The First Update concluded that California is on track to meet the 2020 target but recommended a 2030 mid-term GHG reduction target be established to ensure a continuum of action to reduce emissions. The First Update recommended a mix of technologies in key economic sectors to reduce emissions through 2050, including energy demand reduction through efficiency and activity changes; large-scale electrification of on-road vehicles, buildings, and industrial machinery; decarbonizing electricity and fuel supplies; and the rapid market penetration of efficient and clean energy technologies. As part of the First Update, CARB recalculated the state’s 1990 emissions level, using more recent GWPs identified by the Intergovernmental Panel on Climate Change (IPCC), from 427 MMT CO2e to 431 MMT CO2e (CARB 2014a).
In 2015, as directed by EO B-30-15, CARB began working on an update to the Scoping Plan to incorporate the 2030 target of 40% below 1990 levels by 2030 to keep California on its trajectory toward meeting or exceeding the long- term goal of reducing GHG emissions to 80% below 1990 levels by 2050 as set forth in EO S-3-05. The governor called on California to pursue a new and ambitious set of strategies, in line with the five climate change pillars from his inaugural address, to reduce GHG emissions and prepare for the unavoidable impacts of climate change. In the summer of 2016, the legislature affirmed the importance of addressing climate change through passage of SB 32.
In December 2017, CARB adopted California’s 2017 Climate Change Scoping Plan (2017 Scoping Plan) for public review and comment (CARB 2017). The 2017 Scoping Plan builds on the successful framework established in the initial Scoping Plan and First Update while identifying new, technologically feasible and cost-effective strategies that will serve as the framework to achieve the 2030 GHG target as established by SB 32 and define the state’s climate change priorities to 2030 and beyond. The strategies’ commitments include implementing renewable energy and energy efficiency strategies (including the mandates of SB 350), increasing stringency of the Low Carbon Fuel Standard, implementing measures identified in the Mobile Source and Freight Strategies, implementing measures identified in the proposed Short -Lived Climate Pollutant Reduction Strategy, and increasing stringency of SB 375 targets. To fill the gap in additional reductions needed to achieve the 2030 target, it recommen ds continuing the Cap-and-Trade Program and a measure to reduce GHGs from refineries by 20%.
For local governments, the 2017 Scoping Plan replaced the initial Scoping Plan’s 15% reduction goal with a recommendation to aim for a community-wide goal of no more than 6 MT CO 2e per capita by 2030, and no more
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than 2 MT CO 2e per capita by 2050, which are consistent with the state’s long -term goals. These goals are also consistent with the Under 2 Memorandum of Understanding (Under 2 2016) and the Paris Agreement, which are developed around the scientifically based levels necessary to limit global warming to below 2°C. The 2017 Scoping Plan recognized the benefits of local government GHG planning (e.g., through climate action plan s [CAPs]) and provided more information regarding tools CARB is working on to support those efforts. It also recognize d the California Environmental Quality Act (CEQA) streamlining provisions for project-level review where there is a legally adequate CAP.1
The Scoping Plan recommends strategies for implementation at the statewide level to meet the goals of AB 32, SB 32, and the executive orders, and establishes an overall framework for the measures that will be adopted to reduce California’s GHG emissions. A project is considered consistent with the statutes and executive orders if it meets the general policies in reducing GHG emissions to facilitate the achievement of the state’s goals and does not impede attainment of those goals. A project would be consistent if it will further the objectives and not obstruct their attainment.
CARB adopted the 2022 Scoping Plan Update in December 2022, which outlines the state’s plan to reach carbon neutrality by 2045 or earlier, while also assessing the progress the state is making toward reducing GHG emissions by at least 40% below 1990 levels by 2030, as is required by SB 32 and laid out in the Second Update. The carbon neutrality goal requires CARB to expand proposed actions from only the reduction of anthropogenic sources of GHG emissions to also include those that capture and store carbon (e.g., through natural and working lands, or mechanical technologies). The carbon reduction programs build on and accelerate those currently in place, including moving to zero-emission transportation; phasing out use of fossil gas use for heating homes and buildings; reducing chemical and refrigerants with high GWP; providing communities with sustainable options for walking, biking, and public transit; displacement of fossil-fuel fired electrical generation through use of renewable energy alternatives (e.g., solar arrays and wind turbines); and scaling up new options such as green hydrogen (CARB 2022a).
The 2022 Scoping Plan also emphasizes that there is no realistic path to carbon neutrality without carbon removal and sequestration, and to achieve the state’s carbon neutrality goal, carbon reduction programs must be supplemented by strategies to remove a nd sequester carbon. Strategies for carbon removal and sequestration include carbon capture and storage from anthropogenic point sources, where CO2 is captured as it leaves a facility’s smokestack and is injected into geologic formations or used in industr ial materials (e.g., concrete); and carbon dioxide removal from ambient air, through mechanical (e.g., direct air capture with sequestration) or nature-based (e.g., management of natural and working lands) applications.
The 2022 Scoping Plan included Appendix D, Local Actions, which includes recommendations intended to build momentum for local government actions that align with the State’s climate goals, with a focus on local GHG reduction strategies (commonly referred to as climate action planning) and approval of new land use development projects, including through environmental review under CEQA. The recommendations provided in Appendix D are non-binding and should not be interpreted as a directive to local governments, but rather as evidence -based analytical tools to assist local governments with their role as essential partners in achieving California’s climate goals. Appendix D recognizes consistency with a CEQA-qualified GHG reduction plan such as a CAP as a preferred option for evaluating potential GHG emission impacts under CEQA. Absent a qualified GHG reduction plan, Appendix D provides additional potential threshold options including key attributes that residential and mixed -use projects
1 Sierra Club v. County of Napa (2004) 121 Cal.App.4th 1490; San Francisco Tomorrow et al. v. City and County of San Francisco (2015) 229 Cal.App.4th 498; San Franciscans Upholding the Downtown Specific Plan v. City and County of San Francisco (2002) 102 Cal.App.4th 656; Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 719.
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should achieve that would align with the State’s climate goals, a net -zero threshold, and use of air district recommended thresholds of significance.2
SB 605 and SB 1383. SB 605 (2014) required CARB to complete a comprehensive strategy to reduce emissions of short-lived climate pollutants in the state , and SB 1383 (2016) required CARB to approve and implement that strategy by January 1, 2018. The Short-Lived Climate Pollutants Reduction Strategy was approved by CARB in March 2017, and lays out a range of options to reduce short -lived climate pollutant emissions in California, including regulations, incentives, and other market -supporting activities. SB 13 83 also establishes specific targets for the reduction of short-lived climate pollutants (40% below 2013 levels by 2030 for CH4 and HFCs, and 50% below 2013 levels by 2030 for anthropogenic black carbon), and provides direction for reductions from dairy and livestock operations and landfills. Accordingly, and as mentioned above, CARB adopted its Short-Lived Climate Pollutant Reduction Strategy in March 2017. This strategy establishes a framework for the statewide reduction of emissions of black carbon, CH4, and fluorinated gases.
Building Energy
Title 24, Part 6. Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and regulate California’s building standards. Although not initially promulgated to reduce GHG emissions, Part 6 of Title 24 specifically established Building Energy Efficiency Standards that are designed to ensure new and existing buildings in California achieve energy efficiency and preserve outdoor and indoor environmental quality. These energy efficiency standards are reviewed every few years by the Building Standards Commission and California Energy Commission (CEC) and revised if necessary (California Public Resources Code [PRC] Section 25402[b][1]). The regulations receive input from members of industry and the public, with the goal of “reducing of wasteful, uneconomic, inefficient, or unnecessary consumption of energy” (PRC Section 25402). These regulations are carefully scrutinized and analyzed for technological and economic feasibility (PRC Section 25402[d]) and cost effectiveness (PRC Sections 25402[b][2] and [b][3]). As a result, these standards save energy, increase electricity supply reliability, increase indoor comfort, avoid the need to construct new power plants, and help preserve the environment.
