Agenda, first session — Del Mar City Council, October 2, 2023

Del Mar City Council Meeting Agenda
Del Mar Town Hall
1050 Camino del Mar, Del Mar, California
October 2, 2023 City Council Meeting

INFORMATION RECEIVED

AFTER THE COUNCIL AGENDA

WAS DISTRIBUTED
(“Red Dots”)

CITY COUNCIL AGENDA QUESTIONS
OCTOBER 2, 2023
Item 5 – ChargePoint Electric Vehicle Charging Stations Warranty Coverage and Maintenance Contract Extension

1. It would be nice if staff would report on what the usage history of our chargers has been, the revenue received, and on the maintenance and warranty claims history.

Response: For FY23 (July 1, 2022-June 30, 2023) the City’s ChargePoint charging stations (4 total with 6 ports) collected $16,359.16 in gross revenue from 3,727 charging sessions. The total accumulated energy used during this time was 40.62MWh. The accumulated greenhouse gas (GHG) savings was 28,840kg, which is equivalent to GHG emissions from 3.4 gasoline-powered passenger vehicles driven for one year or 73,933 miles drive by an average gasoline-powered passenger vehicle.

The average port utilization of the chargers for 24-hour periods are as follows for the last three months:

June 2023: 17.10%
July 2023: 12.13%
August 2023: 17.97%
The average session duration (hours) of all charges during the last three months:

June 2023: 2.74 hours
July 2023: 2.32 hours
August 2023: 2.55 hours
The City had one (1) maintenance/warranty claim in 2023, which resulted in the replacement/repair of multiple connector heads, port cables, and cable retractors.

Item 6 –Alert and Warning Memorandum of Agreement between the County of San Diego and the City of Del Mar t and Warning Memorandum of Agreement between the County of San Diego and the City of Del Mar

1. Do the systems interface with TV alerts, or are they just notices for mobile devices? The MOA states in part: "WEAs are emergency notifications sent by authorized government alerting authorities, as determined by the Jurisdiction, through mobile carriers and broadcast to mobile phones receiving a signal from cell towers within or near the alert area." Later it states: " A highly effective Alert & Warning program will use as many delivery methods as appropriate and necessary. Alert & Warning is comprised of multiple modalities which may include: EAS (Emergency Alert System), NWEM (NonWeather Emergency Message), WEA (Wireless Emergency Alert), AlertSanDiego, San Diego County Emergency Website (AlertSD.org), and Social Media" but TV and cable are not mentioned?
1 October 2, 2023 Items 5,6,14,16
Response: The Alert and Warning MOA is in reference to systems that only push notices through mobile devices. For systems that interface with TV/cable messaging, the local jurisdiction is responsible for activating alert and warning systems through cable providers. For example, if the City of Del Mar declares an emergency and an evacuation order or warning is given, the Incident Commander in coordination with the Sheriff Department will call the cable providers emergency notification number, input the local jurisdictions pass code, and then provide the message that needs to be displayed. The message will then be displayed on the local programming for that jurisdiction. The County’s WEA and AlertSD systems do not provide cable messaging.

Item 14– Discussion of Regulatory Framework Examples and Policy Direction for Short Term Rental Regulation

1. It would be nice to know the per bedroom cost from our STR data so that price points could be compared to the per bedroom cost for hotels/motels. An average cost per STR per night of $630 to $625, but with a range of size from studios to multiple bedrooms, and occupancy from 1 to 10 or more, makes it really hard to know a per bedroom price or to compare to hotel/motel options. Do we, or the consultant, have that information? The agenda report and the CCC both indicate that STRs can be a "more affordable" option. I'm not sure that is true as to hotels/motels in Del Mar, and pretty sure it's not true if Del Mar STR prices are compared to hotel/motels prices per bedroom nearby but outside Del Mar. I know the 2016 data showed that Del Mar STRs were more expensive.

Response: The City does not have any information on the bedroom count of existing STRs. This type of data was not available for the STR advertisements that were reviewed January through June 2023. The City is encouraging existing STR owners to register their STRs by December 5, 2023, and the number of bedrooms is a field of information that STR owners are asked to voluntarily provide.

2. It would be helpful to have a clear definition of the difference between "hosted" and "non-hosted" and "owner occupied" and " nonowner occupied." Presumably, "hosted" means somebody long term is on site which could mean the property owner is on site during an STR rental, or it could include no owner on site at any time during the year, but a 30+day tenant on site as "host?" "Owner occupied" presumably means the actual property owner is on site some portion of the year, but not necessarily on site as "host" during STR rentals? For example, the owner might be living in the residence half the year and then STR renting with no host onsite the rest of the year? All this is a bit confusing and clarification to make sure we are all working from the same definitions would be helpful. It would also be important to know the CCC view on these categories and which they prefer. 2 October 2, 2023 Items 5,6,14,16
Response: This is a policy decision for the City Council. The City has flexibility to create its own definitions and regulations for the various STR ownership types. Owner occupied STRs are typically defined as “primary residence STRs” where owners occupy the property as their primary residence for a period of more than 6 months per calendar year and rent the home, or rooms within the home as an STR in a limited accessory use capacity. Non-owner occupied STRs are STRs where owners do not occupy or reside on the property as a residential use. The STR regulations in other jurisdictions are sometimes further differentiated to identify regulations that apply to homes that operate as “hosted” STRs where the owner or permanent resident is on-site as the STR host (i.e., home sharing) and distinguish these from the use of “non-hosted” STRs where the owner is not on-site during stays, including primary residences and non-owner occupied STRs, and apply a separate set of regulations to this use type. The Coastal Commission has approved regulatory approaches that include provisions for each of these variations and more restrictive approaches depending on the context of the jurisdiction. In Del Mar, the majority of existing STRs are non-hosted and non-owner occupied rentals.

