. Every level of government should be doing their utmost to address the problem. Carlsbad has the opportunity to lead by example.

Thank you for your consideration.

Paige DeCino
Paige DeCino
Sierra Club Coasters Executive Committee member
Nov. 12, 2024
Item #8 Page 633 of 637
these GHG reducing measures in new construcHon and tenant improvements. The City’s own GHG reducHons would signiﬁcantly beneﬁt from these changes once they go into eﬀect. Going beyond with a Reach Code only puts Carlsbad at a compeHHve disadvantage with your neighbors as a Reach Code comes at a high cost, which would dramaHcally increase the cost of both residenHal housing and commercial tenancy. It would also create legal risk, as was seen in the City of Berkeley.

The coaliHon is also opposed to the new requirements related to the electriﬁcaHon of construcHon equipment. In most cases, this kind of equipment is not available and, where it is, is extremely expensive. Mass producHon at useful grade for construcHon sites is not expected for some Hme, if at all, given the power needs for this kind of equipment. We would recommend delaying this item unHl a subsequent update to beZer determine the state of the market.

Regarding TDM, it is a diﬃcult measure to implement as it’s expensive, unpopular with employees and impossible to manage. As was noted at the previous Planning Commission hearing, Carlsbad businesses and property owners are already avoiding triggering these requirements under the current CAP , given their high cost. Further, depending on the TDM requirements, congesHon pricing and puniHve parking fees would disproporHonately impact lower income workers, and for the lodging industry, dissuade visitors from coming to Carlsbad. In short, expanding TDM would likely achieve liZle in the way of GHG reducHons, and create a number of other impacts, including fewer tourists, less TOT, and for those who choose to avoid triggering the requirements, further reducing tenant improvement investments, which would age the city’s building stock.

Lastly, we conHnue to have concerns about the lack of ﬁnancial impact analysis for the proposed acHons.

While the City was willing to expend money to determine the impact to itself, it didn’t aﬀord the same acHon for impacts to the regulated community. We believe this kind of analysis should be done before approval, not aGer when implementaHon is being considered.

In closing, we thank the Planning Commission and City staﬀ for hearing the concerns of our coaliHon and providing a reasonable, yet aggressive opHon in the OpHon 1 recommendaHon. With our addiHonal modiﬁcaHons, we would respeceully request your support of RecommendaHon Items 1 and 2.

Sincerely,
Melanie Cohn, Biocom California
W. Erik Bruvold, San Diego North Economic Development Council Craig BenedeZo, NAIOP San Diego & BOMA San Diego
JusHne Murray, San Diego Regional Chamber of Commerce
Melanie Woods, California Apartment AssociaHon
Molly Kirkland, Southern California Rental Housing AssociaHon Chris Duggan, California Restaurant AssociaHon
Lori Holt Pfeiler, Building Industry AssociaHon of San Diego Fred Tayco, San Diego County Lodging AssociaHon
DusHn Steiner, Associated General Contractors San Diego CC: Paz Gomez, Deputy City Manager
James Wood, Director, Environmental Sustainability
Carlsbad City Councilmembers
Nov. 12, 2024
Item #8 Page 634 of 637
Exhibit 7

Planning Commission Staff Report
Dated Sept. 4, 2024
(on file in the Office of the City Clerk)

Nov. 12, 2024
Item #8 Page 635 of 637
Exhibit 8

Planning Commission Staff Report
Dated Oct. 2, 2024
(on file in the Office of the City Clerk)

Nov. 12, 2024
Item #8 Page 636 of 637
Exhibit 9

City Council Resolution No. 2024-014
(on file in the Office of the City Clerk)

Nov. 12, 2024
Item #8 Page 637 of 637
TO: CITY CLERK
DATE OF PUBLIC HEARING:

AFFIDAVIT OF MAILING

NOTICE OF PUBLIC HEARING
SUBJECT: __ ___._~..e...=..::1-,:.....oc..=~= - Q::.......::.:,,C-.~-=,."'""-'-"'---'8'-----'-""&z=-=-c,~ ___ _ LOCATION: ~200 Carlsbad Village Drive, Carlsbad, CA 92008 D Other: ------------------
DATE POSTED TO CITY WEBSITE _ /-t--/ #--/ ~'f~/{)D9~,.. __ V_ DATE NOTICES MAILED TO PROPERTY OWNERS: _________ _
NUMBER_ MAILED: -
I declare under penalty of perjury under the laws.of the State of California that I am employed by the City of Carlsbad and the foregoing is true and correct.

DEPARTMENT: ~TY CLERK'S OFFICE □ OTHER _______ _
Signature Date
SENT TO FOR PUBLICATION VIA E-MAIL TO: □ Union Tribune on ___ _ ~ Coast News on Joky/ :J..t/
PUBLICATION DATE: Union Tribune --------------
Coast News _ _.__} _._J ._./1 ........ /_..f1~a.2....,~t/_ · ____ _ I declare under penalty of perjury under the laws of the State of California that I am employed by the City of Carlsbad and the foregoing is true and correct.

DEPARTMENT: ~TY CLERK'S OFFICE □ OTHER---,-------
I 0/2-:2/~:2 y
Signature Date
Attachments: 1) Mailing Labels
2) Notice w/ attachments

NOTICE OF PUBLIC HEARING
NOTICE IS HEREBY GIVEN to you, because your interest may be affected, that the City Council of the City of Carlsbad will hold a public hearing at the Council Chamber, 1200 Carlsbad Village Drive, Carlsbad, California, at 5 p.m. on Tuesday, Nov. 12, 2024, to consider (1) certification of Addendum No. 1 to the Housing Element Implementation and Public Safety Element Supplemental Environmental Impact Report for the Climate Action Plan Update; and (2) adopting one of the following City Council resolutions for the Climate Action Plan Update:
1) Adopt a resolution adopting the publicly posted Draft Climate Plan Update, excluding Measures E-3.2, E-3.3 and E-4.2 (Nonresidential Building Energy - Updated Reach Code, Nonresidential Building Energy- Solar Carports, and Residential Building Energy- Updated Reach Code, respective ly), to meet the required 2045 reduction target; OR 2) Adopt a resolution adopting the publicly posted Draft Climate Action Plan Update, excluding Measure E-3.2 (Nonresidential Building Energy- Updated Reach Code), which would exceed the 2045 reduction target by approximately 200 MT CO2e; OR 3) Adopt a resolution adopting the publicly posted Draft Climate Action Plan Update, excluding Measure E-4.2 (Residential Building Energy-Updated Reach Code), which would exceed the 2045 reduction target by approximately 4,000 MT CO2e; OR 4) Adopt a resolution adopting the publicly posted Draft Climate Action Plan Update, which would exceed the 2045 reduction target by approximately 6,000 MT CO2e.

More information on the project overall is available at:
~partments/environmentat-sustainability/climate-act ion-p lan.

On Sept. 22, 2015, the City Council certified the Final Program Environmental Impact Report for the General Plan Update and Climate Action Plan, State Clearinghouse Number 2011011004 (EIR 12-02) with Resolution No. 2015-242. EIR 13-02 evaluated the potential environmental effects of implementing the greenhouse gas reduction measures in the 2015 Climate Action Plan. On Jan. 30, 2024, the City Council certified the Supplemental Environmental Impact Report for the 2023 Housing Element Implementation and Public Safety Element Update, State Clearinghouse Number 2022090339 (EIR 2022-0007) with Resolution No. 2024-0014. EIR 2022-0007 evaluated the potential environmental effects of implementing the greenhouse gas reduction measures contained in the Climate Action Plan Update. The city has determined that EIR 13-02 and EIR 2022-0007 are of continuing informational value and that the potential environmental impacts of the Climate Action Plan Update are within the scope of these previously certified documents. The city has determined that none of the conditions requiring subsequent or supplemental environmental review under CEQA Guidelines section 15162 exist for the Climate Action Plan Update. An addendum was prepared and indicated no significant environmental impacts would occur as a result of implementing the Climate Action Plan Update.

On Oct. 2, 2024, the City of Carlsbad Planning Commission (1) voted 7/0 to recommend certification of Addendum No. 1 to the Housing Element Implementation and Public Safety Element Supplemental Environmental Impact Report for the Climate Action Plan Update; and (2) voted 4/3 (Kamenjarin, Lafferty, Danna - No) to recommend adopting the publicly posted Draft Climate Plan Update, excluding Measures E-3.2, E-3.3 and E-4.2 (Nonresidential Building Energy- Updated Reach Code, Nonresidential Building Energy - Solar Carports, and Residential Building Energy - Updated Reach Code, respectively), to meet the required 2045 reduction target.

Those persons wishing to speak on this proposal are cordially invited to attend the public hearing.

