Carlsbad 2024 Executive Summary
State-mandated reforms executed under protest: growth caps declared dead, largest mixed-use project approved, and a new procedural barrier added voluntarily.
Carlsbad spent 2024 executing state-mandated housing reforms while signaling it would prefer not to. The city completed its Housing Element rezoning, declared its voter-approved growth caps unenforceable, and approved its largest mixed-use project in years, all under legal compulsion. It simultaneously passed a local-control resolution opposing the state mandates that forced these actions and expanded public engagement requirements that will slow future projects.
- 3,447
- Rezoning capacity (units)
16 sites toward 3,873-unit RHNA - 3-2
- Growth cap preemption vote
Blackburn, Acosta, Bhat-Patel yes - 26%
- RHNA progress
1,008 of 3,873 units - $15.3M
- Housing Trust Fund balance
Year-end 2024
Zoning and Density
Two structural changes defined the year.
Housing Element rezoning (March 12, 5-0): 16 sites providing 3,447 units of zoning capacity toward a 3,873-unit RHNA allocation. New R-30, R-35, R-40 designations with 45-foot height limits. By-right development established for projects with 20% affordability on RHNA sites. Growth management caps, quadrant limits, and control points formally acknowledged as preempted by SB 166 and SB 330, pushing projected buildout to 56,366 units past Proposition E's 54,599 cap. Staff warned that without certification, Builder's Remedy would allow housing "anywhere in the city, at any density without any discretionary review." Council proceeded on all sites except Cottage Row and Oak Yard despite significant public opposition.
Growth cap preemption (November 19, 3-2): Council formally declared Prop E's residential caps unenforceable under state law. Blackburn, Acosta, and Bhat-Patel voted yes. Hall and Schumacher voted to maintain caps that HCD had found impermissible in February 2021, with only 1,953 units remaining under the cap. Staff language was unambiguous: "the City finds that it cannot and will not enforce these residential caps, quadrant limits, and control points."
Additional liberalization (5-0): mixed-use added by-right in C-1, C-2, and C-L zones; ADU owner-occupancy removed per AB 976; inclusionary ordinance updated with extremely-low-income category and 55-year rental restrictions; permit expiration extended to three years.
The countermoves. Council unanimously expanded Policy 84, dropping the enhanced engagement threshold from 50 to 10 units and requiring it for all mixed-use projects. Noncompliance blocks applications as incomplete. This adds delay and cost to exactly the moderate-density development the rezoning was supposed to enable. Council also passed Resolution 2023-207 (5-0) asserting local control against state housing mandates. Luna softened it by deleting one recital, but the core opposition to state preemption remained.
The Traffic Safety & Mobility Commission voted 6-0 to accept SB 330's prohibition on LOS-based building moratoriums, removing the LOS deficiency declaration for College Blvd/Palomar Airport Rd. A proposed Multimodal Transportation Impact Fee replacing the Traffic Impact Fee would decouple development permitting from vehicular LOS entirely. At the Board of Directors, Bhat-Patel and Acosta initiated a motion to reevaluate Proposition H (the original voter-approved growth management framework), signaling recognition that it conflicts with state law.
Net structural assessment: Carlsbad removed or acknowledged the removal of its most significant structural barriers to housing (growth caps, quadrant limits, LOS moratoriums) while adding a new procedural barrier (Policy 84) and passing an anti-preemption resolution. The structural removals were compelled by state law; the new barrier was voluntary.
Development Pipeline
No etrakit filing data was available for Carlsbad. Pipeline activity is visible only through entitlement records: approximately 350+ units in active review, dominated by the 218-unit Carlsbad Village Mixed-Use project. Whether the Policy 84 expansion chills future filings will show in subsequent years.
Tenant Protections
No tenant protection measures appeared in any body's 2024 record. No rent stabilization, just-cause eviction, or relocation assistance proposals. A gap in Carlsbad's housing policy.
State Mandate Compliance
RHNA progress: 1,008 of 3,873 units (26%), with very-low-income at 7%. The Housing Element rezoning created zoning capacity, but capacity is not permits, and permits are not construction. The fee nexus study ($120,000 budgeted) and Local Facility Management Plan updates ($400,000) for eight rezone sites are implementation steps; whether fees increase or decrease will determine if they help or hinder production. Preparation for the 7th cycle (2029) Housing Element update is underway.