The 2022 Title 24 standards are the currently applicable building energy efficiency standards, and became effective on January 1, 2023. The 2022 Title 24 standards improve upon the 2019 standards for new construction of, and additions and alterations to, residential and nonresidential buildings. The CEC adopted the 2022 Title 24 Energy Code in August 2021 and the California Building Standards Commission approved incorporating the updated code into the California Building Standards Code (CALGreen) in December 2021. The 2022 Energy Code went into effect on January 1, 2023. The 2022 Energy Code focuses on four key areas in newly constructed homes and businesses:
▪ Encouraging electric heat pump technology for space and water heating, which consumes less energy and produces fewer emissions than gas-powered units.
▪ Establishing electric-ready requirements for single-family homes to position owners to use cleaner electric heating, cooking, and EV charging options whenever they choose to adopt those technologies. ▪ Expanding solar photovoltaic system and battery storage standards to make clean energy available onsite and complement the state’s progress toward a 100% clean electricity grid. ▪ Strengthening ventilation standards to improve indoor air quality.
2 The threshold approaches outlined in the 2022 Scoping Plan, Appendix D, are recommendations only and are not requirements; they do not supplant lead agencies’ discretion to develop their own evidence-based approaches for determining whether a project would have a potentially significant impact on GHG emissions.
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Title 24, Part 11. In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as California’s Green B uilding Standards (CALGreen) and establishes minimum mandatory standards and voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirement s), water conservation, material conservation, and interior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground-up, new construction of commercial, low-rise residential and state-owned buildings, schools, and hospitals. The CALGreen 2022 standards, which are the current standards, became effective January 1, 2023.
Title 20. Title 20 of the California Code of Regulations requires manufacturers of appliances to meet state and federal standards for energy and water efficiency. Performance of appliances must be certified through the CEC to demonstrate compliance with standards. New appliances regulated under Title 20 include refrigerators, refrigerator-freezers, and freezers; room air conditioners and room air -conditioning heat pumps; central air conditioners; spot air conditioners; vented gas space heaters; gas pool heaters; plumbing fittings and plumbing fixtures; fluorescent lamp ballasts; lamps; emergency lighting; traffic signal modules; dishwaters; clothes washers and dryers; cooking products; electric motors; low voltage dry -type distribution transformers; power supplies; televisions and consumer audio and video equipment; and battery charger systems. Title 20 presents protocols for testing for each type of appli ance covered under the regulations , and appliances must meet the standards for energy performance, energy design, water performance, and water design. Title 20 contains three types of standards for appliances: federal and state standards for federally regu lated appliances, state standards for federally regulated appliances, and state standards for non-federally regulated appliances.
AB 1109. Enacted in 2007, AB 1109 required the CEC to adopt minimum energy efficiency standards for general- purpose lighting to reduce electricity consumption by 50% for indoor residential lighting and by 25% for indoor commercial lighting.
SB 1. SB 1 (Murray) (August 2006) established a $3 billion rebate program to support the goal of the state to install rooftop solar energy systems with a generation capacity of 3,000 megawatts through 2016. SB 1 added sections to the Public Resources Code, inclu ding Chapter 8.8 (California Solar Initiative), that require building projects applying for ratepayer-funded incentives for photovoltaic systems to meet minimum energy efficiency levels and performance requirements. Section 25780 established that it is a goal of the state to establish a self -sufficient solar industry. The goals included establishing solar energy systems as a viable mainstream option for homes and businesses within 10 years of adoption, and placing solar energy systems on 50% of new homes within 13 years of adoption. SB 1, also termed “Go Solar California,” was previously titled “Million Solar Roofs.” California AB 1470 (Solar Water Heating). This bill established the Solar Water Heating and Efficiency Act of 2007.
AB 1470 makes findings and declarations of the Legislature relating to the promotion of solar water heating systems and other technologies that reduce natural gas demand. AB 1470 defines several terms for purposes of the act. The bill required a commission to evaluate the data available from a specified pilot program, and to design and implement a program of incentives for the installation of 200,000 solar water heating systems in homes and businesses throughout the state by 2017.
Renewable Energy and Energy Procurement
SB 1078 (2002) established the Renewables Portfolio Standard program, which requires an annual increase in renewable generation by the utilities.
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Under the program, a renewable electrical generation facility is one that uses biomass, solar thermal, photovoltaic, wind, geothermal, fuel cells using renewable fuels, small hydroelectric generation of 30 megawatts or less, digester gas, municipal solid w aste conversion, landfill gas, ocean wave, ocean thermal, or tidal current, and that meets other specified requirements with respect to its location.
SB 1368. SB 1368 (September 2006) required the CEC to develop and adopt regulations for GHG emission performance standards for the long -term procurement of electricity by local publicly owned utilities. These standards must be consistent with the standards adopted by the California Public Utilities Commission.
EO S-14-08. EO S-14-08 (November 2008) focused on the contribution of renewable energy sources to meet the electrical needs of California while reducing the GHG emissions from the electrical sector. This EO required that all retail suppliers of electricity in California serve 33% of their load with renewable energy by 2020. Furthermore, the EO directed state agencies to take appropriate actions to facilitate reaching this target. The California Natural Resources Agency (CNRA), through collaboration with the CEC and California Department of Fish and Wildlife (formerly the California Department of Fish and Game), was directed to lead this effort.
EO S-21-09 and SBX1-2. EO S-21-09 (September 2009) directed CARB to adopt a regulation consistent with the goal of EO S -14-08 by July 31, 2010. CARB was further directed to work with the California Public Utilities Commission and CEC to ensure that the regulation builds upon the Renewables Portfolio Standard program and was applicable to investor-owned utilities, publicly owned utilities, direct access providers, and community choice providers. Under this order, CARB was to give the highest priority to those renewable resources t hat provide the greatest environmental benefits with the least environmental costs and impacts on public health and can be developed the most quickly in support of reliable, efficient, cost -effective electricity system operations. On September 23, 2010, CARB initially approved regulations to implement a Renewable Electricity Standard. However, this regulation was not finalized because of subsequent legislation (SB X1-2, Simitian, statutes of 2011) signed by Governor Brown in April 2011.
SB X1 2 expanded the Renewables Portfolio Standard by establishing a renewable energy target of 20% of the total electricity sold to retail customers in California per year by December 31, 2013, and 33% by December 31, 2020, and in subsequent years. Under the bill, a renewable electrical generation facility is one that uses biomass, solar thermal, photovoltaic, wind, geothermal, fuel cells using renewable fuels, small hydroelectric generation (30 megawatts or less), digester gas, municipal solid waste conversion, landfill gas, ocean wave, ocean thermal, or tidal current, and that meets other specified requirements with respect to its location.
SB X1-2 applies to all electricity retailers in the state including publicly owned utilities, investor -owned utilities, electricity service providers, and community choice aggregators. All of these entities must meet the renewable energy goals previously listed.
SB 350. SB 350 (October 2015, Clean Energy and Pollution Reduction Act) further expanded the Renewables Portfolio Standard by establishing a goal of 50% of the total electricity sold to retail customers in California per year by December 31, 2030. In addition, SB 350 included the goal to double the energy efficiency savings in electricity and natural gas final end uses (e.g., heating, cooling, lighting, or class of energy uses on which an energy-efficiency program is focused) of retail custome rs through ene rgy conservation and efficiency. The bill also requires the California Public Utilities Commission, in consultation with the CEC, to establish efficiency targets for electrical and gas corporations consistent with this goal. Regarding mobile sources, as one of its elements, SB 350 establishes a statewide policy for widespread electrification of the transportation sector, recognizing that such electrification is
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required for achievement of the state’s 2030 and 2050 reduction targets (see California Public Utilities Code Section 740.12).