Copies of the staff report will be available on and after Nov. 8, 2024. If you have any questions, please contact Katie Hentrich in the Climate Action Planning Division at (442) 339-2623 or katie.hentr [email protected]_v. The meeting can be viewed online at www.carlsbadca.gQYlcit_y_::
hall/meetings-agendas or on the city's cable channel. In addition, written comments may be submitted to the City Council at or prior to the hearing via U.S. Mail to the attention of Office of the City Clerk, 1200 Carlsbad Village Drive, Carlsbad, CA 92008, or via email to [email protected] .

If you challenge these actions in court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice or in written correspondence delivered to the City of Carlsbad, Attn: City Clerk's Office, 1200 Carlsbad Village Drive, Carlsbad, CA 92008, at or prior to the public hearing.

CASE NAME: CLIMATE ACTION PLAN UPDATE
PUBLISH: FRIDAY, NOV. 1, 2024

CITY OF CARLSBAD CITY COUNCIL
cm OF CARLSBAD

NOTICE OF PIJRI IC MEKONG
NOTICE. JS HE.RF.BY GIVEN to you, beca.wc your inlcre.<!il may be affected,. that the City Council of the City of Carlsbad wilJ hold a public hearing at the Council Chamber, 1200 Carls bad Village Drive, Carlsbad, Ca1ifomia. at 5 p.m. on Tuesday, Nov. 12, 2024, to consider (1) certification of Addendum No. 1 to the Hou&ing F.Jcment lmp1emcnta.tion and Public Safely El ement Supple.mental Environmental Impact Report for t.he Climate Action Pla.n Update; and (2) ado1>Ling one of tl1e following City Council resolutions for the Climate Action Plan Updai.e:
l ) Adopt a resolution adopting lhe publicly posted Draft Climate Plan Update, exclud ing Measures E-3.2, E-3.3 and E-4.2 (Nonresidential Building Energy - Updated Reach Code, Nonresidential Uu.ilding Energy - Solar Carports, and Residential Building Energy - Updated Reach Code, respectively), to meet the required 201-5 reduction target; OR
2) Adopt a resolution adopting the publicly posted Draft Climate Action Plan Update, excluding Measure E-3.2 (NonresidenliaJ Building .Energy- Updated Reach Code), which would exceed I.he 2045 reduction target by approximately 200 MT C02e; OR
3) Adopt a resolution adopting the publicly posted Draft Climate Action Plan Update, excluding Measure E-4.2 (Residential Building Energy - Updated Ruch Code), which would exceed the 204-5 reduction target by approximate ly 4.000 MT C02e; OR
4) Adopt a resolution adopting the publicly posted Draft Climate Act.ion Plan Update, which would e.xcttd the 2045 reduction target by approximately 6,000 MT C02e.

More information on the project overall is available at:
wwwcaclsbadca gnvldepad ment·s/eovicoomen1al-sns1ainebili9'/clim atc-act ioo-p]ao On Se.pl 22, 2ou, the City Council certified the Final rrogram Environmental Impact Rt: porl for the General Plan Update and Climale Action Plat1, Stale Clearinghouse Number 2011011001, (EJR 12-02) wil.h Rctolulion No. 2015-242. ElR 13-02 evaluated the potential environmental effcct.8 of implementing the greenhouse gas reduction measuru in tJ,e 2015 Climate Action Plan. On Jan. 30, 202♦, the City Council certified the Supplemental Emiro n mental Impact Repon for the 2023 Housing Element Implementatio n and Public Safety El ement Update. State Clearinghouse Number 20220903.'.39 (El R 2022 -0007) with Resolution No. 'l O'l-4,-001 ♦. EfR 20l2-0007 c,.-a.lll,\ted the potential environmental effect! of implement ing the greenhouse gas ttducLion measures oontained in the Climate Action Plan Update. The city has detenn ined that El R l3-02 and El R 2022-0007 IU'e of oontimdng informational \..Jue and that the potentiaJ environmental impacts or the Climate Aclion Plan Update are within Lhe scope of lhesc prcYiously certified documents. The city has determin ed that none of U,e oonditiom requiring sub5equent or supplemental environmental review under CE.QA Guide linea section 15162 exist for the Climate Action Plan U1xla1.e. An addendu m was prepared and indicated no significant environmental impacU would occur as a result of implementing the Climat.e Action Plan Updale.

On Oct. 2, 2024, the Cit)' of Carlsbad Planning Commission (1) voted 7/0 to recommend certification of -~de. ndwn No. l to the Bowi ng Element Implementation and Public Safety Element Supplementa l EnvironmentaJ Impact Report for the Climate Action Plan Update; and (l) voted 4/3 (Kamcnjarin, Latrcrly, Danna - No) to recommend adopting the publicly posted Draft Climate Plan Update, excludjng Measures E-3.2, E-3.3 and £-4.l (NonresidentiaJ Building Energy - Updated Reach Code, Nonresident.ial Building Energy - Solar Carports, and Residential lluilding Energy - Updated Rea.ch Code, respectively), to meet t.he required 2045 reduction target.

Those persons wishing to speak on this proposal are oordiaJly invited to attend the public hearing. Copies or the staff tl!J>Orl will be available on and a.ft.er Nov. 8, 2024. If you have uiy queslions, please contact Katie Hentrich in the Climate Action Planning Division at (442)339 · 2623 or katie hcntricb@cadsbadca gov The meeting can be viewed on line a, wwwcoclsbedca gnv/cit:)'•ball/mce1ings-egrodas or on the city's cable channel. ln addition, ·written comments may be submitted to the Cily Council at or prior to the hearing via U.S. Ma.ii to the at.tentlon of Office of I.he City Clerk, 1200 Carlsbad Village Drive. Carlsbad, CA 91008, or via email to clerk@carlsbadca gPY
If you challenge these actio ns in OOW't, you may be limlt:ed to raising only lhost. i~ues you or someone else raised at the public hearing described in this notice or in wriuen c.orrespondence deUvercd ID the City of Carlsbad. Attn: City Clerk's Office. 1200 Ca.rlsba.d Village Drh•c. C.arls bad, CA 92008 , 1.t or prior ID the publk: hearing.

CASE NAME, CLIMATE ACTION PLAN UPOA'.1'£
PUBLISH, FRJOAY, NOV, 1, 2024
CllY OP CARLSBAD Cl1Y COt!NClL.

I l/ 01/2024 CN 29691
3 Col X 9,25"

27.75"x $15
$416,25
Tammy Cloud-McMinn
From:

Sent:

To:

Subject:

City Leaders,
virginia cemashko <[email protected]>
Saturday, November 9, 2024 11 :20 AM
City Clerk
Climate Action Committee: Leaf Blowers
I'm writing in support of a city regulation of gasoline powered leaf blowers.

All Receive - Agenda Item # ~
For the Information of the:
.9~~qUNCIL
Date /..lb;;lf2/:.A YCC -
CM ~ CM Y1JCM (3) ~
At my home I am surrounded by neighbors who maintain their gardens with hired gardeners. These firms/small businesses all use noisy, fume emitting gasoline leaf blowers. My peace and tranquility are interrupted 3-4 times a week by these machines. I am semi- retired and continue to work from home.

I respectfully ask you to consider a city reg to transition to quieter, less polluting electric battery powered leaf blowers in a timely fashion. I would not wish to wait until 2035! Thank you for your attention.

CAUTION : Do not open attachments or click on links unless ou recognize the sender and know the content i safe.
1 Tammy Cloud-McMinn
From:

Sent:

To:

Subject:

Diana A <[email protected]>
Sunday, November 10, 2024 9:07 PM
City Clerk; Keith Blackburn; Carolyn Luna; Melanie Burkholder; Teresa Acosta; Priya Bhat Patel
Agenda Item # 8 Support Updated Climate Action Plan.

Dear Mayor Blackburn & City Councilmembers,
By supporting a CAP, our City will actively contribute to a world where children and future generations can enjoy a stable climate, healthy environments, and economic opportunities in a sustainable society.

Please approve the Climate Action Plan (CAP) as presented by staff member Katie Henrich.

In addition please include these items that were previously presented to the Planning Commission and included in the original CAP.

Measure E-3.2: Nonresidential Building Energy - Updated city building or "reach code" to include updated energy performance-based requirements for new nonresidential buildings.

Measure E-3.3: Nonresidential Building Energy - Construct "solar carports" (also known as installing solar panels over outdoor parking spaces) at eligible city-owned parking lots.

Measure E-4:2 Residential Building Energy - Updated city's building code, or "reach code," to include updated energy performance-based requirements for new residential buildings.

