To the members of th,:
COUNCIL
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Council Memorandum
September 3, 2026
To:
From:
Via:
Honorable Mayor Blackburn and Members of the City Council Jeff Murphy, Deputy City Manager, Community Services
Mike Strong, Community Development Director
Sheila Cobian, Assistant City Manager l;) l2U
{city of
Carlsbad
Memo ID# 2026045
Re: Local Coastal Program Update -Coastal Commission Review Status (Districts -All) This memorandum provides an update on the status of the city's comprehensive update to its Local Coastal Program (LCP) that was approved by the City Council in 2021 and is pending action by the Coastal Commission.
Background
The city has been working with Coastal Commission staff to attain Coastal Commission approval of its LCP amendment since December 2021, when the City Council approved it. Refer to the Council Memorandum dated September 25, 2025, for background on the LCP amendment application review process to date (Attachment A). Under state statute, the Coastal Commission has until February 22, 2027, to act on the city's LCP amendment application. Coastal Commission staff have indicated that they are tentatively targeting a meeting in October 2026 to consider the application, but for the reasons explained below city staff do not feel that date is likely.
Discussion
The Coastal Commission holds monthly meetings in different locations across the state to allow public participation in coastal planning and permitting. Hearing locations are usually rotated between southern, central, and northern California. If possible, city or project applications are scheduled for local hearings to assist with public participation. While the Coastal Commission tries to schedule new city business and hearings locally, legal deadlines may require that they be held in other areas.
The November and December meetings will not be in the San Diego region, but in San Francisco and Newport Beach, respectively. The city has, for the past several months, continuously expressed a strong preference for Coastal Commission staff to work towards the October meeting, which will take place in the City of Oceanside, as it is more convenient for interested local parties to attend.
Ever since the application was submitted in 2021, city staff have participated in numerous meetings, including a site visit to tour the city's coastal resources. In May 2024, Coastal Commission staff provided over 200+ modifications and policy changes that they wanted to be made to the city's LCP. As reflected in the 2025 Council Memorandum, city staff disagreed with Community Services Branch
Community Development Department
1635 Faraday Avenue I Carlsbad, CA 92008 I 442-339-5088 t
Council Memo -Local Coastal Program Update -Coastal Commission Review Status September 3, 2026
many of the requested changes, particularly changes to long standing previously agreed upon policies affecting environmentally sensitive habitat, lower-cost visitor accommodations, scenic resources, and water quality.
City staff attempted to resolve areas of Coastal Commission staff concern and incrementally provided responses/proposed counter language to their 200+ proposed changes starting in early 2025 and concluded this effort in January 2026. While city and Coastal Commission staff have subsequently held meetings to discuss the revised language, city staff are still waiting to receive Coastal Commission staff's full response to those changes.
Given the October hearing target, city staff expressed a need to receive most of Coastal Commission staff responses by July 2026 to provide the city with adequate time to review their proposed modifications and resolve any remaining issues prior to the October 2026 meeting. City staff were initially told that the modifications would be sent to the city chapter by chapter (eight chapters total) and, more recently, coastal staff indicated that the city may receive modifications for three or four chapters by end of August. To date, the city has only received two of the eight draft chapters. Chapter 5 (Agricultural, Cultural, and Scenic Resources) was received on August 20, 2026, and Chapter 3 (Recreation and Visitor Serving) was received on August 21, 2026. No estimate has been provided for when the city might receive modifications for the remaining chapters.
At the time of this writing, Coastal Commission staff are still targeting an October meeting for the city's proposed LCP amendment. There is a chance that city staff will not know the full magnitude of Coastal Commission staff's proposed changes until their staff report is released to the public.
This situation is unfortunate. City staff should be given ample opportunity and time to review Coastal Commission staff's suggested modifications to determine if they are aligned with the city's policy stance, or if additional alternative modifications are needed BEFORE being presented before the Coastal Commission. It is becoming apparent that city staff are not being given this opportunity.
The city has completed all actions within its control, and sole delay for Coastal Commission's approval of the LCP amendment is Coastal Commission staff's inability to complete its review and timely transmit the suggested modifications to the city. Any ability to make the October meeting with mutually agreed upon LCP amendment is currently outside the city's control.
Next Steps
City staff will continue to meet with Coastal Commission staff as policy modifications become available. If policies are proposed that are not supported by city staff, city staff will voice their concerns and opposition during the public comment portion of the Coastal Commission meeting.