Item 16– Approval of Conceptual Design for the 20th Street Lifeguard Tower Driveway Project

1. Will the new pavement include pervious surfaces?
Response: The new concrete driveway will be standard concrete colored to match the existing driveway to the south. Permeable concrete was considered but not selected because the sandy environment would clog up the voids and prevent the material’s permeability.
3 October 2, 2023 Items 5,6,14,16
1 Melinda Gould
From: Bill Lyon <[email protected]>
Sent: Wednesday, September 27, 2023 5:21 PM
To: City Clerk Mail Box; Tracy Martinez; Dan Quirk; David Druker; Terry Gaasterland; Dwight Worden; City Manager Mail Box; Leslie Devaney
Subject: STR Use Red Dot Comments
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Hello,
I hope whatever regulations for STRs you adopt on the October 3 meeting don't reduce the # of days or times of year that a house can be rented (at least for those homes that were being rented before AirBnb and VRBO came along and caused a bunch of problems). I suspect the majority of homes along the beach (Ocean Front) have been summer homes or rentals ever since they were built. Reducing the amount of time they can be rented would just reduce the number of people shopping/dining/etc. in town and would have no effect on the number of homes available for residents.

Thank you for your consideration.

Bill Lyon
1948 Ocean Front
1 October 2, 2023 Item 14
1 Melinda Gould
From: Brad Walters <[email protected]>
Sent: Friday, September 29, 2023 11:40 AM
To: City Clerk Mail Box
Subject: red dot on STRs (Item 14)
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear Council,
My personal preference on short-term rentals is that they be banned outright in all residential zones except for partialhome situations where the owner is also home.

The region desperately needs all available empty units for housing stock, and providing enough housing for our local workforce must come before tourism considerations. Those who would use their homes as STRs could instead lease them out to long-term renters and still realize a tidy profit if desired.

Knowing this scenario is unlikely, I simply ask that:
(a) there be an extremely robust enforcement mechanism to report loud disruptions, and (b) that we not "play favorites" and declare some areas exempt based on those who have the time and resources to file lawsuits; that any cap is instituted equitably city-wide.

While it's in the best financial interest of any STR operator to report that their folks are always considerate, I'm within close proximity of several STRs and am afraid that simply isn't the reality on the ground.

Respectfully,
Brad Walters
Stratford Ct.
1 October 2, 2023 Item 14
1 Melinda Gould
From: Kimberly Jackson <[email protected]>
Sent: Sunday, October 01, 2023 12:15 PM
To: City Clerk Mail Box; Tracy Martinez; Dan Quirk; David Druker; Terry Gaasterland; Dwight Worden; City Manager Mail Box; Leslie Devaney
Subject: Short Term Rental Proposed Rules & Regulations in Del Mar CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear Honorable Mayor and Council Members,
Please follow suit with the cities of: San Diego, Solana Beach, Encinitas, Carlsbad and Oceanside. Allow vacation rentals with reasonable regulation.

Most currently operating STVR owners support the following:
-Collection of TOT (one of the highest rates in California) -No one night stays
-24/7 local number posted for tenant issues/disturbances -Quiet hours of 9pm to 9am out of respect for the neighborhood -No cap on allowable number of nights to be rented per year -Allow STVRs in ADUs
-Abide by current City Trash Regulations
-Occupancy limits such as, 2 per bedroom plus 2 for the home, including visitors -A small permit fee of $150/year or less, and a simple registration process (not elaborate like The City of Encinitas/Oceanside)
-No parties or gatherings allowed EVER
At this point in time, WE DO NOT encourage Registration Participation. We DO NOT recommend the public register their homes on the city website at this time.

To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet.

Kimberly Jackson

FOUNDER
Vacation Rental Management
(503) 957-9354
[email protected]
www.vacationrentalsbykimberly.com
1 October 2, 2023 Item 14
1 Melinda Gould
From: City Clerk Mail Box
Subject: FW: Short Term Rental Proposed Rules & Regulations in Del Mar From: Cherie Harris <[email protected]>
Sent: Sunday, October 01, 2023 12:18 PM
To: Kimberly Jackson <[email protected]>
Cc: City Clerk Mail Box <[email protected]>; Tracy Martinez <[email protected]>; Dan Quirk <[email protected]>; David Druker <[email protected]>; Terry Gaasterland <[email protected]>; Dwight Worden <[email protected]>; City Manager Mail Box <[email protected]>; Leslie Devaney <[email protected]>
Subject: Re: Short Term Rental Proposed Rules & Regulations in Del Mar CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

I concur!!!
Cherie Harris
Del Mar Beach Homeowner
On Oct 1, 2023, at 12:14 PM, Kimberly Jackson <[email protected]> wrote:

Dear Honorable Mayor and Council Members,
Please follow suit with the cities of: San Diego, Solana Beach, Encinitas, Carlsbad and Oceanside. Allow vacation rentals with reasonable regulation.

FOUNDER
Vacation Rental Management
(503) 957-9354
[email protected]
www.vacationrentalsbykimberly.com
3 October 2, 2023 Item 14
1 Melinda Gould
From: Gina Corsini Mattern <[email protected]>
Sent: Monday, October 02, 2023 8:48 AM
To: City Clerk Mail Box; Tracy Martinez; Dan Quirk; David Druker; Terry Gaasterland; Dwight Worden; City Manager Mail Box; Leslie Devaney
Subject: Red Dot October 2nd meeting
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear Council Members:

I requested public records from Code Enforcement to see what "problem" Del Mar has regarding short term rentals. I requested all calls, emails, reports from 2016 to date. I was rather surprised to find out that the "hotline" which was urgently needed in 2016 along with the initial Moratorium was NO LONGER active. The City had received so few phone calls, it was deemed unnecessary.

The 98 records I received, validated this as well. Of the 98, 43 were made in 2021 by 1 person! The remaining were edited for duplicate and showed 42 individual complaints over the course of EIGHT years! The majority of records showed neighbors just wanting to know if the property was allowed under the forbearance period. So it's neighbors turning in neighbors (without an actual "noise, trash, parking, occupancy, etc. complaint). Del Mar DOES NOT have a STR problem. Your "rules/restrictions" should reflect this data.