Housing Supply: Projects Voted On
| Project | Units▼ | Body | Vote | Dissenters | State Law Shield |
|---|---|---|---|---|---|
| Carlsbad Village Mixed-Use | 218 | Council | 4-1 | Burkholder | HAA, Density Bonus, AB 2097 |
| Carlsbad Village Mixed-Use | 218 | Planning Comm. | 5-2 | Kamenjarin, Lafferty | HAA, Density Bonus, AB 2097 |
| FPC Residential (Ponto Dr) | 86 | Planning Comm. | 6-0-1 | Merz recused | Density Bonus |
| Carlsbad by the Sea | 42 | Planning Comm. | 7-0 | None | N/A |
| 945 Chestnut Ave (acquisition) | 16 | Council | 5-0 | None | N/A |
| Tyler Street Homes | 12 | Planning Comm. | Rec. to Council | — | SB 330 fee lock |
| Three on Garfield | 3 | Planning Comm. | 4-1 | Lafferty | N/A |
| Poulter Properties | 2 | Planning Comm. | 6-0 | None | N/A |
| Maple Duplex | 2 | Planning Comm. | 6-0 | None | N/A |
| Normandy Beach (2 lots) | 2 | Planning Comm. | 5-1 each | Lafferty | N/A |
No housing project was denied in 2024. The largest project (218 units) was shielded by the Housing Accountability Act, Density Bonus Law, and AB 2097; City Attorney Frost stated the city could not deny or redesign it without identifying objective health/safety violations. YIMBY Law threatened HAA litigation. Council approved with conditions: unbundled parking, $50,000 transit subsidies, 12-month commercial construction requirement. When state law removes discretion, approval votes reveal less about council posture than structural votes.
Affordable Housing Finance
Active pipeline: La Costa Family Apartments ($10M tax-exempt bonds, 19 units); Laurel Tree Apartments ($45M bonds, 138 units); Mariposa Apartments (106 units, bond reissuance). Housing Trust Fund balance: $15.3M. Affordable Housing Resale Program acquired 25 at-risk units since 2020.
Federal pass-throughs: 756 Housing Choice Vouchers ($9.86M HUD); Rental Assistance Fund at $13.3M, up 17.5%; CDBG at $548K annually; PLHA at $466K, down $1.1M from loss of one-time state funding.
The Successor Agency Housing Trust Fund is being dissolved after its last bond debt service completed September 2023, with no replacement mechanism visible.
Windsor Pointe (50 affordable units) consumed disproportionate Council time: 762 calls for service, with 7 residents generating 53% of calls. Council replaced operator CONAM with Solari Enterprises (4-0, Blackburn recused). Burkholder called co-housing of populations "a completely horrible idea."
Fee structure: Affordable Housing Impact Fee at $2,925/unit; in-lieu fees of $10,040/unit (single-family) and $18/sq ft (2-6 unit projects). ADU fees set at LOW recovery (0-30%).
Infrastructure and Budget
$246M in water/wastewater CIP over five years, dominated by the Encina facility ($189M). Digester capacity near the 15-day permit limit. These investments maintain but do not expand development capacity.
The Traffic Commission killed the Tyler Street Complete Streets study (4-1, Commissioner Penseyres the lone yes), eliminating a Village/Barrio walkability project over parking concerns.
Council Member Patterns
The growth cap preemption (3-2) is the clearest test of housing posture: genuinely contested, structurally consequential, and the outcome of real discretion.
Blackburn, Acosta, Bhat-Patel voted to remove caps. Bhat-Patel and Acosta also initiated the Prop H reevaluation at the Board of Directors. Hall and Schumacher voted to maintain caps that HCD had already found impermissible, choosing symbolic local-control resistance over legal compliance.
On the earlier council (pre-November composition): Burkholder was the consistent dissenter on housing, casting the lone no on the 218-unit Village project. Luna softened the local-control resolution but voted for it. The Housing Element rezoning and zoning liberalization passed unanimously, but both were compelled by state deadlines.
At Planning Commission: Lafferty dissented most frequently on housing items (Village project, Three on Garfield, Normandy Beach, Grand Hope Medical). Kamenjarin aligned with Lafferty on the Village project and climate plan. Merz explicitly cited state law compliance as the commission's role. Sabellico initiated a motion to research counting memory care facilities toward RHNA.
Bottom line: The pattern across all bodies: Carlsbad's 2024 housing record was driven almost entirely by state mandate compliance, not local initiative. The council completed its required rezoning, acknowledged its growth caps were dead, and approved projects it legally could not deny. Its one voluntary structural action (Policy 84 expansion) made development harder. This council complies with state housing law but signals at every opportunity that it would prefer not to.
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