SB 100. SB 100 (2018) increased the standards set forth in SB 350 establishing that 44% of the total electricity sold to retail customers in California per year by December 31, 2024, 52% by December 31, 2027, and 60% by December 31, 2030, be secured from qualifyin g renewable energy sources. SB 100 states that it is the policy of the state that eligible renewable energy resources and zero -carbon resources supply 100% of the retail sales of electricity to California. This bill requires that the achievement of 100% zero-carbon electricity resources do not increase the carbon emissions elsewhere in the western grid and that the achievement not be achieved through resource shuffling.
SB 1020. SB 1020 (September 2022) revises the standards from SB 100, requiring the following percentage of retail sales of electricity to California end-use customers come from eligible renewable energy resources and zero- carbon resources: 90% by December 31, 2035; 95% by December 31, 2040; and 100% by December 31, 2045.
Mobile Sources
State Vehicle Standards (AB 1493 and EO B -16-12). AB 1493 (July 2002) was enacted in a response to the transportation sector accounting for more than half of California’s CO2 emissions. AB 1493 required CARB to set GHG emission standards for passenger vehicles, light-duty trucks, and other vehicles determined by the state board to be vehicles that are primarily used for noncommercial personal transportation in the state. The bill required that CARB set GHG emission standards for motor vehicles manufactured in 2009 and all subsequent model years. CARB adopted the standards in September 2004. EO B -16-12 (March 2012) required that state entities under the governor’s direction and control support and facilitate the rapid commercialization of zero-emissions vehicles. It ordered CARB, CEC, California Public Utilities Commission, and other relevant agencies to work with the Plug -in Electric Vehicle Collaborative and the California Fuel Cell Partnership to establish benchmarks to help achieve benchmark goals by 2015, 2020, and 2025. On a statewide basis, EO B-16-12 established a target reduction of GHG emissions from the transportation sector equaling 80% less than 1990 levels by 2050. This directive did not apply to vehicles that have special performance requirements necessary for the protection of the public safety and welfare.
In March 2022, EPA reinstated California’s authority under the Clean Air Act to implement its own GHG emission standards and ZEV sales mandate. EPA’s action concludes its reconsideration of the 2019 SAFE-1 rule by finding that the actions taken under the previous administration as a part of SAFE -1 were decided in error and are now entirely rescinded.
Heavy Duty Truck and Bus Regulation. CARB adopted the final Heavy-Duty Truck and Bus Regulation on December 31, 2014, to reduce diesel particulate matter, a major source of black carbon, and oxides of nitrogen emissions from heavy-duty diesel vehicles (Cal. Code Regs. tit. 13, § 2025). The rule requires diesel particulate matter filters be applied to newer heavier trucks and buses by January 1, 2012, with older vehicles required to comply by January 1, 2015. The rule will require nearly all diesel trucks an d buses to be compliant with the 2010 model year engine requirement by January 1, 2023. CARB also adopted an Airborne Toxic Control Measure to limit idling of diesel-fueled commercial vehicles on December 12, 2013. This rule requires diesel -fueled vehicles with gross vehicle weights greater than 10,000 pounds to idle no more than 5 minutes at any location (Cal. Code Regs. tit. 13, § 2485).
EO S-1-07. Issued on January 18, 2007, EO S-1-07 sets a declining Low Carbon Fuel Standard for GHG emissions measured in CO2e grams per unit of fuel energy sold in California. The initial target of the Low Carbon Fuel Standard was to reduce the carbon intensity of California passenger vehicle fuels by at least 10% by 2020. The Low Carbon
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Fuel Standard was subsequently amended in 2018 to require a 20% reduction in carbon intensity by 2030. This new requirement aligns with the California’s overall 2030 target of reducing climate changing emissions to 40% below 1990 levels by 2030, set by SB 32. CARB has adopted implementing regulations for both the 10% and 20% carbon intensity reduction targets.
SB 375. SB 375 (2008) addresses GHG emissions associated with the transportation sector through regional transportation and sustainability plans. SB 375 required CARB to adopt regional GHG reduction targets for the automobile and light -truck sector for 2020 and 2 035. Regional metropolitan planning organizations (MPOs) are then responsible for preparing a Sustainable Communities Strategy (SCS) within their Regional Transportation Plan (RTP). The goal of the SCS is to establish a forecasted development pattern for t he region that, after considering transportation measures and policies, will achieve, if feasible, the GHG reduction targets. If an SCS is unable to achieve the GHG reduction target, a metropolitan planning organization must prepare an Alternative Planning Strategy demonstrating how the GHG reduction target would be achieved through alternative development patterns, infrastructure, or additional transportation measures or policies.
Pursuant to California Government Code Section 65080(b)(2)(K), a n SCS does not regulate the use of land; supersede the land use authority of cities and counties; or require that a City’s or county’s land use policies and regulations, including those in a general plan, be consistent with it. Nonetheless, SB 375 makes regional and local planning agencies responsible for developing those strategies as part of the federally required metr opolitan transportation planning process and the state-mandated housing element process.
Advanced Clean Cars Program. The Advanced Clean Cars program (January 2012) is an emissions-control program for model years 2015 through 2025. The program combines the control of smog- and soot-causing pollutants and GHG emissions into a single coordinated package. The package includes elements to reduce smog -forming pollution, reduce GHG emissions, promote clean cars, and provide the fuels for clean cars. To improve air quality, CARB implemented new emission standards to reduce smog -forming emissions beginning with 2015 model year vehicles. It is estimated that by 2025, cars will emit 75% less smog-forming pollution than the average new car sold in 2012. To reduce GHG emissions, CARB, in conjunction with the EPA and NHTSA, adopted new GHG standards for model year 2017 to 2025 vehicles; the new standards are estimated to reduce GHG emissions by 34% in 2025.
The zero-emissions vehicle (ZEV) program will act as the focused technology of the Advanced Clean Cars program by requiring manufacturers to produce incre asing numbers of ZEVs and plug -in hybrid EVs in the 2018 to 2025 model years.
The Advanced Clean Cars II (ACC II) program establishes the next set of LEV and ZEV requirements for model years after 2025 to contribute to meeting federal ambient air quality ozone standards and California’s carbon neutrality standards (CARB 2022b). The ACC II rulemaking package also considers technological feasibility, environmental impacts, equity, economic impacts, and consumer impacts. The ACC II regulations were approved by the California Office of Administrative Law and became effective on November 30, 2022.
AB 1236. AB 1236 (October 2015) (Chiu) required a city, county, or city and county to approve an application for the installation of EV charging stations, as defined, through the issuance of specified permits unless the city or county makes specified written findings based on substantial evidence in the record that the proposed installation would have a specific, adverse impact upon the p ublic health or safety, and there is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact. AB 1236 provided for appeal of that decision to the planning commission, as specified. The bill provided that the implementation of consistent statewide standards to achieve the timely and cost-effective installation of EV charging stations is a matter of statewide concern. The bill required EV charging stations to meet specified standards. AB 1236 required a city, county, or city and county with
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a population of 200,000 or more residents to adopt an ordinance, by September 30, 2016, that created an expedited and streamlined permitting process for EV charging stations. The bill also required a city, county, or city and county with a population of fewer than 200,000 residents to adopt this ordinance by September 30, 2017.
EO N-79-20 (September 2020) requires CARB to develop regulations as follows: (1) Passenger vehicle and truck regulations requiring increasing volumes of new ZEVs sold in the State towards the target of 100% of in-State sales by 2035; (2) medium- and heavy-duty vehicle regulations requiring increasing volumes of new zero-emission trucks and buses sold and operated in the State towards the target of 100% of the fleet transitioning to zero - ZEVs by 2045 everywhere feasible and for all drayage trucks to be zero emission by 2035; and (3) strategies, in coordination with other State agencies, the EPA and local air districts, to achieve 100% zero-emission from off-road vehicles and equipment operations in the State by 2035. EO N -79-20 called for the development of a Zero-Emissions Vehicle Market Development Strategy, which was released February 2021, to be updated every 3 years, that ensures coordination and implementation of the EO and outlines actions to support new and used ZEV markets. The primary mechanism for achieving the ZEV target for passenger cars and light trucks is the ACC II Program, approved in August 2022. In addition to ACC II, the Clean Miles Standard regulation will also help enable the goal of 100% ZEV sales in 2035 by creating demand for ZEVs. This regulation will have aggressive requirements for electric miles that will transition ride-hailing fleets to zero-emission operations starting in 2023 and ramping up through 2030. This regulation was approved by CARB in 2021.