I am in support of the following rules:
• Least restrictive RULES to encourage all to participate in registration/permit process • Accommodate ALL existing STRs
• Allow Permits to ALL who register
• No Limits on Days per year / NO SUNSET Clause
• Reasonable Permit Fees for owners and property managers • 24 Hour Contact Number / Permit Window Signage
• Good Neighbor Policies
• Quiet Hours (10 PM – 7 AM)
--
4 October 2, 2023 Item 14
2 5 October 2, 2023 Item 14
1 Melinda Gould
From: Gerard Pascale <[email protected]>
Sent: Monday, October 02, 2023 10:34 AM
To: City Clerk Mail Box; Tracy Martinez; Dan Quirk; David Druker; Terry Gaasterland; Dwight Worden; City Manager Mail Box; Leslie Devaney
Subject: RED DOT October 2nd meeting
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear City Council,
Respectfully submitted is the following analysis of one of the data points presented at a recent City Council Meeting. The data presented, AVERAGE NIGHTLY RENT OF $630 PER NIGHT, by the City’s paid consultant, IS an incorrect metric. I will “assume” the consultant was asked to generate this metric without an understanding of its implications as use of AVERAGE in the context of how it may be used (potential TOT tax) is flawed. A basic understanding of symmetric vs asymmetric distribution theory indicates the use of an arithmetic average in an asymmetric distribution is incorrect.

Del Mar STR Average Nightly Rent:
“Garbage in Garbage Out”
Del Mar recently presented consultant generated data calculating the Average Nightly Rent to be $630 per night with rents ranging from a low of $25 per night to a high of $4,000 per night.

Several $4,000 per night rents, which are present in the Ocean Front portion of Del, in a small data size of 116 data points will yield a heavily skewed data set where the Average Nightly Rent will be greater than the Median Nightly Rent.

When data is skewed in one direction or another the use of Median Nightly Rent is preferred. The Median of the data set will generate a “typical” rent and a more accurate measure of what guests are paying per night.

Why is this important? If a TOT tax is part of an eventual resolution, one of the data points in the tax model will be the nightly rent number. It is important to use the rent that will be most representative of a “typical” rent. If the data is right skewed where the Average Nightly Rent is higher than the Median Nightly Rent the tax model will over estimate income generated by the tax thus failing to meet budget estimates.
1 October 2, 2023 Item 14
2 THE FOLLOWING IS AN EXAMPLE OF A SKEWED DISTRIBUTION.

NOT HAVING ACCESS TO CITY DATA THE DATA POINTS ARE

ESTIMATED IN THIS STUDY AND THE SAMPLE SIZE IS SMALLER, SOLELY FOR PURPOSES OF THIS STUDY. EVERY EFFORT WAS UNDERTAKEN

TO CREATE A DISTRIBUTION MODEL CLOSE TO WHAT THE ACTUAL DATA WOULD PRESENT. IT IS THE CONCLUSION THAT USING THE

INCORRECT METRIC IN ANY FUTURE PROPOSED MODEL WILL
YIELD AN INCORRECT RESULT. THAT IS WHAT COUNCIL SHOULD FOCUS ON.

Rent/Night Units/Category Rent/Category Average/Night Median $50 1 $50
$300 10 3,000
$400 20 8,000
$500 10 5,000
$600 5 3,000
$4,000 4 16,000
50 $35,050 $701 Average/Night $400
Average Nightly Rent: $701 (vs. Consultant’s $630)
Median Nightly Rent: $400
2 October 2, 2023 Item 14
3 Potential Tax Model Arithmetic:
7,000 (*) visits X 3.7 days per visit X $400 per night X 7% Tax = $725,200 TOT Revenue
7,000 visits X 3.7 days per visit X $630 per night X 7% = $1,142,190 TOT Revenue
$417,000 +/- Unfavorable Variance
Conclusion: using an incorrect metric in a potential tax model will create a potential significant variance
between estimated tax to be collected (budget) and actual tax revenue! (*) Source: Del Mar Consultant presented data (in bold): 116 STRs (X) 365 days per year (X) 62% Occupancy / 3.7 Days per stay = 7,094 (7,000 +/-)
Respectfully,
Gerard Pascale
3 October 2, 2023 Item 14
1 Melinda Gould
From: deftos <[email protected]>
Sent: Monday, October 02, 2023 10:41 AM
To: City Clerk Mail Box
Subject: Red dot item 14 STR
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Del Mar City Council,
City staff's work in reviewing STR orinances from other cities and prior Coastal Commission decisions is very helpful and much appreciated. City staff’s recommendations for the “Issue Categories” are wellconsidered and will help achieve the City Council’s stated “guiding principles.” Non-owner occupied STRs are detrimental to the City and its residents and new STRs should be restricted to owner-occupied properties (for all residential zones) with a cap set at no more than 5% Citywide. With a requirement for annual permit renewal and non-transferability of permits, the number of “grandfathered” non-owner occupied STRs should decline over time through attrition as properties eventually change hands.

Regarding the recommendation to limit the total number of STRs on a Citywide basis (rather than by zone or neighborhood), the current distribution of STRs in different neighborhoods (60/25/15%) seems reasonable, reflects market forces, beach access, and possibly parallels historical practices when the Community Plan was adopted.

Regarding the recommendation to “accommodate existing STRs above the cap as needed,” this seems fair and might facilitate environmental review (and ward against CEQA lawsuits sometimes motivated by selfinterest rather than a true concern for the environment) since there would not be a change from current conditions.

Thanks,
Michael Deftos
4 October 2, 2023 Item 14
1 Melinda Gould
From: Danielle Nicholas <[email protected]> Sent: Monday, October 02, 2023 10:45 AM
To: City Clerk Mail Box; Tracy Martinez; Dan Quirk; David Druker; Terry Gaasterland; Dwight Worden; City Manager Mail Box; Leslie Devaney
Subject: RED DOT Oct 2nd meeting
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear Council Members:

I respectfully submit the following proposed regulations to govern Short Term Rentals:
• Least restrictive RULES to encourage all to participate in registration/permit process • Accommodate ALL existing STRs
• Allow Permits to ALL who register
• No Limits on Days per year / NO SUNSET Clause
• Reasonable Permit Fees for owners and property managers • Good Neighbor Policies
• Quiet Hours (10 PM – 7 AM)
Thank you. Sincerely, Danielle Nicholas
5 October 2, 2023 Item 14
1 Melinda Gould
From: JoyDelMar <[email protected]>
Sent: Monday, October 02, 2023 11:06 AM
To: City Clerk Mail Box
Subject: Red Dot-Oct 2nd City Council- item # 15
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear Del Mar City Council,
I would once again like to add my name to the long list of Del Mar residents who are hoping that you will limit the number of Short Term Rentals in the City as much as possible.

