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Environmental Analysis

Voter-sponsored initiatives are not required to comply with the California Environmental Quality Act; however, a comprehensive (more than 4,000 pages) Environmental Analysis has been voluntarily prepared by the proponent, which provides information about potential environmental impacts of the plan and a commitment to “Environmental Protection Features.”

Because these features are a component of the initiative, the proponent would be bound to these Environmental Protection Features during development and operation of the plan. 

Overall Findings

  • Staff evaluated the information contained in the Environmental Analysis and concurs that the analysis and proposed Environmental Protection Features are in substantial conformance with the typical city policies and practices for addressing various environmental issue areas that would occur through a typical CEQA review process. 
    • There are only a few instances where more detail or clarification regarding potential impacts or measures to reduce impacts could have been provided.
    • These clarifications can be addressed either as the plan advances through the California Coastal Commission review and approval process or as part of staff ministerial permit review and plan check approvals.
  • No environmental impacts resulting from the plan were found to be excessive or extraordinary as compared to many similar development projects that have been approved and constructed within the city in recent years. 

Air Quality

  • The City of Carlsbad is located in a “non-attainment air basin” for several precursor emissions, meaning the area has been designated by the state and/or federal government as not meeting regulatory standards for one or more pollutants.
  • Because of this designation, thresholds for acceptable levels of emissions for new projects are very low.
  • The plan, which proposes 585,000 square feet of commercial land uses, exceeds the 2009 San Diego Regional Air Quality Strategy development projection of 463,600 square feet of recreational commercial land uses on the plan site.
  • Although the plan is consistent with the city’s existing and proposed Land Use Plans and SANDAG’s 2050 Regional Transportation Plan and Sustainable Communities Strategy, the plan is not consistent with the 2009 Regional Air Quality Standards for San Diego.
  • The Environmental Analysis conclusion regarding air quality is consistent with most other large projects that have been evaluated and approved by the city over the years through the typical CEQA review process.


  • The Environmental Analysis states that soils within the visitor-serving commercial portion of the plan are suitable for commercial/industrial uses, and hazardous materials would not be released.
  • The Environmental Analysis also concludes that the “exclusive agriculture open space” portion of the plan would not be developed with commercial or industrial uses, and hazardous materials would not be released. Soil sampling assessments and soil management procedures are required.
  • The Environmental Analysis does not discuss the potential release of hazardous materials in the other open space areas.
    • Based on a review of the information provided, the Habitat Management Plan open space portion of the plan site has likely remained untouched by agricultural activities and is not likely to contain soil contaminates that would result in the release of hazardous materials.
    • The “passive open space” portion of the plan is within areas of previous agricultural activity. Based on the soil sampling results from 2004, portions of this area contain elevated levels of organochloride pesticides in the soil. This area calls for the development of hiking and biking trails, picnic areas and other passive recreational activities. 
    • Adherence to the construction specifications and applicable federal, state and local regulations during ministerial/permit review and plan check approvals would ensure that there is not a significant hazard to the public or the environment from the pesticides.
    • The cost of mitigating the hazard, including removal of soil, if necessary, would be the responsibility of the landowner/developer.

    Water Supply

    • The plan would use less potable water at build out than the amount historically used by the agricultural operations on the site.
    • Projections for potable water demand are generally consistent with current Carlsbad Municipal Water District standards; however, the proposed potable water demand is slightly higher than projections in the CMWD 2012 Water Master Plan, so supply availability would need confirmation at plan check based on a hydraulic analysis.
    • This can be done in conjunction with the Environmental Protection Features included in the plan, which provides that building permits shall not be issued unless adequate water facilities are available at the time of permit issuance and will continue to be available until time of occupancy.
    • Recycled water demand projections of 2,230 gallons per day are higher than those in the 2012 CMWD Recycled Water Master Plan category for industrial properties but recycled water is available to support the plan.

    For more detailed information on this issue, read the full "9212 report."
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