Advanced Clean Trucks (ACT) Regulation. The purpose of the ACT Regulation (June 2020) is to accelerate the market for zero- ZEVs in the medium - and heavy-duty truck sector and to reduce emissions NO x, fine particulate matter, TACs, GHGs, and other criteria pollutants generated from on-road mobile sources (CARB 2022b). Requiring medium- and heavy-duty vehicles to transition to zero -emissions technology will reduce health risks to people living in and visiting California and is needed to help California meet established near- and long-term air quality and climate mitigation targets.
EO B-16-12. EO B-16-12 (2012) directs state entities under the Governor’s direction and control to support and facilitate development and distribution ZEVs. On a statewide basis, EO B-16-12 also establishes a GHG emissions reduction target from the transportation sector equaling 80% less than 1990 levels by 2050. In furtherance of this executive order, the Governor convened an Interagency Working Group on ZEVs that has published multiple reports regarding the progress made on the penetration of ZEVs in the statewide vehicle fleet.
Water
SB X7-7/Water Conservation Act of 2009. This regulation required that all water suppliers increase their water use efficiency with an overall goal of reducing per capita urban water use by 20% by December 31, 2020. Each urban water supplier was required to develop water use targets to meet this goal.
EO B-29-15. In response to the ongoing drought in California, EO B -29-15 (April 2015) set a goal of achieving a statewide reduction in potable urban water usage of 25% relative to water use in 2013. The term of the executive order extended through February 28, 2016, although many of the directives have since become permanent water- efficiency standards and requirements. The executive order includes specific directives that set strict limits on water usage in the state. In response to EO B-29-15, the California Department of Water Resources modified and adopted a revised version of the Model Water Efficient Landscape Ordinance that, among other changes, significantly increased the requirements for landscape water use efficiency and broaden ed its applicability to include new development projects with smaller landscape areas.
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EO B-37-16. Issued May 2016, EO B-37-16 directed the State Water Resources Control Board to adjust emergency water conservation regulations through the end of January 2017 to reflect differing water supply conditions across the state. The State Water Resources Control Board also developed a proposal to achieve a mandatory reduction of potable urban water usage that builds off the mandatory 25% reduction called for in EO B-29-15. The State Water Resources Control Board and Department of Water Resources will develop new, permanent water use targets that build on the existing state law requirements that the state achieve 20% reduction in urban water usage by 2020.
EO B -37-16 also specifies that the State Water Resources Control Board permanently prohibit water -wasting practices such as hosing off sidewalks, driveways, and other hardscapes; washing automobiles with hoses not equipped with a shut -off nozzle; using non -recirculated water in fountain s and other decorative water feature s; watering lawns in a manner t hat causes runoff, or within 48 hours after measurable precipitation; and irrigating ornamental turf on public street medians.
EO N-10-21. In response to a state of emergency due to severe drought conditions, EO N-10-21 (July 2021) called on all Californians to voluntarily reduce their water use by 15% from their 2020 levels. Actions suggested in EO N-10-21 include reducing landscape irrigation, running dishwashers and washing machines only when full, finding and fixing leaks, installing water-efficient showerheads, taking shorter showers, using a shut-off nozzle on hoses, and taking cars to commercial car washes that use recycled water.
Solid Waste
AB 939, AB 341, AB 1826, and SB 1383. In 1989, AB 939, known as the Integrated Waste Management Act (PRC Sections 40000 et seq.), was passed because of the increase in waste stream and decrease in landfill capacity.
The statute established the California Integrated Waste Management Board, which oversees a disposal reporting system. AB 939 mandated a reduction of waste being disposed of where jurisdictions were required to meet diversion goals of all solid waste through source reduction, recycling, and composting activities of 25% by 1995 and 50% by 2000.
AB 341 (Chapter 476, Statutes of 2011 [Chesbro]) amended the California Integrated Waste Management Act of 1989 to include a provision declaring that it is the policy goal of the state that not less than 75% of solid waste generated be source -reduced, recy cled, or composted by 2020, and annually thereafter. In addition, AB 341 required the California Department of Resources Recycling and Recovery (CalRecycle) to develop strategies to achieve the state’s policy goal. CalRecycle conducted several general stakeholder workshops and several focused workshops, and in August 2015 published a discussion document titled AB 341 Report to the Legislature, which identified five priority strategies that CalRecycle believed would assist the state in reaching the 75% goal by 2020, legislative and regulatory recommendations, and an evaluation of program effectiveness (CalRecycle 2015).
AB 1826 (Chapter 727, Statutes of 2014, effective 2016) requires businesses to recycle their organic waste (i.e., food waste, green waste, landscape and pruning waste, nonhazardous wood waste, and food -soiled paper waste that is mixed in with food waste) depending on the amount of waste they generate per week. This law also requires local jurisdictions across the state to implement an organic waste recycling program to divert organic waste generated by businesses, including multi -family residential dwelling s that consist of five or more units. The minimum threshold of organic waste generation by businesses decreases over time, which means an increasingly greater proportion of the commercial sector will be required to comply.
SB 1383 (Chapter 395, Statutes of 2016) establishes targets to achieve a 50% reduction in the level of the Statewide disposal of organic waste from the 2014 level by 2020 and a 75% reduction by 2025. CalRecycle was granted the regulatory authority required to achieve the organic waste disposal reduction targets and establishes
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an additional target that not less than 20% of currently disposed edible food is recovered for human consumption by 2025 (CalRecycle 2019).
Other State Regulations and Goals
SB 97. SB 97 (Dutton) (August 2007) directed the Governor’s Office of Planning and Research to develop guidelines under CEQA for the mitigation of GHG emissions. In 2008, the Governor’s Office of Planning and Research issued a technical advisory as interim guidance regarding the analysis of GHG emissions in CEQA documents. The advisory indicated that the lead agency should identify and estimate a project’s GHG emissions, including those associated with vehicular traffic, energy consumption, water usage, and construction activities (OPR 200 8). The advisory further recommended that the lead agency determine significance of the impacts and impose all mitigation measures necessary to reduce GHG emissions to a level that is less than significant. The CNRA adopted the CEQA Guidelines amendments in December 2009, which became effective in March 2010.
Under the amended CEQA Guidelines, a lead agency has the discretion to determine whether to use a quantitative or qualitative analysis or apply performance standards to determine the significance of GHG emissions resulting from a particular project (14 CCR 15064.4[a]). The CEQA Guidelines require a lead agency to consider the extent to which a project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]). The CEQA Guidelines also allow a lead agency to consider feasible means of mitigating the significant effects of GHG emissions, including reductions in emissions through the implementation of project features or off -site measures. The adopted amendments do not establish a GHG emissions threshold, instead allowing a lead agency to develop, adopt, and apply its own thresholds of significance or those developed by other agencies or experts. The CNRA also acknowledged that a lead agency may consider compliance with regulations or requirements implementing AB 32 in determining the significance of a project’s GHG emissions (CNRA 2009a).