I think we can all agree that, if given the choice, most people in Del Mar would not want to live next door to a short term rental.

Also, since the City is in the process of compiling a list of short term rentals, with the intention of issuing permits, I am requesting that you make this list public before permits are issued.

Sincerely,
Joy Shadle Ehrenfeld
220-10th St
Sent from my iPhone
6 October 2, 2023 Item 14
STRs in Del Mar
City Council Meeting, October 2, 2023
Gina C. Mattern
1 October 2, 2023 Item 14
- CITY COUNCIL GIVING LIP

SERVICE TO COMMUNITY
- COUNCIL’S DECISIONS

PREDETERMINED & NOT

ALIGNED WITH CCC (EXPOSE)
- STRs ARE NOT A PROBLEM (PROOF)
- SUGGESTED STR FRAMEWORK
2 October 2, 2023 Item 14
COUNCIL’S ARROGANCE
“…we’ll create whatever we
want. That’s kinda what we did
the last time.”
Councilman Druker,
City Council meeting September 5, 2023
3 October 2, 2023 Item 14
COUNCIL’S WORDS GO AGAINST LEGAL

GUIDEANCE
4 October 2, 2023 Item 14

COUNCIL ARGUES PERMISSIVE ZONING IN
COURT
Del Mar Alliance for the Preservation of Beach Access and Village vs City of Del Mar The City argues that the Resolution is a mere restatement of the law because STRs were already prohibited under the Zoning Code. The City argues it has a permissive zoning code which does not expressly allow STRs. A permissive zoning code is one in which a particular use of land is not allowed unless it is expressly designated in the zoning code as a permissible use. STRs are neither listed nor expressly prohibited in the Zoning Code.

The Honorable Katherine Bacal (December 24,2019)
The City of Del Mar v The California Coastal Commission In its challenges to the Commission's decision in this case, the City repeatedly claimed that STRs are prohibited in the City's residential zones and that it has a "permissive" zoning code without mentioning that a challenge to both those contentions was pending.

The Honorable Joel R. Wohlfeil (February 6, 2020)
5 October 2, 2023 Item 14

CITY WEBSITE STATES NO STRS IN RESIDENTAL
ZONES
Currently, short term rental operations are only permitted in the Residential-Commercial (RC) zone and the Visitor Commercial (VC) zone and where otherwise provided for
by development entitlement (i.e. Wave Crest Time
Shares, Hotel Specific Plan, and the 941 Camino del Mar Specific Plan). STRs are not permitted in residential
zones.
(Del Mar City website Sept 30, 2023)
6 October 2, 2023 Item 14

MORE OPPORTUNITY IN COMMERCIAL ZONES
Del Mar Times September 8, 2023
“The intent is to protect the residential character of
neighborhoods in residential zones by creating new
opportunities for STRs in commercial zones and
maintaining the majority of dwelling units in residential zones for long-term housing,” the (City Staff) report said.
7 October 2, 2023 Item 14

CCC WILL NOT APPROVE MORE RESTRICTIVE

REGULATIONS
Wendy House Report to City Council September 5, 2023
“The CCC typically will not approve more restrictive
regulations if a jurisdiction does not provide
sufficient data, analysis and/or justification to show
why the regulations are necessary.”
8 October 2, 2023 Item 14

HEAVY RESTRICTIONS DESIRED BY COUNCIL
Del Mar Times, September 12, 2023
“You can change community character”, MARTINEZ said, “It can can be imposing on your lifestyle and in your own home. So pretty clear and STRICT regulations are going to be important.” 9 October 2, 2023 Item 14
“GUIDING PRINCIPALS” MAKE NO
ACCOMMODATIONS FOR STRs
• COUNCIL GUIDING PRINCIPLES & OBJECTIVES FOR NEW STR REGULATIONS • Honor the existing policies in the Del Mar Community Plan. • Maintain the residential character of neighborhoods in residential zones. • Honor the tradition of vacation rentals during the summers, holidays, and services. • Ensure the protection of the public health, safety, and general welfare. • Ensure the City’s natural resources will be preserved and protected. • Ensure STRs will not overburden public improvements, facilities, and services. • Minimize adverse impacts to adjacent private properties and the surrounding neighborhood. • Consider distribution and concentration of STRs throughout the community. • Craft regulations that are easy to understand and implement. • Communicate expectations for civil conduct in line with “good neighbor” policies. • Establish enforcement protocols, and ensure regulation of short-term rentals is, at a minimum, revenue neutral to the City.
• Work towards a solution for STRs that works for Del Mar and will pass muster with the Coastal Commission. 10 October 2, 2023 Item 14
COUNCIL MISREPRESNTS NUMBER OF STRs
CITY ARGUED THERE WERE 300-400 STRS IN 2018
CASE TITLE: Del Mar Alliance for the Preservation of Beach Access and Village vs City of Del Mar

JANUARY – APRIL 2023
PAID STUDY RESULTS –
116 STRS
11 October 2, 2023 Item 14

I BELIEVE THE ABOVE SLIDES PROVE COUNCIL IS

GIVING LIP SERVICE TO THIS ISSUE AND THEIR
CONCLUSIONS ARE AND HAVE BEEN PREDETERMINED FOR A VERY LONG TIME! 12 October 2, 2023 Item 14

PUBLIC RECORDS REQUEST
So, is there an STR problem?
Request for Public Records #23-239 September 25, 2023
for Calls/Emails to STR Hotline or Code Enforcement
regarding STRs 2016-2023
13 October 2, 2023 Item 14

THE COMPLAINT DATA RESULTS
•
• 98 Records Returned (2016 – Present)
• 2016-2023 – 42 general complaints
• 2017 – 1 person complaining about 5 properties
• 2019 – 1 person complaining about 4 properties
• 2019 – 1 person complaining about 4 properties
• 2021 – 1 person complaining about 43 properties
Currently STR HotLine shut down due to INACTIVITY
•
14 October 2, 2023 Item 14