These measures demonstrate the city's commitment to sustainable development and proactive climate action, aligning with the CAP goals to reduce pollution, promote renewable energy, and protect public health and the environment.
- Reduction of Greenhouse Gas Emissions: By adopting updated energy performance requirements for both nonresidential and residential buildings, the city would significantly reduce energy consumption, thereby lowering greenhouse gas emissions from heating, cooling, and lighting. 1 - Increased Renewable Energy Adoption: Installing solar carports in city owned parking lots helps increase the city's renewable energy capacity, contributing to a more sustainable and diversified energy grid, reducing dependency on fossil fuels.
- Long-Term Energy Savings: Energy-efficient buildings often result in lower utility costs, encouraging long-term energy conservation and minimizing the overall energy demand, which aligns with sustainable urban development goals.
- Enhanced Resilience and Climate Adaptation: Energy-efficient and solar powered infrastructure creates a more resilient community by providing clean energy sources and reducing strain on the electric grid, especially during extreme weather events linked to climate change.
- Leadership and Community Influence: By updating its building codes, the city sets an example for businesses, residents, and other cities to follow, promoting a culture of environmental responsibility and climate action. - Local Job Creation in Green Industries: Increased demand for solar installations and energy-efficient construction practices supports local green job growth, contributing positively to the economy while reducing environmental impact.
- Improved Air Quality: Reduced reliance on non-renewable energy decreases air pollutants associated with fossil fuel energy production, which can improve local air quality and public health.

Thank you for taking my input into consideration.

Diana Aguirre, CA Naturalist Certified, Citizen's Academy Graduate 2023, Resident District 3.

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2 Tammy Cloud-McMinn
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Hello,
Susan Kobara <[email protected]>
Monday, November 11, 2024 8:06 AM
City Clerk
Agenda Item# 8 Support Updated Climate Action Plan
I am a resident of Carlsbad and am asking that you approve the Climate Action Plan. This plan is critical to me, my family, my neighbors and the entire Carlsbad community. We can't afford not to address climate solutions in Carlsbad as the cost of not taking action can be significant.

This Climate Action Plan gives Carlsbad resilience, provides an equitable strategy to address many climate-related issues and protects our water, energy, transportation, agriculture and health. While some think climate solutions are at odds with business and jobs, good climate policy can safeguard our businesses and open up opportunities for clean tech jobs.

I feel so fortunate to live in beautiful Carlsbad. It is important to me that my children and all future generations enjoy the beauty and the community that we have here.

Thank you for all you do. With best regards,
Susan Kobara
2938 Via lpanema
Carlsbad, CA 92009
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1 Tammy Cloud-McMinn
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Ann Feeney <[email protected]>
Monday, November 11, 2024 3:09 PM
City Clerk; Council Internet Email
comments on CAP update from SDBEC
SDBEC Letter Carlsbad Draft CAP Nov 2024.pdf
Here are comments on your CAP update from SDBEC.

Ann Feeney
co-chair, SanDiego Building Electrification Coalition
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1 SAN DIEGO BUILDING

ELECTRIFICATION COALITION
11 November 2024
RE: Comments on draft Carlsbad Climate Action Plan
Dear Mayor Blackburn and City Councilmembers,
The San Diego Building Electrification Coalition (SDBEC) is an alliance of over 45 community, business, faith, justice , and environmental organizations coming together to accelerate electrification in residential and commercial buildings.

SDBEC advocates for electric new building construction by supporting the modification of building codes in cities throughout the San Diego region, and supports an equitable pathway to phase out methane gas in existing buildings. We oppose the use and expansion of methane gas hookups due to the adverse impacts of methane gas combustion on Greenhouse Gas (GHG) emissions , indoor health , and public safety.

We are pleased that Carlsbad's Draft Climate Action Plan Update recognizes the urgency to significantly reduce and avoid GHG emissions to achieve emissions targets by 2035 and 2045.

However, we urge Council to keep all of the building electrification measures in the CAP update that you adopt.

In particular, we urge you to retain the following, as written:

E-3.2 Nonresidential Building Energy - Updated Reach Code E-3.3 Nonresidential Building Energy - Solar Carports
E-4.2 Residential Building Energy - Updated Reach Code
E-3.2 and E-4.2 apply to new construction, where it is lower cost to build new homes that are all-electric rather than mixed fuel. Importantly, building electrification is one of the most effective ways to cut climate pollution by reducing GHG emissions. Of equal importance, studies show that methane gas use in homes leads to indoor air pollution and is associated with increased risk of various diseases including asthma and premature fetal mortality. These proposed reach codes provide flexibility in the manner in which developers can achieve these energy efficiency standards.

E-3.3 requires solar carports at eligible city-owned parking lots, and first will do feasibility studies on existing city-owned parking lots, and then will apply for outside grant funding for the carports.

Carports provide ideal locations for generating clean renewable energy.

We urge Carlsbad City Council to adopt a strong Climate Action Plan that will achieve the significant results that are needed to reduce carbon pollution. Building electrification can make a significant contribution and provide results right now. We urge you to adopt the CAP update

SAN DIEGO BUILDING
ELECTRIFICATION COALITION ieJ
that includes all three of these measures, Option 5, which would exceed the 2045 reduction target by -6,000 mt CO2E.

Sincerely,
Kelly Lyndon
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Tammy Cloud-McMinn
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City clerk,
Paige DeCino <[email protected]>
Monday, November 11, 2024 8:42 PM
City Clerk
Scott Chadwick; Katie Hentrich

11.12.24 council meeting agenda item #8
Council comments from team 11.12.24.docx
Please submit the attached letter as part of the public record for the 11 /12/24 council meeting.

Sincerely,
Paige DeCino
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1 11/11/24
Mayor, council members,
At the council meeting on 11/12/24 you'll be reviewing the updated Climate Action Plan (CAP). This has been in the works for over a year and the final version will set Carlsbad on the right, sustainable path toward addressing climate change. Last month the Planning Commission by a 4-3 vote recommended adopting the CAP with the exception of removing the reach codes in E-3.2 and E-4.2 as well as E-3.3 solar carports .

I'd like to address some of the concerns related to these 3 measures based upon the letter submitted to the Planning Commission (PC) by a coalition of business interests. 1) On page 3 of their 8/16/24 letter to the PC they wrote: "The City should take action to LEAD in the meantime--Renewable energy expansion at city facilities, including solar carports at city facilities." The reason the PC voted to remove solar canopies wasn't due to any opposition from stakeholders in the community but the fact that that measure (E-3.3) happened to get lumped in with the 2 reach codes. By a slim majority the PC wanted to eliminate the reach codes and the solar carports were dragged along.

Please remove that measure from consideration for removal. 2) Within the same letter was the comment "Reach codes cost money." However, no clear examples have been given to indicate this is true. Our team and staff have repeatedly told public forums (PC and council meetings) that in order for any reach code to be approved by the CA Energy Commission it must be cost effective . There are ways to write up reach code ordinances fairly quickly. First, the state has an easy-to use tool, the Cost Effectiveness Explorer. This tool allows for mixed-fuel use in buildings. Secondly, other cities have adopted high performance reach code ordinances, specifically, Encinitas and San Luis Obispo.

These, too, allow for mixed-fuel use and can be used as a starting point to create an ordinance for Carlsbad. 3) Anothe r point their letter and public comments to the PC brought up, was that the updated CAP didn't do an analysis on the cost impact from reach codes on the business community. In response to that I would point out that Council never directed staff to do any such study and, furthermore, for each reach code the time to analyze cost-effectiveness is once the ordinance details have been determined and written up not before the specifics have been laid out.
4) The reach codes under consideration have been part of Carlsbad's CAP since 2019. These are not newly minted measures. What the businesses are asking for is a big step backwards. 5) Their concerns for electrifying commercial buildings are valid. Not all businesses are created equal and some, such as laboratories, may need natural gas. However, exemptions can (and have been) written into ordinances to allow for special use. Also, as mentioned above, the currently adopted reach codes in other cities allow for mixed-fuel use.
6) Two local developments - Laguna Row and Marja Acres - are all electric . From discussions with the architect (LR, Brett Fa rrow) and developer (MA, KB Home) they saved, respectively, $100,000-200,000 and over $1,000,000 by not installing natural gas lines to their buildings.

Carlsbad residents and businesses, contribute to the climate crisis every day by using gas in our buildings. With the CAP Update, we have the opportunity to imagine a different future for our children, and the tools to guide us.

Choosing the CAP update with all measures, including building electrification reach codes and municipal solar carports, is a necessary, strong step toward that better future.

Sincerely,
Paige DeCino on behalf of Carlsbad Sierra Club team
Tammy Cloud-McMinn
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[email protected]
Tuesday, November 12, 2024 6:46 AM
City Clerk
Agenda item 8 - Climate Action Plan (CAP)
Americans spoke last week - rejecting identity politics and false media narratives and unifying around common sense issues like safe communities, crushing weight of inflation , family values and love of country.

One false narrative pushed by media, climate alarmists and certain Carlsbad staff is a climate emergency based on greenhouse gas emissions. If only the truth were allowed to be published it would shine a light on green agenda lies we have been fed.

The truth is, there is 'NO Climate Crisis' Says Coalition of 1,600 Actua l Scientists! There is however a crisis of nameless, faceless, unelected bureaucrats on commissions in California acting in bad faith.

Those 1600 scientists from the CO2 Coalition shared the truth and good news referenced above in a May 2024 letter to the California Air Resources Board. The letter further stated:
"Modest warming of California is beneficial and not a cause for concern: Globally , more people have died from the cold than from the heat since 2000.