With respect to GHG emissions, the CEQA Guidelines state in Section 15064.4(a) that lead agencies should “make a good faith effort, to the extent possible on scientific and factual data, to describe, calculate or estimate” GHG emissions. The CEQA Guidelines note that an agency may identify emissions by either selecting a “model or methodology” to quantify the emissions or by relying on “qualitative analysis or other performance -based standards” (14 CCR 15064.4 [a]). Section 15064.4(b) states that the lead ag ency should consider the following when assessing the significance of impacts from GHG emissions on the environment: the extent a project may increase or reduce GHG emissions as compared to the existing environmental setting; whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project; and the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]).
EO S-13-08. EO Order S -13-08 (November 2008) is intended to hasten California’s response to the impacts of global climate change, particularly sea -level rise. Therefore, the executive order directs state agencies to take specified actions to assess and plan for such impacts. The final 2009 California Climate Adaptation Strategy report was issued in December 2009 (CNRA 2009b), and an update, Safeguarding California: Reducing Climate Risk, followed in July 2014 (CNRA 2014). To assess the state’s vulnerability, the report summarizes key climate change impacts to the state for the following areas: agriculture, biodiversity and habitat, emergency management, energy, forestry, ocean and coastal ecosystems and resources, public health, transportation, and water.
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Local
San Diego Association of Governments (SANDAG)
2021 Regional Transportation Plan/Sustainable Communities Strategy The passage of SB 375 requires MPOs to prepare an SCS in their RTP. SANDAG serves as the MPO for the San Diego region and is responsible for developing and adopting a SCS that integrates transportation, land use, and housing to meet GHG reduction targets s et by CARB. The RTP/SCS is updated every 4 years in collaboration the 18 cities and unincorporated County of San Diego, in addition to regional, state, and federal partners. The most recent, San Diego Forward: The 2021 Regional Plan was adopted in 2021 and provides guidance on meeting or exceed GHG targets through implementation of five key transportation strategies, including complete corridors, high-speed transit services, mobility hubs, flexible fleets, and a digital platform to tie the transportation system together. Through these strategies, the 2021 Regional Plan is projected to reduce per capita GHG emissions from cars and light -duty trucks to 20% below 2005 levels by 2035, exceeding the regions state - mandated target of 19% (SANDAG 2021).
City of Chula Vista
The City of Chula Vista General Plan was updated by the City on December 13, 2005, and most recently amended in 2020. The General Plan provides a long-term strategy to address planning issues for the growth and development of the City and is composed of th e following six elements: land use and transportation, economic development, public facilities and services, growth management, environmental, and housing (City of Chula Vista 2005). The project site is located in the Bayfront Planning Area and Harbor Dist rict subarea of the General Plan (City of Chula Vista 2005). The goals and policies for improving air quality in the General Plan are as follows:
Land Use and Transportation Element
Policy LUT-23.1: Encourage the use of bicycles and walking as alternatives to driving.
Policy LUT-23.2: Foster the development of a system of inter-connecting bicycle routes throughout the City and region.
Policy LUT-23.5: Provide linkages between bicycle facilities that utilize circulation element alignments and open space corridors.
Policy LUT-23.8: Provide and maintain a safe and efficient system of sidewalks, trails, and pedestrian crossings.
Policy LUT -23.14: Require new development projects to provide internal bikeway systems with connections to the citywide bicycle networks.
Environmental Element
Policy E 6.1: Encourage compact development featuring a mix of uses that locate residential areas within reasonable walking distance to jobs, services, and transit.
Policy E 6.2: Promote and facilitate transit system improvements in order to increase transit use and reduce dependency on the automobile.
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Policy E 6.3: Facilitate the use of alternative fuel and low - and zero-emission vehicles and equipment in the community.
Policy E 6.4: Do not site new or re -powered fossil-fueled baseload or peaking -type Electric Generating Facilities and other major toxic emitters within 1,000 feet of sensitive receptors, or site sensitive receptors within 1,000 feet of such facilities.
Policy E 6.5: Ensure Electrical Generating Facilities incorporate cleaner fuel sources and least polluting technologies in order to help transition the City to a less fossil fuel- dependent future, while meeting Chula Vista’s energy demand.
Policy E 6.6: Explore incentives to promote voluntary air pollutant reductions, including incentives for developers who go above and beyond applicable requirements and for facilities and operations that are not otherwise regulated.
Policy E 6.7: Encourage innovative energy conservation practices and air quality improvements in new development and redevelopment projects consistent with the City's Air Quality Improvement Plan Guidelines or its equivalent, pursuant to the City's Growth Management Program.
Policy E 6.8: Encourage climate resilient design techniques in new buildings and infrastructure to reduce future risks from climate change-related impacts such as wildfires, extreme heat, and flooding.
Policy E 6.9: Discourage the use of landscaping equipment powered by two-stroke gasoline engines within the City and promote less-polluting alternatives to their use.
Policy E 6.10: The siting of new sensitive receivers within 500 feet of highways resulting from development or redevelopment projects shall require the preparation of a health risk assessment as part of the CEQA review of the project. Attendant health risks identified in the Health Risk Assessment (HRA) shall be feasibly mitigated to the maximum extent practicable, in accordance with CEQA, in order to help ensure that applicable federal and state standards are not exceeded.
Policy E 6.11: Develop strategies to minimize CO hot spots that address all modes of transportation.
Policy E 6.12: Promote clean fuel sources that help reduce the exposure of sensitive uses to pollutants.
Policy E 6.13: Encourage programs and infrastructure to increase the availability and usage of energy-efficient vehicles, such as hybrid electric vehicles, electric vehicles, or those that run on alternative fuels.
Policy E 6.14: Transition the City fleet to 100% “clean” vehicles by integrating hybrid and alternative fuel vehicles as current municipal fleet vehicles are replaced.
Policy E 6.15: Site industries: and other stationary emitters in a way that minimizes the potential impacts of poor air quality on homes, schools, hospitals, and other land uses where people congregate, and disadvantaged populations.
Policy E 6.16: Encourage the use of bicycles through support of bike share opportunities, community bike programs, and the provision of bicycle parking opportunities such as bike racks and bike lockers.
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Policy E 6.B.1: Protect and develop shade tree cover along streets and within parking lots as a priority, particularly in new developments or tree-deficient areas.
Policy E 6.B.2: Preferentially plant female street trees to reduce pollen, especially in the most populated areas.
Policy E 6.B.3: Prioritize natural filtration, as opposed to impermeable hardscaping, within new development projects, along roadways, and adjacent to stream and river banks.
Policy E 6.B.4: Update the building code to support best practices in “green building” design, construction, and operations.
Policy E 6.B.5: Provide fast -track permitting for projects that implement “green building” design and construction.
Policy E 6.B.6: Encourage or require all new building construction to incorporate green roofs and encourage conversions of existing roof space to green roofs to reduce heat island effect.
Climate Action Plan
In September 2017, the City adopted its most recent CAP. The CAP includes goals and policies to strengthen the City’s climate action efforts that have been underway since 2000. The City’s CAP identified a goal of reducing GHG emissions to 15% below 2005 emission levels by 2020 and 55 percent by 2030. The City’s implementation actions are focused on the following categories:
▪ Water Conservation and Reuse
▪ Waste Reduction
▪ Renewable and Efficient Energy
▪ Smart Growth and Transportation
Since the first GHG inventory in 1990 the City’s population has increased 84% but GHG emissions have only increased 42%, which has caused the per capita emissions to decrease 23% to 6.1 MT CO ₂e per person. CARB’s 2022 Scoping Plan has identified a goal of carbon neutrality by 2045 so the City will continue advancing to meet these ambitious goals. Notably, the City’s CAP is not considered a “qualified” CAP for tiering per CEQA Guidelines Section 15183.5 because it has not undergone environmental review.
5.7.1.2 Existing Setting
5.7.1.2.1 Climate Change Overview
Climate change refers to any significant change in measures of climate, such as temperature, precipitation, or wind patterns, lasting for an extended period of time (decades or longer). The Earth's temperature depends on the balance between energy entering and leaving the planet’s system. Many factors, both natural and human, can cause changes in Earth’s energy balance, including variations in the sun's energy reaching Earth, changes in the reflectivity of Earth’s atmosphere and surface, and changes in the greenhouse effect, which affects the amount of heat retained by Earth’s atmosphere (EPA 2023).