GENERAL COMPLAINT BREAKDOWN
• 2016-2023 Complaint breakdown: (42 in 8 yrs)
• 9 – Noise
• 1 – Parking
• 1 – Trash (found not to be and STR)
• 1 – Dog Barking
• 1 – Leaf Blower
• 6 – No specific complaint
• 23 – Forbearance status queries
15 October 2, 2023 Item 14
BREAKDOWN OF THE 43 IN ONE DAY

COMPLAINTS
• 7 Qualified STR
• 2 Not Qualified
• 2 Noted as unfounded
• 32 Noted as CLOSED only
16 October 2, 2023 Item 14
% OF COMPLAINTS TO KNOWN STRS DATA
(CITY CONSULTANT’S DATA EXTRAPOLATED)
• 116 KNOWN STRS
• 62% OCCUPANCY
• 3.7 DAYS PER STAY
• = 7,000 (+/-) STAYS PER YEAR
• =50,000 (+/-) STAYS FROM 2016-2023
• COMPLAINTS / VISIT (2016-2023) (DRUMROLL, PLEASE!)
• 1/10TH of 1 percent
THERE IS NO STR PROBLEM!!
17 October 2, 2023 Item 14
How Many Complaints = Problem??
18 October 2, 2023 Item 14

STR FRAMEWORK
• Least restrictive RULES to encourage all to participate in registration/permit process
• Good Neighbor Policies
• Quiet Hours (10 PM – 7 AM)
• Accommodate ALL existing STRs
• Allow Permits to All who register
• No limit on Days per year
• Reasonable Permit Fees for owners and property managers • 24 Hour Contact Number / Window Permit Signage
• 2 Year Collection Data to be evaluated against Registered Complaints (reevaluation at that time if necessary)
19 October 2, 2023 Item 14
1 Melinda Gould
From: Debbie Church <[email protected]>
Sent: Monday, October 02, 2023 12:12 PM
To: City Clerk Mail Box; Terry Gaasterland; David Druker; Dan Quirk; Dwight Worden; Tracy Martinez
Subject: Red dot item 14
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear Mayor Martinez and Council members,
First, some background on me. I am a Del Mar resident who has owned and operated my family’s second home as a vacation rental for the last 40 years as well as my having rented my personal primary residence as a vacation rental.

Unfortunately I am out of town for this meeting since the date was delayed so I am writing a letter to express to you some of my views on some of the issue categories listed.

Issue Category 1 & 4:

I do agree that there should be a difference between a primary residence and a secondary residence/full-time STR.

Primary Residence - we should allow an unlimited number of permits (no cap) for anyone who wishes to rent their primary residence for at most 90 days per year. Anyone who wishes to rent for more than 90 days should apply for the Full-Time permit instead.

This does not reduce our housing stock since it is still a primary residence.

My views on this are shaped by the fact that I used to move out every summer and rent out my home so that I could afford a home in Del Mar.

Historically, this is how many teachers, professors and families of more modest means were able to settle in Del Mar. Believe me, this is not for everyone. It is a real pain to prepare your home for this type of rental and have the majority of your personal belongings left behind. You have to really need the income to want to do this since there is a huge hassle factor. And I think we should continue this legacy to encourage younger families to join our community without limit.

Additionally, this retains property rights for any homeowner. Sometimes people hit a financial hardship (think of Covid, health emergency, etc.) and this allows a homeowner a way to make ends meet during a hardship. An unexpected hardship could happen to anyone so please maintain these rights to all. When a hardship hits, a permit would be available.

Secondary Residence or Full-Time Vacation Rental - I believe these should be grouped into the same category and be allowed for the full 365 days/year. This is the group of rentals that you can settle on a cap for after making sure all existing ones are accommodated.

Again, my views are based upon my experiences. I maintain my family’s second home two blocks from me. We would like to keep this home in the family and renting it out short term is the only way we can still use the home ourselves while making just enough to break even on the home.

I look forward to the continued discussions on these regulations.

Debbie Church
27th St.
1 October 2, 2023 Item 14
1 Melinda Gould
From: [email protected]
Sent: Monday, October 02, 2023 11:35 AM
To: City Clerk Mail Box; Tracy Martinez; Dan Quirk; David Druker; [email protected]; Dwight Worden; City Manager Mail Box; [email protected] Subject: Del Mar Short Term Rental Public Input
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Ladies and Gentlemen,
I am submitting my comments to the Red Dot Committee as I am not able to attend the meeting scheduled for October 2, 2023.

My husband and I have owned our home in Del Mar since 1991, We have always viewed our home as both a great place for us to vacation, but also as a source of income. Over the past 30+ years, for the most part, our rentals have been short term, especially in the summer season. As we are now retired, the income from our property is even more important. We are not opposed to reasonable ordinances, but not permitting STRs or not permitting them except during the summer, holidays and racing season is, in our view, an unacceptable taking of our property.

There are many reasons for people to utilize short term rentals, not just vacations as some have said. We have had tenants over the years that are being treated at Scripps and need a place to stay near the hospital for short term. We have had people who need to have their homes fumigated rent our house on a short term basis.

Because we allow pets, we have had tenants who have had no other choice but to rent homes that allow pets. These are not limited to summers or holidays. Most of our rentals are for long weekends--3 days/nights. We have a reputable agent who manages many of the STRs in Del Mar and we are very strict about rules to limit the number of people in the home (it is a 3 bedroom home and we limit the number of guests to 6). We also installed outside cameras to make sure that there are no extra guests than what we allow. We limit noise after 9 p.m. (even though there are no such limits on residents). We do not allow guests to have large gatherings--we've seen and heard much larger parties at properties that are not rented out.

Del Mar does not have an abundance of hotel rooms available, and those that do exist are not affordable for many families (especially those that need more than one room). Not allowing or limiting short term rentals will deprive many who cannot afford expensive hotel rooms and drive that business to other beach communities that are not so restrictive. This is not a benefit to Del Mar who will lose those tourist dollars. Moreover, those that work in service businesses here in Del Mar will lose income that has already been greatly harmed by the pandemic and its aftermath. Now is not the time to seek ways to harm these businesses or their employees.

Finally, as we have owned and operated our property for the past 30+ years, we have been grandfathered in with respect to rentals (with no limitations). If the City decides to move forward with restrictions on STRs, we request that our property be grandfathered in under the existing rules. Depriving us of our property rights is not the way to proceed without an expectation that we will fight it.