Increase in agricultural production : The combination of lengthened growing seasons (from warming) and increased CO2 concentrations has contributed to this increase .

CO2 is essential : Plants need CO2, sunlight, water, and nutrients from the soil to produce food and oxygen , both of which are essential for human and animal lives.

CO2 is beneficial : Exposing plants to higher concentrations of CO2 increases their growth , food production , and drought -resistance; and greens the Earth.

California is in no danger of unusual drought: The annual precipitation in California has fluctuated greatly over the last 150 years, with only a slight decrease.

Ski resorts are experiencing more snow: Most (21 of 22) ski resorts in California had increasing snowfall from 2012 to 2023.

California is in no danger of drowning: North Spit, CA, has the highest rate of sea level rise of 0.005 meter/year, or 1.64 feet in l 00 years, which is easily mitigated.

Less natural disasters over the years: Significantly reduced number of wildfires and acres burned were reported in the United States and globally; California has infrequent tornadoes, no landfalling hurricane from 1851 to 2023, and no tropical 1 depression from 1950 to 2023; and tropical storms are rare in California , with the last two reported in 2023 and 1997.

Air quality in California keeps getting better: The concentrations of major pollutants have decreased over the years." Read the full article here.

Another consequence of unelected bureaucrats on CA commissions running amok is the fleecing of the taxpayer , by way of massive fines on businesses, which ultimately pass their cost on to the consumer . In an article titled California 's Corrupt Air Board and The Great California Shakedown , we find that "This is how businesses in California are treated by the government - they are shaken down for million$ and treated as if they are criminal enterprises . They are litigated and indic ted behind the closed doors of the air boards, and then in the court of public opinion with spiteful news articles. The CARB has issued 82 such penalties this year ... and 2024 is not over yet."
This again involves the California Air Resources Board, which by the way just voted for a .65 cent per gallon increase in gas prices
I'm not a scientist, but a friend of mine who is had this to say about the Climate Action Plan:
"ALL of the climate actions rest upon the alleged results of Global Circulation MODELS that continually FAIL to predict even short-term changes in climate let alone predictions over longer horizons. The institutions that established these models are the same ones that wrote the epidemiological models [wrongly] predicting the overload of hospitals at the start of the covid-19 Outbreak: The University of London , and the University of Washington. CO2 is a red herring. During covid the mainstream media and pharma paid luminaries would tout "correlation is not causation" yet for the climate debacle, you NEVER hear this argument .

Show me the so called consensus of scientists that are NOT captured by federal money that say CO2 is a cause for runaway global temperature. There are NONE. Just weeks ago 8 astro and geo physicists from around the globe teamed together and published the results of an analysis in the Journal of Astrophysics . The analysis combined data, a first of its kind that stitched together data from all the satellites with solar lrradiance sensors to examine the variance in the solar cycles . The results raise REASONABLE DOUBT that policy makers should heed before further committing or investing in projects to 'combat climate change'. The results confound the assertion of CO2 as a CAUSE. An inconvenient truth to INVESTORS in the New Green Deal. "
2 The CAP justifies policies stating that it meets the state's requirements. If the state's requirements are not based on true science, but instead based on lies and greed, then basing a Plan on those requirements is deeply wrong. This is common sense.

Simply put, if the state's requirements are lies, then creating a Plan based on those requirements is also a lie - and we should reject that Plan.

Reject the Climate Action Plan.

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Mike Borrello <[email protected]>
Tuesday, November 12, 2024 7:28 AM
City Clerk
[email protected]
Agenda item 8 - Climate Action Plan (CAP)
Please file this complaint and notification in community communications regarding tonight's meeting.

Cease and desist! From ANY 'climate action plan' that involves my hard earned tax money until our mayor and council can properly inform themselves their decisions are based on legitimate foundation. I DO NOT CONSENT.

HERE is reasonable doubt that confounds the man made greenhouse gas narrative as a cause:
https://iopscience.iop.org/article/10.3847 /1538-4357 /ad7794 And here's the lead author explaining the implications of findings from an unprecedented study:
https://youtu.be/RhP8cL87v3E?si=q4aPyvGsre6HEl-7
If there is doubt, freeze spending until there is DEBATE and resolution. STOP blindly following state and federal narratives.

Consider this email Fair Notice to the Mayor, council members, the city manager, and the city attorney.

Best regards,
Mike Borrello
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1 Tammy Cloud-McMinn
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Council Internet Email
Tuesday, November 12, 2024 8:25 AM
City Clerk
FW: Climate Action Plan Update
From: Esteban Danna <[email protected]>
Sent: Monday, November 11, 2024 9:18 PM
To: Council Internet Email <[email protected]>
Subject: Climate Action Plan Update
Dear Mayor and Members of the City Council,
I am writing in support of option four (exceeding the 2045 reduction target by approximately 6,000 MT CO2e) of the Climate Action Plan Update. The Climate Action Plan Update can also introduce additional measures to improve its effectiveness and help the City of Carlsbad lead on this issue. When this item was heard and discussed by the Planning Commission, I recommended that the City Council consider the following additional measures for the Climate Action Plan Update:

Water and Wastewater
• Set a maximum percentage of the site area permitted to have high water use landscaping (grass/lawn).

Energy
• Reach codes should be applicable to building additions and intensification of use, not simple tenant improvements.

Transportation
• Coordinate with CUSD and CEF to analyze the implementation of school buses to calm traffic, reduce greenhouse gas emissions, and give children another transportation option other than e bikes.
• Coordinate high school bus routes with NCTD and CUSD. • Reduce the number of car trips by city employees by establishing a work from home policy instead of leaving it to the discretion of the City Manager or department directors. • Pay to park in village to incentivize alternative modes of transportation, proceeds to go to climate change programs
1 Off-Road Equipment
• Expand to all gardening equipment, not just leaf blowers Thank you,
Esteban Danna
Planning Commissioner
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2 Tammy Cloud-McMinn
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Tuesday, November 12, 2024 8:27 AM
City Clerk
Subject: FW: In Support of Solar Canopies over City Owned Parking Lots in Carlsbad From: David Garmon <[email protected]>
Sent: Monday, November 11, 2024 9:41 PM
To: Council Internet Email <[email protected]>
Subject: In Support of Solar Canopies over City Owned Parking Lots in Carlsbad Dear Carlsbad Council,
It has come to my attention you will hear the proposed updated Climate Action Plan tomorrow, November 12th, and that building Solar Canopies over city owned parking lots is on the agenda.

The Tubb Canyon Desert Conservancy, based in Borrego Springs, greatly appreciates your efforts to build local, in-basin renewable electricity generation over parking lots, rooftops, and vacant land in Carlsbad. Your approach to renewable energy is the least expensive and most resilient alternative as we all strive for 100°/o renewable energy by 2045.

Your efforts to build a sustainable grid that is beneficial to rate payers and the environment will help reduce the perceived need to build remote, utility-scale solar farms in the fragile and biodiverse deserts of East Count, as well as the need to build a $2.3 billion dollar, 130 mile long, 500 kV transmission line that will scar the countryside between our two cities.

Please know that we in the East County support and applaud your efforts.
1 In gratitude,
David
J. David Garmon, M.D.

President, Tubb Canyon Desert Conservancy
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2 Tammy Cloud-McMinn
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Peggy < [email protected] >
Tuesday, November 12, 2024 10:32 AM
City Clerk
Agenda item 8 - Climate Action Plan (CAP)
All Receive - Agenda Item # §
For the Information of th e:
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Climate change activists spreading "misinformation" play a large part in why the Democrats lost the 2024 election . People are not buying their hysteria that is based on untruths.

Below are two excerpts from a column by William McGurn in today's WSJ:

The Democrats' Religion
https://wallstreetjournal-ny .newsmemory .com/?publink=026f278b3 134d4fc The Democrats' Religion "Take climate change. It comes with all the tropes of a religion: descriptions of Earth as an Eden despoiled by man , predictions of end times if we don't radically change our ways, and indulgences that al--low celeb rities to jet around the world so long as they drive electric cars to atone for their carbon sins. That also explains why green politics almost always elevates the radical over the sensible .. .. A few observers have made much of the Fox News voter analysis finding that Ms. Harris outperformed Mr. Trump with the "nones." These are voters who reported no religion, and they went for her, 69% to 29%."
But don't let the "none" part kid you : The Democratic Party today holds orthodo xies, pieties and heresies every bit as dogmatic and unyielding as traditional religion . And it's the reason so many Democrats are responding to the election results not by reexamining their own policy positions but by blaming the voters for the ir apostasy.

Please reject the Climate Action Plan.

Peggy Bartley
Carlsbad, CA
"God's childl' en al'e not/01· sale" Jim Caviezel
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1 Tammy Cloud-McMinn
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Barbara Diamond <[email protected]>
Tuesday, November 12, 2024 10:54 AM
City Clerk
Tiem # 8
Carlsbad City Council,
Tonight there will be testimony arguing how strong the CAP measures should be. For me, this is a non issue. All of us should make the maximum effort to reduce GreenHouse Gases.

