State law requires cities to draw up General Plans [GP] to show the cities’ futures. What development? What limits? Carlsbad is circulating its updated GP. My comments to Carlsbad on those GP parts relevant to Palomar development were:
1. “Palomar Key Strategy: Despite the size and impact of McClellan-Palomar [Palomar] on Carlsbad, the GP has no key strategy for Palomar in GP § 1.5.
2. Modification of Carlsbad Ordinance 21.53.015 and CUP 172 Suppression. The GP seeks to modify the Carlsbad Ordinance 21.53.015 voter requirement by limiting Palomar Airport expansions of concern to only “geographic expansions.” Apparently, Carlsbad is saying that voters need not approve a Palomar 900-foot runway extension even though the State Aeronautics Act in PUC § 21664.5 defines an airport expansion as including runway extensions. Similarly, the GP “geographic expansion” policy language is inconsistent with Airport expansion conditions 1, 8, and 11 of CUP 172.
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The GP term “geographic expansion” is also undefined and unclear. Does the GP mean that the county can expand up to but not beyond El Camino Real? Or does the term “geographic expansion” mean that the county could create an FAA-rated C-III airport by bridging over El Camino Real?
Please recall that both Carlsbad and the county have claimed in the last year that Carlsbad failed to define the term “General Aviation Basic Transport” in CUP 172 and such failure lead to confusion. Given this history, it seems appropriate for Carlsbad to define key terms in its General Plan.
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3. Palomar Airport Blvd Gridlock & Scenic Corridor. The GP recognizes that even without Palomar Airport expansion, the traffic on Palomar Airport Blvd and El Camino Real will not meet Carlsbad Levels of Service [LOS] and the GP proposes no real solution. The GP ignores the further LOS deterioration that would occur from significant Palomar passenger service increases. The GP also ignores the county failure to landscape Palomar scenic corridors.
4. Palomar Noise Generation. The GP inadequately discusses Palomar noise issues. The GP does not (a) tell citizens how “noise averaging” methods are used to artificially reduce aircraft noise numbers, (b) disclose the substantial difference in noise that corporate jets create when displacing smaller planes, (c) explain that the “Fly Friendly” program is voluntary and has no effective enforcement mechanism, and (d) ignores the noise impacts of 500,000 to 900,000 added vehicles on the road if Palomar begins new air carrier service.
5. Public Safety & Environmental Concerns. The GP does not clearly distinguish between “On-Airport” and “Off-Airport” Palomar regulation thereby creating the false impression that all issues have been addressed. The GP does not disclose any attempt of Carlsbad to address on-airport Palomar problems including storm water contamination that can result from the 3 Palomar Airport landfills and from toxic leaks from Palomar aviation storage tanks owned by the county and county tenants.”
Perhaps Carlsbad could issue a press release saying it has no intent to require the county to get Carlsbad approvals for a Palomar Airport 900-foot runway extension rather than burying the ambiguous language of Palomar "geographic expansion" in its General Plan.