Respectfully submitted,
Mary Alden and Kurt Osenbaugh
1 October 2, 2023 Item 14
1 Melinda Gould
From: Nina Detrow <[email protected]>
Sent: Monday, October 02, 2023 2:21 PM
To: City Clerk Mail Box; Tracy Martinez; Dan Quirk; David Druker; Terry Gaasterland; Dwight Worden; City Manager Mail Box; Leslie Devaney
Subject: Del Mar Vacation Rentals
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear Honorable City Council Mayor & Members,
I fully support the Short Term Vacation Rental industry here in Del Mar. This is the fabric of our community and many homeowners have relied on this income for generations. We offer so much here in Del Mar: beautiful beaches, the race track and all activities offered onsite around the calendar year, great food, shopping, etc. How will we accommodate all of these visitors if we shut these homes down? The money they spend in town will go to another town. Please don't let that happen. Follow Solana Beach, Carlsbad, Encinitas, Oceanside, and numerous other coastal towns across the county and please embrace this thriving economy to continue to exist.

Thank you!
Nina Detrow
Surf Vacation Rentals
858-945-5609
[email protected]
DRE#01968523
www.surfvacationrentals.com
Surf Vacation Rentals
P. O Box 2269
Del Mar CA 92014
Trinity Real Estate Services
Cell (858) 945-5609
Member San Diego Regional Chamber of Commerce
Member Solana Beach Chamber of Commerce
My Business thrives on your referrals!
1 October 2, 2023 Item 14
1 Melinda Gould
From: City Clerk Mail Box
Subject: FW: Del Mar's STR History and Current Ban is Illegal and Destroys Public Visitor-Serving Beach Access
Attachments: Del Mar’s 7-Year STR Moratorium is Illegal, Damaging and Costly 10.2.2023.pdf From: Laura DeMarco <[email protected]>
Sent: Monday, October 02, 2023 10:20 PM
To: Tracy Martinez <[email protected]>; David Druker <[email protected]>; Dwight Worden <[email protected]>; Terry Gaasterland <[email protected]>; Dan Quirk <[email protected]> Cc: Ashley Jones <[email protected]>; Amanda Lee <[email protected]>; Karl Schwing <[email protected]>; Jack Ainsworth <[email protected]>; City Clerk Mail Box <[email protected]>
Subject: Re: Del Mar's STR History and Current Ban is Illegal and Destroys Public Visitor-Serving Beach Access CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Please refer to attached PDF of PowerPoint presentation previously sent to you as it's formatting is easier to read, especially on mobile devices.

On Monday, October 2, 2023 at 05:23:12 PM PDT, Laura DeMarco <[email protected]> wrote:

Dear City Council Members and Staff,
Please find attached a presentation outlining Del Mar's long history of STRs and legal review that is separate and distinct from any other coastal city in California.

Del Mar's historic STRs enabled generations of families to access and enjoy our beaches which are the safest and best in the region. These vacation rentals sustain the economic vitality of many longterm Del Mar residents and our village's shops and restaurants who struggle to make it through the off-season. STRs are also the critical gateway that brought my family, the Sullivans, Stokes, McDermotts, Sharps, Charnholms and so many others to permanently settle in and contribute to our community.

Fortunately, the San Diego Superior Court as well as the California appellate court recognize that Del Mar's attempted STR ban violates the Coastal Act, CEQA, and/or due process rights. As Judge Katherine Bacal previously ruled, Del Mar's new 2017 zoning code "interpretation" is "invalid" and Ordinance 934 STR ban is "legally unenforceable."
However, In defiance of Judge Bacal's order and without Coastal Commission approval, Del Mar continues its STR ban through an effective 7-year moratorium so that now only approximately 100 STRs are left vs. 300-400 in 2016. As a result, over 66% of Del Mar's historic STRs with over 600 rooms have been lost to thousands of vacationing families who can no longer walk to our beach and our village.
1 October 2, 2023 Item 14
2 This illegal ban is not remedied by Del Mar's proposed "registry" that omits new owners of 200-300 historic STR properties.

Sincerely,
Laura DeMarco
2 October 2, 2023 Item 14
z
Del Mar’s 7-Year STR
Moratorium/Forbearance:

Cuts 2/3 of STRs with
Del Mar Beach Access
Violates Court Order, CEQA & Coastal Act
3 October 2, 2023 Item 14
Del Mar’s Long STR History
➢ 1930-1970s: STR boom with only ~100 hotel rooms
available after Hotel Del Mar closed in 1963
➢ 1970s: Community Plan Taskforce rejects
discouraging “transient occupancy” (daily and weekly)
and Community Plan notes “comparatively large
percentage” of STRs in North Beach zone
➢ 1981: City Attorney memo to Planning Commission
and City Council states STR is “residential use”
➢ 2010: Prop J Ballot initiative states STRs are “fabric” of community” (voters reject STR TOT tax)
➢ 2016-present: Temporary ban on new STRS through
“Urgency” ordinance (extended with “forbearance”)
➢ 2017: New council majority makes new zoning code
“interpretation” that STRs not allowed and passes
Ordinance 934 banning STRs in residential zones
➢ 2017-20: Court rules new 2017 zoning code
interpretation is “invalid” and Ordinance 934 STR ban
is “legally unenforceable”
➢ 2018-20: Coastal Commission rejects Del Mar’s 28/7
STR ban prompting City lawsuit dismissed by judge
➢ 2023: City ignores court order and continues STR
ban so only ~100 STRs left vs. 300-400 in 2016
70 Del Mar STRS listed on VRBO
Source: VRBO as of 1/23/2023
Hotel Del Mar
4 October 2, 2023 Item 14
Del Mar voters & CCC approved STRs as
allowed use in 1976 Community Plan
“North Beach District: A comparatively large percentage of transient housing is available in this planning area.”
Del Mar Community Plan, p. 56
STRs occupied by college students in off-season:
✓ 20-70% in North Beach (3 zones)
✓ 10-20% in South Bluff and Beach (3 zones)
✓ 1-5% in North Hill and Village (3 zones)
Source: Del Mar Community Plan Demographics, p. 13
Del Mar was North County’s “Mission Beach” in 1976 until later gentrified by city’s noise restrictions and landlord preferences for vacationing families
Mission Beach STR cap is 30% in Coastal Commission’s
approved LCP Amendment for City of San Diego in 2022
5 October 2, 2023 Item 14
z City of Del Mar’s Illegal STR Ban Plan
In 2016 Council Member Dwight Worden and Mayor Sheryl Parks blocked Council majority from adopting STR regulations until they got new council who would follow their STR "ban plan” in blatant disregard of Del Mar’s Community Plan, CEQA, Coastal Act, Coastal Commission, due process, testimony, and petitions from 500+ Del Mar citizens My first choice is to ban short term rentals of less than 28 days. But, I prefer not to call it a "ban" as it sounds like something new is being imposed and that's a trigger for the Coastal Commission. Rather, we can confirm by interpretation that our existing rules do not allow, and never have allowed, STR less than 28 nights in residential zones. This effectively achieves the objective without any new rules that the CC (Coastal Commission) might argue with." 5/5/2016 Council Member Dwight Worden email to Mayor Sheryl Parks "I think we should slow this down. We might get 3 votes in November…Stalling. I can try to manage to get it off the agenda (as mayor she controlled agenda) but staffs (sic) really pushing for a decision by the last meeting in November because the emergency ordinance is expiring then....We'd simply need to reintroduce it to rollover." 6/14/2016 Mayor Sheryl Parks to Council Member Dwight Worden Source: City of Del Mar PRA
6 October 2, 2023 Item 14
➢ 6/1/2017: Alliance lawsuit filed vs. STR ban
➢ 12/20/2019: Trial
➢ 12/24/2020: Judge Bacal issues court order
that Resolution 2017-29 is “invalid and
legally unenforceable”
➢ 2/24/2020: Court ruling stands as city’s
60-day appeal period expires
➢ 3/19/2020 COVID stay-at-home order
➢ In defiance of court order and without
required CCC-approved LCP STR
amendment, Del Mar code enforcement
continues STR ban so ~300 STRs (2/3) lost
from 2016-2023 with ownership changes
➢ 1/18/2023: Lawsuit challenges 2 STR
citations as being illegal and unenforceable
➢ 1/23/2023: City Council passes STR
Forbearance Resolution that is erroneous,
defies court order, and invites costly and
wasteful legal battles City has never won
➢ 2/2024: Judge Bacal to rule on 2 lawsuits vs.

Del Mar STR ban in defiance of her court
order
Court Invalidates STR Ban
7 October 2, 2023 Item 14
Judge Bacal’s findings and ruling
against Del Mar’s STR ban (2020)
8 October 2, 2023 Item 14
z
City of Del Mar Loses STR Lawsuit vs.
the Coastal Commission (2020)
Excerpt of CA Deputy Attorney General court brief:
➢ Del Mar must set aside its 2017 Ordinance due to CEQA and the court’s rejection of Del Mar's "permissive code" arguments that STRs were never permitted ➢ Del Mar must start all over again from the beginning with a new Ordinance that will be factually and legally significantly different than what has been done thus far In its challenges to the Commission's decision in this case, the City never disclosed Judge Bacal’s prior ruling that basis of Del Mar’s STR ban is illegal and unenforceable A brand new LCP Amendment must be submitted to the Commission in a new restart review based upon the new facts and not the City's false claims Source: The City of Del Mar v. The California Coastal Commission Case# 37-2018- 00039254-CU-WM-CTL
9 October 2, 2023 Item 14
z California Appellate Court Rulings:

STR Bans are Illegal in Coastal Zone
Keen v. City of Manhattan Beach
(2022)
➢ Court notes City’s residential zoning code
does not distinguish between short- and
long-term rentals
➢ City’s permissive zoning code does not
disallow STRs
➢ As residential use, STR allowed
➢ City’s new interpretation of zoning code
cannot be used to disallow STRs nor avoid
Coastal Commission jurisdiction
➢ Any change to City’s code regarding STRs
requires Coastal Commission approval
Kracke v. City of Santa Barbara
(2021)
➢ City contends STRs not expressly in
its LCP so are excluded, which gives
City right to ban STRs without regard
to Coastal Act
➢ The City can’t act unilaterally,
especially when it allowed STRs for
years
➢ Court rules STR regulation/ban in
Coastal Zone is a development
impacting public access that must be
approved by Coastal Commission
10 October 2, 2023 Item 14
zDel Mar’s Damaging STR Moratorium:
2/3 of STRs Lost = 600 STR Rooms Lost
Hotel Rates Jump 50%
July
2016
July
2022 Difference
Hotel ADR/room $339 $510 +$171 +50.4%
STR ADR/room $110 $160 +$50 +33.3%
# Hotels/rooms 6/355 6/358 3 rms +0.8%
# STRS/rooms 300/900 100/300 -600 rms -66.7%
July TOT hotel $368 K $507 K +$139 K +37.8%
FY TOT hotel $2.62 M $3.42 M +$800 K +30.5%
Source: City of Del Mar; vacation rental websites; Coastal Commission June 7, 2018 STR LCP staff report
11 October 2, 2023 Item 14
Del Mar
Hotels
# of
Rooms
July 2023
weekend
2-nights
July 2023
weekend
daily rate
L’Auberge
(1989)
120 $2,835-$11,835
(3-night min)
$945-$3,945
Del Mar Beach
Hotel (1968)
46 $998-$1,138 $499-$569
Hotel Indigo 94 $625-$1,018 $312-$509
Best Western 80 $357-$720
(2nd weekend)
$178-$360
Les Artistes Inn 12 sold out N/A
Secret Garden 4 sold out N/A
Total 356 3 of 6 sold out N/A
Source: Bookings.com for 1st weekend in July; already sold out for 3 hotels: Best Western is 2nd weekend; LA/SG July sold out Del Mar Hotel Pricing as of 1/23/2023 Del Mar Hotel Map 12 October 2, 2023 Item 14
1 Melinda Gould
From: annette wiesel <[email protected]>
Sent: Sunday, October 01, 2023 1:06 PM
To: City Clerk Mail Box
Subject: Fw: RED DOT : Agenda item 15. October 2, 2023 City Council meeting CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Respectable City Council Members,
Item : 15
North Commercial Zone Short Term Rentals
Should STRs be allowed in NC for multifamily and by right development? NO !
Short Term Rentals should not be allowed on future development in the city of Del Mar.