Climate change is expensive and we will all be paying for it in various ways, e.g. increased taxes to cover the weather calamities, higher insurance premiums etc. Some businesses feel that they should be able to continue business as usual or their
businesses would suffer serious losses.

The history of this country shows that capitalism has always recovered; think of the great depression, the stagflation of the ?O's, the 2008 collapse.

For the environment, passing the tipping point means NO recovery.

There is a consensus among scientists that life as we know it will not survive if the temperatures increase another three degrees. So far, the global temperature is rising despite efforts to reduce the use of fossil fuels. Timelines for predicting the tipping points range around 2045. This means that time is of the essence.

Council, the ball is in your court. I am begging you to make the difficult, but correct vote to approve of all the CAP measures. Blow back from the business community is likely and you may lose some financial support, but in exchange you will have the gratitude and respect of your average resident, their progeny and all the critters that live and breathe in this beautiful community of Carlsbad.

Sincerely,
Barbara C. Diamond
3808 Skyline Road, Carlsbad CA 92008
1 Tammy Cloud-McMinn
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City of Carlsbad
November 12, 2024
Mayor, Council Members -
maryoren < [email protected] >
Tuesday, November 12, 2024 11:12 AM
City Clerk
Mary Oren
Item #8 11/12/24
Council comments from team 11.12.24.docx
Thank you for your hard work to lead our beloved Carlsbad, surviving the process of running for office and taking on the responsibility of getting things done for our better future - is something we deeply appreciate! Some speaking today worked hard to get you in place to do what you do! As Stevie Wonder sang many decades ago, Here We Are On Earth Together, It's You and I. We share this moment up close where we see smiles and concerned faces and miraculously at a distance - technology reminds us of the spinning blue globe we share making its way around our sun every day.

It's happening this minute in the room here and united on a big blue ball with a nearly full moon tagging along. With boots on the ground, I'm proud to say we've done a responsible job in Carlsbad.

So what exactly have we done? We've been open to progress, taking on needs and challenges with the kind of technology available to help us improve our quality of life. As time goes on we understand bad habits based on outdated technology can prove challenging yet we have to figure out a way to fix things.

At this moment, it's urgent. We're in that space of science and technology evolving to a better understanding of what we did right and what we did wrong, we just need leadership and community action to take a turn toward responsible progress, responsible management of our brilliant place under the sun. Carlsbad has come so far from the early days of magical water underground toward a desalination facility in place way ahead of other coastal communities. We removed an outdated energy source and eye sore along the coast and are embracing clean solar technology. We have improved road management with safer bike routes, provided popular commuter transit services that are heavily utilized and growing in routes and popularity and so much more is on the table that must be addressed now.

Over the years, we've asked and you responded as our leaders. Things don't seem to adjust on a global level fast enough these days let's be real - but that does not mean we can stop or slow down or dismiss the urgency of action in our town now. We've put together a request for you that needs quick action, ownership and dedication and we urge you to choose the CAP update with all measures, including building electrification reach codes and municipal solar carports as just the start of more solar expansion and storage to meet our energy use now and in the future.

It's so cliche but our kids and their kids and theirs - are counting on you, on us right now to do everything we can to address the serious impact our prior energy use has had on our planet, our 1 community, our future. We are in this together and must do all that we can to repair the damage that has been done. Science and technology has done their part, informed and given us options over the years. It is our responsibility as leaders and citizens to act on the science and technology available for us to respond to today. Thank you.

With gratitude,
Mary Oren
Carlsbad resident 25 years
Sierra Club Member
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2 11/11/24
Mayor, council members,
At the council meeting on 11/12/24 you'll be reviewing the updated Climate Action Plan (CAP). This has been in the works for over a year and the final version will set Carlsbad on the right, sustainable path toward addressing climate change. Last month the Planning Commission by a 4-3 vote recommended adopting the CAP with the exception of removing the reach codes in E-3.2 and E-4.2 as well as E-3.3 solar carports.

Please remove that measure from consideration for removal. 2) Within the same letter was the comment "Reach codes cost money." However, no clear examples have been given to indicate this is true. Our team and staff have repeatedly told public forums (PC and council meetings) that in order for any reach code to be approved by the CA Energy Commission it must be cost effective. There are ways to write up reach code ordinances fairly quickly. First, the state has an easy-to use tool, the Cost Effectiveness Explorer. This tool allows for mixed-fuel use in buildings. Secondly, other cities have adopted high performance reach code ordinances, specifically, Encinitas and San Luis Obispo.

These, too, allow for mixed-fuel use and can be used as a starting point to create an ordinance for Carlsbad. 3) Another point their letter and public comments to the PC brought up, was that the updated CAP didn't do an analysis on the cost impact from reach codes on the business community. In response to that I would point out that Council never directed staff to do any such study and, furthermore, for each reach code the time to analyze cost-effectiveness is once the ordinance details have been determined and written up not before the specifics have been laid out.
4) The reach codes under consideration have been part of Carlsbad's CAP since 2019. These are not newly minted measures. What the businesses are asking for is a big step backwards. 5) Their concerns for electrifying commercial buildings are valid. Not all businesses are created equal and some, such as laboratories, may need natural gas. However, exemptions can (and have been) written into ordinances to allow for special use. Also, as mentioned above, the currently adopted reach codes in other cities allow for mixed-fuel use.
6) Two local developments - Laguna Row and Marja Acres - are all electric. From discussions with the architect (LR, Brett Farrow) and developer (MA, KB Home) they saved, respectively, $100,000-200,000 and over $1,000,000 by not installing natural gas lines to their buildings.

Choosing the CAP update with all measures, including building electrification reach codes and municipal solar carports, is a necessary, strong step toward that better future.

Sincerely,
Paige DeCino on behalf of Carlsbad Sierra Club team
Tammy Cloud-McMinn
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To:

Subject:

Janis <[email protected]>
Tuesday, November 12, 2024 12:04 PM
City Clerk
Agenda Item #8- Climate Action Plan
Dear Honorable Mayor and City Council Members,
I urge you to adopt the Climate Action Plan as presented by l<atie Hentrich, including the following:
• Measure E-3.2: Nonresidential Building Energy- Update the city's building code ("reach code") to include enhanced energy performance requirements for new nonresidential buildings. • Measure E-3.3: Nonresidential Building Energy- Construct solar carports (install solar panels over outdoor parking spaces) at eligible city-owned parl<ing lots. • Measure E-4.2: Residential Building Energy- Update the city's building code ("reach code") to include enhanced energy performance requirements for new residential buildings.

Please incorporate these essential measures to ensure all possible steps are taken to reduce emissions, stabilize the climate, and safeguard a healthy planet for future generations.

Thank you for your leadership on this critical issue.

Sincerely,
Janis Jones
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1 Tammy Cloud-McMinn
From: Vanessa Forsythe <[email protected]>
Tuesday, November 12, 2024 12:33 PM Sent:

To: City Clerk
Subject: Agenda Item# 8: Support
Hello Honorable Mayor Blackburn and City Councilors
I ask that you adopt all of the measures indicated in the proposed Climate Action Plan Update including the business and residential reach codes and solar carports city owned parking lots (all of these were included in the CAP previously). My understanding is it is necessary for approval of Addendum 1 the Housing and Safety Element Update so implementation by the city can go forward.

Thank you to Katie Heinrich and other city staff for their efforts on the Updated Climate Action Plan - a tremendous effort.Throughout the plan most of the actions indicate a co-benefit to public health.

As a healthcare professional and community member I am addressing these factors why both upstream and resulting downstream measures to decrease greenhouse gases and address climate change now are necessary for approving the updated CAP along with present and implementation measures relative to the health and sustainability of our community:

1. We are experiencing more extreme weather events including: rising temperatures, drought, severe storms with flooding and landslides, rising sea levels (beach erosion}, and wildfires.

2. All of these have been scientifically proven to be related to climate change and are impacting our community and planet sustainability as well as resulting in immediate health and economic costs.

3. Health and sustainability impacts:
• impact on our crop yields and food supply
• decreased water supply
• increase ER visits and hospitalizations, loss or work time and school attendance • increase occurrence of injuries, increase episodes of overheating and heat stroke and preterm births
• loss of green canopy and carbon sequestration as we lose trees and lagoons • increase allergens and pollen because longer seasons for cultivating • increase vector borne and infectious disease (survive in heat) • mental health and stress related disorders (particularly impacting our youth with increasing uncertainty and despair about their future)
• increase occurrence and severity of lung, heart and kidney conditions • loss of biodiversity and extinction with extreme weather and loss of habitat - affecting insects, birds, animals and plants
• loss of connecting with our open spaces, beaches and natural wildlife - that make Carlsbad such a wonderful place to live andvisit
1 I refer you to this page from the Effects of Climate Chan eon Health from the CDC. Please support the Updated CAP and continued implementation of these measures promoting a sustainable and healthy environment for all of Carlsbad now wna in the future.