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The greenhouse effect is the trapping and build -up of heat in the atmosphere (troposphere) near the Earth’s surface. The greenhouse effect traps heat in the troposphere through a threefold process as follows: Short -wave radiation emitted by the Sun is abso rbed by the Earth; the Earth emits a portion of this energy in the form of long-wave radiation; and GHGs in the upper atmosphere absorb this long-wave radiation and emit it into space and toward the Earth. The greenhouse effect is a natural process that contributes to regulating the Earth’s temperature and creates a pleasant, livable environment on the Earth. Human activities that emit additional GHGs to the atmosphere increase the amount of infrared radiation that gets absorbed before escaping into space, thus enhancing the greenhouse effect and causing the Earth’s surface temperature to rise.
The scientific record of the Earth’s climate shows that the climate system varies naturally over a wide range of time scales and that in general, climate changes prior to the Industrial Revolution in the 1700s can be explained by natural causes, such as changes in solar energy, volcanic eruptions, and natural changes in GHG concentrations.
Recent climate changes, in particular the warming observed over the past century, however, cannot be explained by natural causes alone. Rather, it is extremely likely that human activities have been the dominant cause of that warming since the mid-20th century and is the most significant driver of observed climate change (IPCC 2014; EPA 2023a). Human in fluence on the climate system is evident from the increasing GHG concentrations in the atmosphere, positive radiative forcing, observed warming, and improved understanding of the climate system (IPCC 2014). The atmospheric concentrations of GHGs have increased to levels unprecedented in the last 800,000 years, primarily from fossil fuel emissions and secondarily from emissions associated with land use changes (IPCC 2014).
Continued emissions of GHGs will cause further warming and changes in all components of the climate system, which is discussed further in Section 5.7.1.5, Potential Effects of Climate Change.
5.7.1.2.2 Greenhouse Gases and other Climate Forcing Substances A GHG is any gas that absorbs infrared radiation in the atmosphere; in other words, GHGs trap heat in the atmosphere. GHGs include, but are not limited to, carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), ozone (O3), water vapor, hydrofluorocarbons (HFCs), hydrochlorofluorocarbons (HCFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF 6).3 Some GHGs, such as CO 2, CH 4, and N 2O, occur naturally and are emitted to the atmosphere through natural processes and human activities. Of these gases, CO 2 and CH 4 are emitted in the greatest quantities from human activities. Manufactured GHGs, which have a much greater heat -absorption potential than CO 2, include fluorinated gases, such as HFCs, HCFCs, PFCs, and SF 6, which are associated with certain industrial products and processes. A summary of the most common GHGs and their sources is included in the following text.4 Also included is a discussion of other climate forcing substances.
Carbon Dioxide (CO 2). CO2 is a naturally occurring gas and a by -product of human activities and is the principal anthropogenic GHG that affects the Earth’s radiative balance. Natural sources of CO2 include respiration of bacteria, plants, animals, and fungus; evaporation from oceans; volcanic out -gassing; and decomposition of dead organic matter. Human activities that generate CO 2 are from the combustion of fuels such as coal, oil, natural gas, and wood and changes in land use.
Methane (CH4). CH4 is produced through both natural and human activities. CH4 is a flammable gas and is the main component of natural gas. Methane is produced through anaerobic (without oxygen) decomposition of waste in
3 California Health and Safety Code 38505 identifies seven GHGs that CARB is responsible to monitor and regulate to reduce emissions: CO2, CH4, N2O, SF6, HFCs, PFCs, and NF3.
4 The descriptions of GHGs are summarized from the Intergovernmental Panel on Climate Change (IPCC) Fourth Assessment Report (2007), CARB’s Glossary of Air Pollution Terms (2023i), and EPA’s Glossary of Climate Change Terms (2016).
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landfills, flooded rice fields, animal digestion, decomposition of animal wastes, production and distribution of natural gas and petroleum, coal production, and incomplete fossil fuel combustion.
Nitrous Oxide (N2O). N2O is produced through natural and human activities, mainly through agricultural activities and natural biological processes, although fuel burning and other processes also create N 2O. Sources of N 2O include soil cultivation practices (microbial processes in soil and water), especially the use of commercial and organic fertilizers, manure management, industrial processes (such as in nitric acid production, nylon production, and fossil-fuel-fired power plants), vehicle emissions, and using N2O as a propellant (such as in rockets, racecars, and aerosol sprays).
Fluorinated Gases. Fluorinated gases (also referred to as F-gases) are synthetic powerful GHGs emitted from many industrial processes. Fluorinated gases are commonly used as substitutes for stratospheric ozone -depleting substances (e.g., CFCs, HCFCs, and halons). The most prevalent fluorinated gases include the following:
▪ Hydrofluorocarbons: HFCs are compounds containing only hydrogen, fluorine, and carbon atoms. HFCs are synthetic chemicals used as alternatives to ozone-depleting substances in serving many industrial, commercial, and personal needs. HFCs are emitted as by-products of industrial processes and are used in manufacturing. ▪ Perfluorocarbons: PFCs are a group of human -made chemicals composed of carbon and fluorine only.
These chemicals were introduced as alternatives, with HFCs, to the ozone depleting substances. The two main sources of PFCs are primary aluminum production and semiconductor manufacturing. Since PFCs have stable molecular structures and do not break down through the chemical processes in the lower atmosphere, these chemicals have long lifetimes, ranging between 10,000 and 50,000 years. ▪ Sulfur Hexafluoride: SF6 is a colorless gas soluble in alcohol and ether and slightly soluble in water. SF6 is used for insulation in electric power transmission and distribution equipment, semiconductor manufacturing, the magnesium industry, and as a tracer gas for leak detection. ▪ Nitrogen Trifluoride: NF3 is used in the manufacture of a variety of electronics, including semiconductors and flat panel displays.
Chlorofluorocarbons (CFCs). CFCs are synthetic chemicals that have been used as cleaning solvents, refrigerants, and aerosol propellants. CFCs are chemically unreactive in the lower atmosphere (troposphere) and the production of CFCs was prohibited in 1987 due to the chemical destruction of stratospheric O3.
Hydrochlorofluorocarbons (HCFCs). HCFCs are a large group of compounds, whose structure is very close to that of CFCs—containing hydrogen, fluorine, chlorine, and carbon atoms—but including one or more hydrogen atoms. Like HFCs, HCFCs are used in refrigerants and propellants. HCFCs were also used in place of CFCs for some applications; however, their use in general is being phased out.
Black Carbon. Black carbon is a component of fine particulate matter, which has been identified as a leading environmental risk factor for premature death. It is produced from the incomplete combustion of fossil fuels and biomass burning, particularly from older diesel engines and forest fires. Black carbon warms the atmosphere by absorbing solar radiation, influences cloud formation, and darkens the surface of snow and ice, which accelerates heat absorption and melting. Black carbon is a short -lived species that varies spatially, which makes it difficult to quantify the GWP. Diesel particulate matter emissions are a major source of black carbon and are toxic air contaminates (TACs) that have been regulated and controlled in California for several decades to protect public health. In relation to declining diesel particulate matter from CARB’s regulations pertaining to diesel engines, diesel
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fuels, and burning activities, CARB estimates that annual black carbon emissions in California have reduced by 70% between 1990 and 2010, with 95% control expected by 2020 (CARB 2014a).
Water Vapor. The primary source of water vapor is evaporation from the ocean, with additional vapor generated by sublimation (change from solid to gas) from ice and snow, evaporation from other water bodies, and transpiration from plant leaves. Water vapor is the most important, abundant, and variable GHG in the atmosphere and maintains a climate necessary for life.