Once the LCP amendment and any suggested modifications are approved by the Coastal Commission, city staff will present the modifications (with city staff recommendation) to the City Council for consideration. The City Council has six months following Coastal Commission action to either accept the modified LCP amendment in its entirety or reject (withdraw) the LCP amendment. If the City Council does not adopt the modified LCP amendment within six months
Council Memo -Local Coastal Program Update -Coastal Commission Review Status September 3, 2026
of the Coastal Commission's action, the city's existing LCP remains in effect. If the Coastal Commission modifies the city's LCP amendment, and the City Council wants to change those modifications, the city must process a new application -effectively starting this process over.
Attachment: A. Council Memorandum dated September 25, 2025 cc: Geoff Patnoe, City Manager
Cindie McMahon, City Attorney
Dalton Sorich, Assistant City Attorney
Eric Lardy, Assistant Community Development Director
Attachment A
To the members of the:
CITY COUNCIL
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CM ACM/ DCM (3)v
September 25, 2025
Council Memorandum
To:
From:
Honorable Mayor Blackburn and Members of the City Council Gary Barberio, Deputy City Manager, Community Services
Via:
Jeff Murphy, Community Development D/!)ctoJ
Sheila Cobian, Assistant City Manager ~
{city of
Carlsbad
Memo ID# 2025056
Re: Local Coastal Program Update -Coastal Commission Review Status (Districts -All) This memorandum is an update to the City Councill memorandum dated November 2, 2023, which provided a status of the city's comprehensive update to its Local Coastal Program (LCP) that was approved by the City Council in 2021.
Background
The City Council approved on October 12, 2021, a comprehensive update to the city's LCP (Attachment A), which was subsequently submitted to the Coastal Commission in December 2021 for approval. Under state law, and with a one-year time extension granted in August 2022, the Coastal Commission had until August 2023 to act on the city's application. In May 2023, Coastal Commission staff informed the city that they would not be able to complete their review before August 2023, and therefore requested the city withdraw the application to provide them with more time to review and comment. The city agreed to this request and withdrew the LCP update application in June 2023 (Attachment B).
While the Coastal Commission staff committed, as part of the city's withdrawal, to provide the city with all outstanding comments within the following two months, all remaining comments (over 200 in total) were not received until May 2024, roughly 11 months later. Since then, city staff have reviewed, evaluated and held informal discussions on the comments with Coastal Commission staff in an effort to work out a compromise.
Discussion
City staff evaluated and categorized the comments provided by the Coastal Commission staff on a scale from "easy" to "challenging" resolution. The topics with the widest disagreement included policies affecting environmentally sensitive habitat, sea level rise, lower-cost visitor accommodations, scenic resources, environmental justice, and water quality.
As stated in the 2023 Council Memorandum (Attachment B), because there was such disagreement between the city and Coastal Commission staff on key policy issues, city staff anticipated that a presentation to City Council would be necessary to discuss the discrepancies and seek further direction .
Community Services Branch
Community Development Department
1635 Faraday Avenue I Carlsbad, CA 92008 I 442-339-5088 t
Council Memo -Local Coastal Program Update -Coastal Commission Review Status September 25, 2025
However, over the past six months Coastal Commission staff have expressed flexibility in their position and a willingness to compromise on key policy issues, and city staff are optimistic that with further meetings and discussion staff will be able to resolve the differences to a level of mutual agreement.
Given the progress achieved to date, city staff intend to restart the official Coastal Commission approval process by resubmitting the LCP update application to the Coastal Commission next month (October 2025). State law requires that an application to amend a LCP must be submitted to the Coastal Commission within four years of the last public hearing on the amendment, which in the case of the LCP update was City Council's approval of the update on October 12, 2021. As such, the city must submit (resubmit) the LCP update by October 12, 2025, to continue the processing of the LCP amendment.
Next Steps
After the city resubmits the LCP update, Coastal Commission staff will follow state law timing requirements for processing an LCP amendment application. Like the last submittal, state law provides the ability for the Coastal Commission to grant a one-year time extension on the processing time; city staff anticipate that Coastal Commission action on the LCP update may occur approximately 18 months after resubmittal. During that time, city staff will continue to coordinate with the Coastal Commission's staff to find resolutions to all of their comments on the LCP update.
City staff will continue to provide LCP status updates to the City Council via Council Memorandum.
Attachment:
A. City Council staff report dated October 12, 2021 (on file with the City Clerk's Office) B. Council Memorandum dated November 2, 2023 (on file with the City Clerk's Office) cc: Geoff Patnoe, City Manager
Cindie McMahon, City Attorney
Dalton Sorich, Assistant City Attorney
Mike Strong, Assistant Community Development Director
Eric Lardy, City Planner
Robert Efird, Principal Planner
Jennifer Jesser, Senior Planner