Thank you for your consideration.

Vanessa
Vanessa Forsythe RN MSN
California Nurses for Enviro mental Health & Justice
CleanEarth4Kids
Climate Health Now
"Keep Marching ... your ancestors are all the proof that you need that progress is possible not guaranteed ... keep marching on ... the future demands that we fight for it now" 2 Tammy Cloud-McMinn
From:

Sent:

To:

Subject:
( City of
Carlsbad
Dr. Melanie Burkholder
City Council Member, District 1
City of Carlsbad
1200 Carlsbad Village Drive
Carlsbad, CA 92008
www.carlsbadca.gov
442-339-2830 (City Hall)
442-637-2853 (mobile/text)
Melanie Burkholder
Tuesday, November 12, 2024 12:52 PM
City Clerk
Fw: Climate Action Plan
From: KC <[email protected]>
Sent: Tuesday, November 12, 2024 10:42:35 AM
To: Melanie Burkholder <[email protected]> Subject: Climate Action Plan
Hello,
I live in District 1. I have a question about the Climate Action Plan. Are these actions mandated by the state? Kevin Coyle
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1 Tammy Cloud-McMinn
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Subject:

Mary Hassing <[email protected]>
Tuesday, November 12, 2024 1 :28 PM
City Clerk
Comments to the City Council on Agenda #8, Nov. 12
Mayor Blackburn, City Council Members,
As a resident of Carlsbad, I ask that you approve the Updated Climate Action Plan as written. City staff from every department have been involved in the creation of this draft and they made a tremendous effort to gather information from resident stakeholders. The responses from the citizens of this city are included in the draft packet and they are resoundingly in favor of a robust plan of action against climate change.

As homeowners, we are making changes, investing in solar power and heat pumps, and driving electric and hybrid vehicles. But we depend on you to make decisions that will make the biggest impact. We depend on you to stay true to the Climate Emergency Resolution you passed in 2021. Our children are watching. They know the ocean is rising. They know the droughts and wildfires are getting worse. They keep their go-bags packed for evacuation.

Please approve the CAP as written, Option #4.

Sincerely,
Mary Hassing
2679 Regent Road, Carlsbad
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1 Tammy Cloud-McMinn
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Subject:

Ip <[email protected]>
Tuesday, November 12, 2024 1 :53 PM
City Clerk
Item# 8
Please include in tonight's agenda. Thank you.

I object to the adoption of the City's CAP until other parties are given equal time to express their opposing opinions to staff Regards,
D. Persico
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Cc:

Subject:

Attachments:

Craig Benedetto <[email protected]>
Tuesday, November 12, 2024 1 :54 PM
City Clerk
Paz Gomez; James Wood; Katie Hentrich
Item #8 - Carlsbad CAP Update - Nov 12, 2024
CBAD CAP Ltr - City Council - Nov 12, 2024.pdf
Attached, please find a letter for tonight's council hearing regarding Item #8, the City's Draft Climate Action Plan Update. Thank you for your consideration and for distribution to the City Council.

Sent by:

Craig Benedetto
California Strategies
530 B Street, Suite 920
San Diego, CA 92101
0: (619) 546-7 451
C: (619) 980-8032
E: [email protected]
www.calstrat.com
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1 Carlsbad Chamber of Commerce
San Diego Regional Chamber of Commerce
BOMA San Diego
Building Industry Association of San Diego
California Apartment Association
San Diego County Lodging Association
San Diego North Economic Development Council
Southern California Rental Housing Association
California Restaurant Association
Associated General Contractors San Diego
NAIOP San Diego
November 12, 2024
Honorable Keith Blackburn
Mayor
City of Carlsbad
1200 Carlsbad Village Drive
Carlsbad, CA 92008

TRANSMITTED ELECTRONICALLY
RE: Draft Climate Action Plan Update - Please Support Option 1 with Modifications Dear Mayor Blackburn and Members of the Carlsbad City Council:

On behalf of the undersigned coalition of jobs and housing providers, we are writing today in support of the Planning Commission recommended Item 1 of the options included in the November 12th staff report with a couple of additional modifications. Item 1 would remove the "reach code" items related to residential and non-residential development. In terms of modifications, we would respectfully request the removal of the requirement for electrification of construction equipment, as well as the expansion of the "transportation demand management" or TOM requirements. We would also suggest the inclusion of the solar car port requirement for government facilities, which would further demonstrate the City's willingness to lead by example.

By adopting staff delineated Option 1 with these modifications, you are still not only meeting your near term goals of attainment by 2035, you will also likely do so for the 2045 timeframe. This modified option still allows Carlsbad to be a leader on reducing greenhouse gas emissions (GHG), while also balancing the cost and consequences to your residents and businesses. It also helps protect against legal risk to the City in moving forward with a de facto electrification mandate through a Reach Code.

In terms of the concerns regarding the other options, the coalition is opposed to the adoption of a separate Reach Code. The state code, including the recently finalized triennial building code, is one of the most stringent in the world. And the new measures under the code would continue to ratchet up these GHG reducing measures in new construction and tenant improvements. The City's own GHG reductions would significantly benefit from these changes once they go into effect. Going beyond with a Reach Code only puts Carlsbad at a competitive disadvantage with your neighbors as a Reach Code comes at a high cost, which would dramatically increase the cost of both residential housing and commercial tenancy. It would also create legal risk, as was seen in the City of Berkeley, given the means of compliance with the building performance budget allowance would likely result in the need to eliminate all natural gas from buildings.

The coalition is also opposed to the new requirements related to the electrification of construction equipment. In most cases, this kind of equipment is not available and, where it is, is extremely expensive. Mass production at useful grade for construction sites is not expected for some time, if at all, given the power needs for this kind of equipment. We would recommend delaying this item until a subsequent update to better determine the state of the market.

Regarding TDM, it is a difficult measure to implement as it's expensive, unpopular with employees and impossible to manage. As was noted at the previous Planning Commission hearing, Carlsbad businesses and property owners are already avoiding triggering these requirements under the current CAP, given their high cost. Further, depending on the TOM requirements, congestion pricing and punitive parking fees would disproportionately impact lower income workers, and for the lodging industry, dissuade visitors from coming to Carlsbad. In short, expanding TOM would likely achieve little in the way of GHG reductions, and create a number of other impacts, including fewer tourists, less TOT, and for those who choose to avoid triggering the requirements, further reducing tenant improvement investments, which would age the city's building stock.

It should be noted that for both the construction equipment item, as well as the enhanced TDM measure, these are not significant drivers of GHG. Further, the staff report doesn't take into consideration the recent decision this past weekend by the California Air Resources Board to change the Low Carbon Fuel Standards (LCFS) which will, according to their staff report, significantly reduce GHG emissions.

Lastly, we continue to have concerns about the lack of financial impact analysis for the proposed actions.

While the City was willing to expend money to determine the impact to itself, it didn't afford the same action for impacts to the regulated community. We believe this kind of analysis should be done before approval, not after when implementation is being considered.

In closing, we thank the Planning Commission and City staff for hearing the concerns of our coalition and providing a reasonable, yet aggressive option in the Option 1 recommendation. With our additional modifications, we would respectfully request the Council's support of Recommendation Items 1 and 2.

Sincerely,
Bret Schanzenbach, Carlsbad Chamber of Commerce
W. Erik Bruvold, San Diego North Economic Development Council Craig Benedetto, NAIOP San Diego & BOMA San Diego
Justine Murray, San Diego Regional Chamber of Commerce
Melanie Woods, California Apartment Association
Molly Kirkland, Southern California Rental Housing Association Chris Duggan, California Restaurant Association
Lori Holt Pfeiler, Building Industry Association of San Diego Fred Tayco, San Diego County Lodging Association
Dustin Steiner, Associated General Contractors San Diego CC: Paz Gomez, Deputy City Manager
James Wood, Director, Environmental Sustainability
Tammy Cloud-McMinn
From:

Sent:

To:

Subject:

Howard Krausz <[email protected]>
Tuesday, November 12, 2024 1 :57 PM
City Clerk
Agenda item #8, CAP
Here are some comments I hope the council will consider before finalizing the draft CAP.

Some thoughts about the CAP Update:

Introduction 1.1 Well written. Does not deny that climate change is a critically serious problem exacerbated by humans burning fossil fuels. The CAP and its implementation need to match the challenges. Buying mitigation credits, as mentioned elsewhere in the document, is not a solution.

Figure and Table 2.1 27% of Greenhouse Gas Emissions are "Electricity" but it needs to be clear that those are from the production of electricity by fossil fuel run generators. Demand for electricity will increase rapidly. The CAP Update should include more specifics about local solar energy production, battery storage and even the possibility of a small nuclear generator as used by some submarines and aircraft carriers to reduce GHG emissions from electricity generation.