Short Term rentals oppose the purpose and goals of Del Mar's housing element and goals of the California Department of Housing and Community Development (HCD) What is the state of California housing goal?
"California must plan for more than 2.5 million homes over the next eight-year cycle, and no less than one million of those homes must meet the needs of lower-income households." Short term rentals encourage investment property purchasing thus driving up housing costs by lowering number of available housing units.

Please Consider to prohibit Short Term Rentals (STRs) in any “by-right” development project in the NC Zone as part of implementation of the special project currently in process to establish new citywide STR regulations and implement Housing Element Program 5C.

Thank you for your consideration,
Annette Wiesel
2139 Heather Lane
Del Mar
1 October 2, 2023 Item 15
1 Melinda Gould
From: JOHN SPELICH <[email protected]>
Sent: Sunday, October 01, 2023 3:38 PM
To: City Clerk Mail Box
Subject: Oct 2, 2023 Council item 15 Red Dot letter
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear Mayor Martinez and fellow City Council members:

Regarding Agenda Item 15, I oppose allowing short term rentals in the North Commercial zone.

North commercial was up-zoned to create conditions for actual housing. Allowing short-term rentals does not accomplish that objective and as such it must not be allowed.

It’s time that we stand up once and for all and say that when laws are meant to create more affordable housing, which we desperately need, we should cease larding them up with alternative uses and insist they create real housing.

It’s time to stop the nonsense and focus on accomplishing the objective.

Sincerely,
John W Spelich
2143 David Way
Del Mar, CA 92014
2 October 2, 2023 Item 15
1 Melinda Gould
From: Angelina Neglia <[email protected]>
Sent: Monday, October 02, 2023 8:56 AM
To: City Clerk Mail Box
Subject: Red Dot Response - Item 15 for tonight's City Council Meeting CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear City Council Members,
Regarding STR’s in NC Zone:

1. I am against this idea of allowing STR’s in this area of town, and even expanding STR’s in Del Mar. We already have many STR’s in town, and the city is struggling with recording STR’s, recording income for tax purposes, and finding “underground STR’s."

2. The NC Zone is already congested with traffic, as Camino Del Mar is the only way into this area of town. The last thing we need is STR’s in an apartment building.

3. The City of Del Mar is struggling with finding, and building Low/Moderate Income Housing, as the State is Mandating this. So why expand STR’s when we HAVE to provide low/moderate income housing? We only have so much available land and as you all know we have a shortage of low/moderate income housing available.

Thank you for your consideration and including my Red Dot letter.

Kind Regards,
Angelina and Ross Neglia
(Del Mar Residents)
Angelina Neglia
Neglia Collaboration
Healthcare/Educational Advocate
[email protected]
(858) 945 8827
3 October 2, 2023 Item 15
1 Melinda Gould
From: Arnold Wiesel <[email protected]>
Sent: Monday, October 02, 2023 10:45 AM
To: City Clerk Mail Box
Subject: Fw: RED DOT LETTER Agenda item #15 - 10/2/23 City Council Meeting...

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

RE: Red Dot Letter - City Council Meeting 10/2/23 - Agenda item #15
Good afternoon City Council Members,
Land Use / Development in the North Commercial Zone should and needs to prohibit:

Condominium Conversions of market rate units developed pursuant to 'by-right' development in the NC Zone
AND prohibit Short Term Rentals (STRs) in any 'by-right' development project in the NC Zone.

The State of California has already imposed huge (almost unattainable) requirements for additional housing, including lowerincome/affordable housing, within Del Mar.

By allowing STR's and Condo Conversions in this area, real estate developers, land owners and investors will be encouraged to convert residences to Condominiums and STR's. Consequently reducing available and potentially available permanent residential housing and affordable housing!
These consequential negative impacts are easily foreseeable by any reasonable person, and will be easily determined by the 1 October 2, 2023 Item 15
2 State of California as a blatant disregard and disingenuous attempt to meet state requirements for housing and affordable housing within Del Mar.

Again, if STR's and Condo Conversions are allowed in the North Commercial Zone, while understanding there is little else land left to build upon, would be a very transparent attempt by the City of Del Mar to defy/deny the ultimate success of our Housing Elements already approved and will lead to litigation as between our City and the State of California.

Therefore, our City Council should and needs to prohibit Land Use / Development in the North Commercial Zone as to Condominium Conversions and STRs of market rate units developed pursuant to 'by right' development.

Otherwise, if our City does not prohibit Condo Conversions and STRs in the NC, our City will be guilty of intentionally and/or negligently
reducing our ability to meet and satisfy State law (HCD) requirements for housing in Del Mar. NOTE, regardless of whether our City believes they are intentionally and/or negligently escalating a reduction of housing and affordable housing shortages is ultimately the same in this case. The negative impacts to our obligation under law to provide increased housing and affordable housing quotas are obvious and herein forewarned.

In summary, STR's and Condo Conversions will obviously
undermine and ultimately defeat our City's ability to meet state law housing (HCD) requirements.

Allowing STR's and Condo Conversions will eliminate our potential to provide requisite state mandated quotas and opportunities for available housing and affordable housing. 2 October 2, 2023 Item 15
3 AGAIN, please note, STRs and Condo Conversions will defeat the purpose of having 'by-right' developments which are intended to provide housing and affordable housing.

Our Community does not want to violate our approved Housing Cycle(s) nor get entangled in a legal fight against the State of California.

Our Community does not want our City to undermine and ultimately defeat our city's ability to meed state law housing (HCD) requirements.

Lastly, this NC Zone is a separate isolated 'UP-ZONED' area which has received very focused and detailed attention different from other areas within Del Mar. Accordingly, this issue need be dealt with separately and specifically now!
Respectfully,
Del Mar Hillside Community Association
Arnold Wiesel
2139 Heather Ln.

Del Mar, Ca 92014
3 October 2, 2023 Item 15

Del Mar City CouncilOctober 2, 2023

Del Mar City Council
October 2, 2023