Ozone (O3). Tropospheric O3, which is created by photochemical reactions involving gases from both natural sources and human activities, acts as a GHG. Stratospheric O3, which is created by the interaction between solar ultraviolet radiation and molecular oxygen (O 2), plays a decisive role in the stratospheric radiative balance. Depletion of stratospheric O 3, due to chemical reactions that may be enhanced by climate change, results in an increased ground-level flux of ultraviolet-B radiation.
Aerosols. Aerosols are suspensions of particulate matter in a gas emitted into the air through burning biomass (plant material) and fossil fuels. Aerosols can warm the atmosphere by absorbing and emitting heat and can cool the atmosphere by reflecting light.
5.7.1.2.3 Global Warming Potential
Gases in the atmosphere can contribute to climate change both directly and indirectly. Direct effects occur when the gas itself absorbs radiation. Indirect radiative forcing occurs when chemical transformations of the substance produce other GHGs, when a gas influences the atmospheric lifetimes of other gases, and/or when a gas affects atmospheric processes that alter the radiative balance of the Earth (e.g., affect cloud formation or albedo) (EPA 2023a). The IPCC developed the GWP concept to compare the ability of each GHG to trap heat in the atmosphere relative to another gas. The GWP of a GHG is defined as the ratio of the time -integrated radiative forcing from the instantaneous release of 1 kilogram of a trace substance relative to that of 1 kilogram of a reference gas (IPCC 2014). The reference gas used is CO 2; therefore, GWP -weighted emissions are measured in metric tons CO 2 equivalent (MT CO2e).
The current version of the CalEEMod (version 2022) assumes that the GWP for CH4 is 25 (so emissions of 1 MT of CH4 are equivalent to emissions of 25 MT of CO 2), and the GWP for N 2O is 298, based on the IPCC Fourth Assessment Report (IPCC 2007). The GWP values identified in CalEEMod were applied to the project.
5.7.1.2.4 Sources of Greenhouse Gas Emissions
Global Inventory
Anthropogenic GHG emissions worldwide in 2020 (the most recent year for which data is available) totaled approximately 49,800 MMT of CO2e, excluding land use change and forestry (PBL 2022). The top six GHG emitters include China, the United States, the Russian Federation, India, Japan, and the European Union, which accounted for approximately 60% of the total global emissions, or approximately 30,270 MMT CO2e (PBL 2022). Table 5.7-1 presents the top GHG-emissions-producing entities.
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unprecedented over decades to millennia. Signs that global climate change has occurred include warming of the atmosphere and ocean, diminished amounts of snow and ice, and rising sea levels (IPCC 2014).
In California, climate change impacts have the potential to affect sea -level rise, agriculture, snowpack and water supply, forestry, wildfire risk, public health, frequency of severe weather events, and electricity demand and supply.
The primary effect of global climate change has been a rise in average global tropospheric temperature. Reflecting the long-term warming trend since pre-industrial times, observed global mean surface temperature for the decade 2006–2015 was 0.87°C (1.6°F) (likely between 0.75 °C [1.4°F] and 0.99°C [1.8°F]) higher than the average over the 1850–1900 period (IPCC 2018). Scientific modeling predicts that continued emissions of GHGs at or above current rates would induce more extreme climate changes during the twenty-first century than were observed during the twentieth century. Human activities are estimated to have caused approximately 1.0°C (1.8°F) of global warming above pre-industrial levels, with a likely range of 0.8 °C to 1.2 °C (1.4°F to 2.2 °F) (IPCC 2018). Global warming is likely to reach 1.5°C (2.7°F) between 2030 and 2052 if it continues to increase at the current rate (IPCC 2018).
Although climate change is driven by global atmospheric conditions, climate change impacts are felt locally. A scientific consensus confirms that climate change is already affecting California. The Office of Environmental Health Hazard Assessment identifie d various indicators of climate change in California, which are scientifically based measurements that track trends in various aspects of climate change. Many indicators reveal discernible evidence that climate change is occurring in California and is having significant, measurable impacts in the state. Changes in the state’s climate have been observed, including an increase in annual average air temperature with record warmth from 2012 to 2016, more frequent extreme heat events, more extreme drought, a decline in winter chill, an increase in cooling degree days and a decrease in heating degree days, and an increase in variability of statewide precipitation (OEHHA 2018).
Warming temperatures and changing precipitation patterns have altered California’s physical systems—the ocean, lakes, rivers, and snowpack—upon which the state depends. Winter snowpack and spring snowmelt runoff from the Sierra Nevada and southern Cascade Mountains provide approximately one-third of the state’s annual water supply.
Impacts of climate on physical systems have been observed such as high variability of snow -water content (i.e., amount of water stored in snowpack), decrease in snowmelt runoff, glacier change (loss in area), rise in sea levels, increase in average lake water temperature and coastal ocean temperature, and a decrease in dissolved oxygen in coastal waters (OEHHA 2018).
Impacts of climate change on biological systems, including humans, wildlife, and vegetation, have also been observed, including climate change impacts on terrestrial, marine, and freshwater ecosystems. As with global observations, species responses include those consistent with warming: elevational or latitudinal shifts in range, changes in the timing of key plant and animal life cycle events, and changes in the abundance of species and in community composition. Humans are better able to adapt to a changing climate than plants and animals in natural ecosystems. Nevertheless, climate change poses a threat to public health as warming temperatures and changes in precipitation can affect vector -borne pathogen transmission and disease patterns in California as we ll as the variability of heat-related deaths and illnesses. In addition, since 1950, the area burned by wildfires each year has followed an increasing trend overall.
CNRA has released four California Climate Change Assessments (in 2006, 2009, 2012, and 2018), which have addressed the following: acceleration of warming across the state, more intense and frequent heat waves, greater riverine flows, accelerating sea level rise, more intense and frequent drought, more severe and frequent wildfires, more severe storms and extreme weath er events, shrinking snowpack and less overall precipitation, and ocean acidification, hypoxia, and warming. To address local and regional gov ernments’ need for information to support
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action in their communities, the Fourth Assessment (CNRA 2018) includes reports for nine regions of the state. Key highlights for the San Diego Region include the following (CNRA 2019):
▪ Temperature is projected to increase substantially, along with mean temperature, heat wave frequency will increase, with more intensity and longer duration.
▪ Precipitation will remain highly variable but will change in character, with wetter winters, drier springs, and more frequent and severe droughts punctuated by more intense individual precipitation events. ▪ Wildfire risk will increase in the future as climate warms. The risk for large catastrophic wildfires driven by Santa Ana wind events will also likely increase as a result of a drier autumns leading to low antecedent precipitation before the height of the Santa Ana wind season.
The sea level along San Diego County is expected to rise. High tides combined with elevated shoreline water levels produced by locally and distantly driven wind-driven waves will drive extreme events. Longer-term sea level rise will increase rapidly in the second half of the century and will be punctuated by short periods of storm-driven extreme sea levels that will imperil existing infrastructure, structures, and ecosystems with increasing frequency.
5.7.2 Thresholds of Significance
The significance criteria used to evaluate the project’s GHG emissions impacts is based on the recommendations provided in Appendix G of the CEQA Guidelines. For the purposes of this GHG emissions analysis, the project would have a significant environmental impact if it would (14 CCR 15000 et seq.):
Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs?
Global climate change is a cumulative impact; a project participates in this potential impact through its incremental contribution combined with the cumulative increase of all other sources of GHGs. There are currently no established thresholds for assessi ng whether the GHG emissions of a project, such as the project, would be considered a cumulatively considerable contribution to global climate change; however, all reasonable efforts should be made to minimize a project’s contribution to global climate cha nge. In addition, while GHG impacts are recognized exclusively as cumulative impacts (CAPCOA 2008) , GHG emissions impacts must also be evaluated on a project-level under CEQA.