Section 2.4 CA requires PV installations in new residential construction but only low-rise multifamily housing. What about the coming high rise multifamily housing under density bonus laws? Table 3.1 T-2 TOM program accounts for the most GHG reductions but there is little detail about how this will actually work.

T-4 Bikeway Safety improvements. These need to harmonize with new regulations about e-bikes and be done in consultation with frequent cyclists to ensure safety and to allow both e-bikes and other non-electric bikes to operate together.

Water While only 1 % of GHG emissions are from water transport and delivery this doesn't include energy use for desalination, which will be increasingly necessary. Perhaps this is not the appropriate document, but water conservation, recycling and desalination will all be more necessary as population increases and climate change worsens. These water issues must be addressed and dealt with.

Urban Canopy Planting more trees for carbon sequestration and oxygen production is very important but that requires open space. The Growth Management Plan performance standard of open space is 15% of unconstrained developable land in each LFMZ must be left open. Carlsbad must require that at least 15% of the footprint of new developments be left open and should work much harder to preserve remaining open space. Where possible, rooftop gardens should be encouraged particularly on large buildings, in addition to rooftop solar panels. Brush and forest fires reduce carbon sequestration and fuel global warming.

Howard Krausz, MD
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From:

Sent:

To:

Cc:

Subject:

Jose Torre-Bueno <[email protected] >
Tuesday, November 12, 2024 1 :57 PM
City Clerk
Don Christiansen
Comment on Item 8 the Climate Action Plan
The Center for Community Energy, a local 501 (c)3 environmental non-profit organization would respectfully like to make the following comments on the City of Carlsbad's Climate Action Plan.

We are aware that including solar canopies with EV charging stations over city owned parking lots was considered as part of the Climate Action Plan. We strongly advise including this measure for the following reasons. Beyond the immediate CO2 reduction from powering some fraction of driving from locally derived solar energy there are secondary benefits to ratepayers. To the extent that energy is generated locally the need to add new long distance transmission lines is reduced. This build out of transmission infrastructure is a major factor in utility rate increases (1 ). An additional factor in rate increases is the necessity to upgrade the local distribution system to accommodate building and transportation electrification. A study sponsored by the CPUC estimated this will add approximately $50 billion to utility costs (2). A follow-on study by the CEC (3) has shown this can be substantially reduced if EVs are charged during the day, so charging in city lots will be very advantageous. Further, in the future it is probable that many EVs will be bidirectional. Studies by our organization have shown that bidirectional EVs arriving home fully charged could send power into homes via bidirectional chargers, saving the owners high evening electric rates and reducing the load on the grid in the evening.(4) This load reduction can further avert the need for future rate increases. 1 Energy Strategies. (2024). The Connected West Study. A report commissioned by Gridworks and GridLab. Salt Lake City, UT. www.energystrat.com pg 37
2 Kevala Part 1: Bottom-Up Load Forecasting and System-Level Electrification Impacts Cost Estimates pg 20 3 CEC Public Advocates Office Distribution Grid Electrification Model Supplemental Analysis March 2024 4 https://centerforcommunityenergy.org/wp-content/uploads/2024/1 0/ECCE2024-Oral-Presentation.pd Jose Torre-Bueno, Ph.D.

Executive Director
Center for Community Energy
(619) 977-0553
~/i . .; mm FOH frtr:cc •. , COMMUNITY ,~:: • • ••••• ' CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content i 1 Tammy Cloud-McMinn
From:

Sent:

To:

Council Internet Email
Tuesday, November 12, 2024 2:28 PM
City Clerk
Subject:

Attachments :

FW: Item #8 - City of Carlsbad Climate Action Plan Update - Nov 12, 2024 CBAD CAP Ltr - City Council - Nov 12, 2024.pdf
All Receive - Agenda Item #,2
For the Information of the:

C)l)'_~OUNCIL
Date 1..)/!g_ CA _ CC I/"
From: Craig Benedetto <[email protected]> CM _ ACM_ DCM (3) _ Sent: Tuesday, November 12, 2024 1:59 PM
To: Keith Blackburn <[email protected]>; Priya Bhat-Patel <[email protected]> ; Teresa Acosta <[email protected]>; Melanie Burkholder <melanie [email protected]>; Carolyn Luna <carolyn.Luna@carlsbadca .gov>
Cc: Council Internet Email <[email protected]>
Subject: Item #8 - City of Carlsbad Climate Action Plan Update - Nov 12, 2024 Attached , please find a coalition letter regarding Item #8 which will be considered at this evening's city council meeting. We appreciate your consideration of the coalition's recommended request. Please don't hesitate to call if you have any questions . Thank you ... csb Sent by:

Craig Benedetto
California Strategies
530 B Street, Suite 920
San Diego, CA 92101
0: (619) 546-7451
C: (619) 980-8032
E: [email protected]
www.calstrat.com
1 Carlsbad Chamber of Commerce
San Diego Regional Chamber of Commerce
BOMA San Diego
Building Industry Association of San Diego
California Apartment Association
San Diego County Lodging Association
San Diego North Economic Development Council
Southern California Rental Housing Association
California Restaurant Association
Associated General Contractors San Diego
NAIOP San Diego
November 12, 2024
Honorable Keith Blackburn
Mayor
City of Carlsbad
1200 Carlsbad Village Drive
Carlsbad, CA 92008

TRANSMITTED ELECTRONICALLY
RE: Draft Climate Action Plan Update - Please Support Option 1 with Modifications Dear Mayor Blackburn and Members of the Carlsbad City Council:

On behalf of the undersigned coalition of jobs and housing providers, we are writing today in support of the Planning Commission recommended Item 1 of the options included in the November 12th staff report with a couple of additional modifications. Item 1 would remove the "reach code" items related to residential and non-residential development. In terms of modifications, we would respectfully request the removal of the requirement for electrification of construction equipment, as well as the expansion of the "transportation demand management" or TDM requirements. We would also suggest the inclusion of the solar car port requirement for government facilities, which would further demonstrate the City's willingness to lead by example.

Regarding TDM, it is a difficult measure to implement as it's expensive, unpopular with employees and impossible to manage. As was noted at the previous Planning Commission hearing, Carlsbad businesses and property owners are already avoiding triggering these requirements under the current CAP, given their high cost. Further, depending on the TDM requirements, congestion pricing and punitive parking fees would disproportionately impact lower income workers, and for the lodging industry, dissuade visitors from coming to Carlsbad. In short, expanding TDM would likely achieve little in the way of GHG reductions, and create a number of other impacts, including fewer tourists, less TOT, and for those who choose to avoid triggering the requirements, further reducing tenant improvement investments, which would age the city's building stock.

Lastly, we continue to have concerns about the lack of financial impact analysis for the proposed actions.

Sincerely,
Bret Schanzenbach, Carlsbad Chamber of Commerce
W. Erik Bruvold, San Diego North Economic Development Council Craig Benedetto, NAIOP San Diego & BOMA San Diego
Justine Murray, San Diego Regional Chamber of Commerce
Melanie Woods, California Apartment Association
Molly Kirkland, Southern California Rental Housing Association Chris Duggan, California Restaurant Association
Lori Holt Pfeifer, Building Industry Association of San Diego Fred Tayco, San Diego County Lodging Association
Dustin Steiner, Associated General Contractors San Diego CC: Paz Gomez, Deputy City Manager
James Wood, Director, Environmental Sustainability
Tammy Cloud-McMinn
From:

Sent:

To:

Subject:

Attachments:

Susan Clifford <[email protected]>
Tuesday, November 12, 2024 2:53 PM
City Clerk
Reject my tax dollars to be spent on Climate
Screenshot_20240526_083134_XJpg; Screenshot_20240526_092707 _XJpg We reject my tax dollars to be spent on any and all climate initiatives for the City of Carlsbad. The first mention of Climate change was in the 1970s. The World Economic Forum Opened in 1971.

The Climate change Agenda is part of the World Economic Forum Globalist Agenda to control the World population through Climate control implementing lockdowns, limits on natural gas, and coal.

Both Al Gore and John Kerry are members of the World Economic Forum.

This informative video is The World Economic Forum Agenda. https:/ /youtu. be/ A 1 m4zZvyCxg?feature=shared
Our Government only funds scientist that write scientific papers that support Climate change and reject scientists who disprove Climate change.

Many politicians in our Government including Joe Biden are members of The World Economic Forum.

Sincerely
Susan Clifford
7027 Cinnamon Teal St, Carlsbad, CA 92011.

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1 Al Gore
WORLD

ECONOMIC
FORUM
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( Sign in)
V,c._, President of tht: United Stat,.:i:, '.1993-2001):

Vice-President of the United States (1993-
2001); Chairman and Founding Partner
Generation Investment Management LLP
t-ormer vice t-1resIaent: Al Jre is a founding
partner and chairman of Generation
Investment Management, the founder and
~li~ir,r-p:, ~ f ~;1 ➔ Cl:rr.,t<J lity Project, and
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Tammy Cloud-McMinn
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Subject:

Hi-
Krisha Markowicz < [email protected] >
Tuesday, November 12, 2024 5:02 PM
City Clerk
Oppose climate agenda
I oppose the climate agenda. Carlsbad needs to focus on keeping the city safe, focus on the homeless issue and worry about the citizens that can't afford their groceries.

Mrs. Wolter( district 2)
Sent from my iPhone
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1 Climate Action Plan Update
Katie Hentrich (she/her)
Climate Action Plan Administrator
Nov. 12, 2024
1 Hold a public hearing and adopt a resolution for one of the following Climate Action Plan Update options:

RECOMMENDED ACTIONS
2 2045 reduction level

1. Exclude residential and nonresidential energy reach code updates and solar carports at city owned parking lots Meets

2. Exclude nonresidential energy reach code update only Exceeds by 200 MT CO2e

3. Exclude residential energy reach code update only Exceeds by 4,000 MT CO2e

4. Adopt as presented (including all measures) Exceeds by 6,000 MT CO2e ITEM 8: CLIMATE ACTION PLAN UPDATE
3 That the City Council adopt the following:

1. A resolution certifying Addendum No. 1 to the Housing Element Implementation and Public Safety Element Update
Supplemental Environmental Impact Report for the Climate Action Plan Update.

ITEM 8: CLIMATE ACTION PLAN UPDATE
RECOMMENDED ACTIONS (CONT.)
• Why CAP Update is required
• Inventory, projections, reduction targets
• Public and decisionmaker input
• Options
• Next steps
• Conclusion
4 ITEM 8: CLIMATE ACTION PLAN UPDATE
TODAY’S PRESENTATION

5 APRIL 4, 2021
City Council approved
Housing Element update
APRIL 13, 2021
Staff presented CAP
Annual Report 4, need
for CAP Update
SEPT. 16, 2022
Assembly Bill 1279
signed into law
JUNE 8, 2021
City Council approved
funding for CAP Update
JAN. 30, 2024
City Council certified Final SEIR for
Housing Element update, including
Mitigation Measure GHG-1
ITEM 8: CLIMATE ACTION PLAN UPDATE

WHY CAP UPDATE IS REQUIRED

6 GREENHOUSE GASES IN CARLSBAD
ITEM 8: CLIMATE ACTION PLAN UPDATE

2035
50% below baseline
Senate Bill 32
General Plan
2045
85% below baseline
Assembly Bill 1279

TARGETS
7 ITEM 8: CLIMATE ACTION PLAN UPDATE

PROJECTIONS
993,000
1,024,000
981,000
456,000 239,000
490,000
147,000
-
200,000
400,000
600,000
800,000
1,000,000
1,200,000
2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 MT CO2e
Year
BAU Legislatively-adjusted BAU GHG reduction targets
8 ITEM 8: CLIMATE ACTION PLAN UPDATE
9 9

MEASURE CATEGORIES
ITEM 8: CLIMATE ACTION PLAN UPDATE

10 ITEM 8: CLIMATE ACTION PLAN UPDATE

PUBLIC INPUT, THREE PHASES

OVERALL PRIORITIES REVIEW OF

POTENTIAL MEASURES

REVIEW DRAFT PLAN
PHASE 1: IDEAS, PRIORITIES, CONCERNS
11 • Workshop
• Online survey
• Ideas board
• Social media
• News releases
• Emails
ITEM 8: CLIMATE ACTION PLAN UPDATE

PHASE 2: REVIEW DRAFT MEASURES
• Online survey
• Meetings with interested stakeholders
• Community events
• Social media
• Emails
• News releases
• Flyers at facilities
• City Council presentation
12 ITEM 8: CLIMATE ACTION PLAN UPDATE

CITY COUNCIL MEMBER FEEDBACK
• Consider establishing clear, interim benchmarks between 2035 and 2045 target years
• Consider adding more measures so GHG emission reductions exceed the 2045 reduction target
• Consider adding a measure to install solar in city-owned parking lots • Consider adding a measure banning artificial turf within municipal facilities 13 ITEM 8: CLIMATE ACTION PLAN UPDATE

PHASE 3: REVIEW DRAFT PLAN
• Meetings with interested stakeholders
• Community events
• Social media
• Emails
• News releases
• Flyers at facilities
• Planning Commission presentation
14 ITEM 8: CLIMATE ACTION PLAN UPDATE
15 PLANNING COMMISSION
Sept. 4, 2024
Informational presentation/discussion
Oct. 2, 2024

1. Recommend adopting “Option 1”
Exclude residential and nonresidential energy reach code updates and solar carports at city owned parking lots

2. Recommend certifying addendum
15 ITEM 8: CLIMATE ACTION PLAN UPDATE

OPTIONS
16 2045 reduction level

1. Exclude residential and nonresidential energy reach code updates and solar carports at city owned parking lots Meets

2. Exclude nonresidential energy reach code update only Exceeds by 200 MT CO2e

3. Exclude residential energy reach code update only Exceeds by 4,000 MT CO2e

4. Adopt as presented (including all measures) Exceeds by 6,000 MT CO2e ITEM 8: CLIMATE ACTION PLAN UPDATE

NEXT STEPS
• Finalize document based on selected option
• Begin implementing CAP Update, particularly measures and actions with 2025 monitoring benchmarks
• Monitor and report annually
• Create an online dashboard for tracking progress
• Prepare future updates to the CAP
17 ITEM 8: CLIMATE ACTION PLAN UPDATE
18 Hold a public hearing and adopt a resolution for one of the following Climate Action Plan Update options:

RECOMMENDED ACTIONS
2045 reduction level

1. Exclude residential and nonresidential energy reach code updates and solar carports at city owned parking lots Meets

2. Exclude nonresidential energy reach code update only Exceeds by 200 MT CO2e

3. Exclude residential energy reach code update only Exceeds by 4,000 MT CO2e

4. Adopt as presented (including all measures) Exceeds by 6,000 MT CO2e ITEM 8: CLIMATE ACTION PLAN UPDATE
RECOMMENDED ACTIONS (CONT.)
19 That the City Council adopt the following:

1. A resolution certifying Addendum No. 1 to the Housing Element Implementation and Public Safety Element Update
Supplemental Environmental Impact Report for the Climate Action Plan Update.

ITEM 8: CLIMATE ACTION PLAN UPDATE

OPEN PUBLIC HEARING
ITEM 8: CLIMATE ACTION PLAN UPDATE

CLIMATE ACTION PLAN UPDATE

WHAT OTHER CITIES ARE DOING
• City of San Diego*: adopted CAP Update 8/2/2022, net zero by 2035 target • County of San Diego*: adopted CAP Update on 9/11/2024, 85% by 2045 target, with an “aspirational goal” of net zero by 2045
• City of Solana Beach: adopted CAP Update 10/9/2024, 85% by 2045 target • City of La Mesa*: draft CAP Update posted to website, estimated adoption by end of Nov. 2024, 85% by 2045 target • City of Encinitas*: draft measures shared, 85% by 2045 target • City of Chula Vista: CAP Update measure development and outreach underway, net zero by 2045 target • Other jurisdictions with adopted CAPs were adopted/updated prior to AB 1279 * CEQA-qualified CAP

CLIMATE ACTION PLAN UPDATE
MEASURE OR-2 (INCREASE RENEWABLE OR

ALTERNATIVE FUEL CONSTRUCTION EQUIPMENT)
• Measure language
• “Develop, adopt, and implement an ordinance requiring new developments and significant land-moving and construction projects to use electric-powered or alternatively-fueled construction equipment that reduces 50% of emissions from construction activities”
• Long-term implementation by 2045
• Other jurisdictions with similar CAP measures:
• City of Escondido
• City of Vista
• County of San Diego
• City of Santa Rosa, County of San Bernadino, Butte County • Some electric construction equipment is now available

CLIMATE ACTION PLAN UPDATE
MEASURE E-3.3 (NONRES BLDG. ENERGY – SOLAR

CARPORTS)
• Measure background
• Was included as a supporting action in proposed measures shared with the public and with City Council on Nov. 7, 2023 (in Nonres. Bldg. Energy – Existing Reach Code) • City Council and public comments to make a standalone measure • Measure is unquantified due to lack of available data • Measure language
• “Construct solar carports (also known as installing solar panels over outdoor parking spaces) at city-owned parking lots”
• Medium-term implementation (6-10 years), with a monitoring benchmark in 2030 for a feasibility study • Complements supporting actions in Measures E-1 and E-3.1 Source: Carlsbad Unified School District

Source: US EPA Greenhouse Gas Equivalencies Calculator
43 6,000 MT
Option 4
1,428 cars driving
for typical use over
1 yr
782 homes’ energy
use for 1 yr
4,000 MT
Option 3
952 cars driving for
typical use over 1
yr
522 homes’ energy
use for 1 yr
200 MT
Option 2
48 cars driving for
typical use over 1
yr
26 homes’ energy
use for 1 yr

Carlsbad City CouncilNovember 12, 2024

Carlsbad City Council
November 12, 2024