With respect to GHG emissions, the CEQA Guidelines Section 15064.4(a) states that lead agencies “shall make a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate” GHG emissions resulting from a project. The CEQA Guidelines note that an agency has the discretion to either quantify a project’s GHG emissions or rely on a “qualitative analysis or performance -based standards” (14 CCR 15064.4[a]). A lead agency may use a “model or methodology” to estimate GHG emissions and has the discretion to select the model or methodology it considers “most appropriate to enable decision makers to intelligently take into account the project’s incremental contribution to climate change” (14 CCR 15064.4[c]). The CEQA Guidelines provide that the lead agency should consider the following when determining the significance of impacts from GHG emissions on the environment (14 CCR 15064.4[b]):
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The extent a project may increase or reduce GHG emissions as compared to the existing environmental setting.
Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.
The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.
In addition, the CEQA Guidelines specify that “[w]hen adopting or using thresholds of significance, a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies, or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence” (14 CCR 15064.7[c]).
The extent to which a project increases or decreases GHG emissions in the existing environmental setting should be estimated in accordance with Section 15064.4, Determining the Significance of Impacts from Greenhouse Gas Emissions, of the State CEQA Guidelines. The State CEQA Guidelines indicate that when calculating GHG emissions resulting from a project, lead agencies shall make a good -faith effort based on scientific and factual data (Section 15064.4 (a)), and lead agencies have discretion to select the model or methodology deemed most appropriate for enabling decision makers to intelligently assess the project’s incremental contribution to climate change (Section 15064.4 (c)).
The State CEQA Guidelines do not indicate an amount of GHG emissions that constitutes a significant impact on the environment. Instead, they authorize the lead agency to consider thresholds of significance previously adopted or recommended by other public agencies or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence (State CEQA Guidelines Sections 15064.4(a) and 15064.7(c)).
Governor’s Office of Planning and Research Guidance
The Governor’s Office of Planning and Research technical advisory titled, CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA) Review, states that “public agencies are encouraged but not required to adopt thresholds of significance for environmental impacts. Even in the absence of clearly defined thresholds for GHG emissions, the law requires that such emissions from CEQA projects must be disclosed and mitigated to the extent feasible whenever the lead agency determines that the project contributes to a significant, cumulative climate change impact” (OPR 2008). Furthermore, the advisory document indicates that “in the absence of regulatory standards for GHG emissions or other scientific data to clearly define what constitutes a ‘significant impact,’ individual lead agencies may undertake a project-by-project analysis, consistent with available guidance and current CEQA practice” (OPR 2008).
SCAQMD Guidance
In October 2008, the South Coast Air Quality Management District (SCAQMD) proposed recommended numeric CEQA significance thresholds for GHG emissions for lead agencies to use in assessing GHG impacts of residential and commercial development projects as presented in its Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold (SCAQMD 2008). This guidance document, which builds on the previous guidance prepared by the California Air Pollution Control Officers Association, explored various approaches for establishing a significance threshold for GHG emissions. The draft interim CEQA thresholds guidance document was not adopted or approved by the Governing Board. However, in December 2008, the SCAQMD adopted an interim 10,000 MT
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CO2e per-year screening level threshold for stationary source/industrial projects for which the SCAQMD is the lead agency (see SCAQMD Resolution No. 08-35, December 5, 2008).
The SCAQMD formed a GHG CEQA Significance Threshold Working Group to work with SCAQMD staff on developing GHG CEQA significance thresholds until statewide significance thresholds or guidelines are established. From December 2008 to September 2010, the SCAQMD hosted working group meetings and revised the draft threshold proposal several times, although it did not officially provide these proposals in a subsequent document. The SCAQMD has continued to consider adoption of significance thresholds for residenti al and general land use development projects. The most recent proposal, issued in September 2010 proposed the use of 3,000 MT CO 2e per year for mixed-use projects.
In the absence of an adopted numerical threshold for the project region or by SCAQMD, the significance of the project- related GHG emissions can be determined by evaluating the project’s compliance with regulations or requirements adopted to implement statewide, regional, or local plans for the reduction or mitigation of GHG emissions.
Approach to Determining Significance
Given that neither the City, nor CARB, San Diego Air Pollution Control District , nor SCAQMD have adopted a numerical threshold of significance for GHG emissions within the City or region, the approach for evaluating the project’s impacts related to GHG emissions relies on compliance with applicable plans, policies, or regulations adopted for the purposed of reducing the emissions of GHGs. The compliance evaluation is the sole basis for determining the significance of the project’s GHG-related impacts on the environment.
The significance of the project’s GHG impacts is based on the project’s compliance with statewide GHG reduction regulations and requirements. At the state level, guidance on reduction strategies for GHG emissions has been provided through the CARB Scoping Plans and at the local level through the SANDAG’s RTP/SCS and the City’s CAP and General Plan. Although the City’s most recent CAP adopted in 2017 is not qualified for tiering per CEQA Guidelines Section 15183.5, a project’s potential to conflict with the CAP is evaluated in the context of ensuring the project does not conflict with broad regional and state goals.
The Scoping Plan (approved by CARB in 2008 and updated in 2014, 2017, and 2022) provides a framework for actions to reduce California’s GHG emissions and requires CARB and other state agencies to adopt regulations and other initiatives to reduce GHGs. As d iscussed above, 2030 marks the next statutory statewide milestone target applicable to the proposed project. Given that the 2017 Scoping Plan is the Update developed for identifying how the state will achieve the 2030 reduction target, it is the most relevant plan for evaluating the project’s consistency with statewide GHG emission reduction strategies. The Scoping Plan is not directly applicable to specific projects, nor is it intended to be used for project-level evaluations.5 Under the Scoping Plan, however, there are several state regulatory measures aimed at the identification and reduction of GHG emissions. CARB and other state agencies have adopted many of the measures identified in the Scoping Plan. Most of these measures focus on area source emissions (e.g., energy usage, high-GWP GHGs in consumer products) and changes to the vehicle fleet (i.e., hybrid, electric, and more fuel-efficient vehicles) and associated fuels (e.g., Low Carbon Fuel Standard), among others.
5 The Final Statement of Reasons for the amendments to the State CEQA Guidelines reiterates the statement in the Initial Statement of Reasons that “[t]he Scoping Plan may not be appropriate for use in determining the significance of individual projects because it is conceptual at this stage and relies on the future development of regulations to implement the strategies identified in the Scoping Plan” (CNRA 2009a).
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CARB’s 2017 Scoping Plan specifically emphasizes the importance of reducing vehicle miles traveled (VMT) of on- road vehicles to lower mobile -source GHG emissions to achieve statewide reduction targets. The 2017 Scoping Plan recommends a 15% reduction in total light-duty VMT from the business-as-usual scenario in 2050 in alignment with the Mobile Source Strategy (CARB 2017 and CARB 2021). CARB analysis on the relationship of VMT reductions to state climate goals found that certain land use development projec ts that have total VMT per capita of 14.3% lower than existing conditions, and light -duty VMT per capita of 16.8% lower than existing conditions could be considered consistent with transportation assumptions assumed for the 2017 Scoping Plan and with the s tate’s long-term (i.e., 2050) GHG reduction goals (CARB 2019). Per Section 15064.3 of the revised (2022) CEQA Guidelines, VMT is the most appropriate measure of transportation impacts, and is defined as the amount and distance of automobile traffic attributable to a project. This methodology is consistent with the guidance provided in OPR’s Technical Advisory on Evaluating Transportation Impacts in CEQA, which assists with making significance determinations for transportation impacts in accordance with SB 743. Per the CEQA Gui delines, VMT is the most appropriate metric to ensure that transportation impacts from project-level environmental review under CEQA align with the state’s long-term GHG reduction goals (OPR 2018).
CARB adopted the 2022 Scoping Plan Update in May 2022 to discuss progress toward reaching the 2030 target and to address how the state will achieve carbon neutrality by 2045, as required by EO B -55-18. As the official guidance on approach to reaching the 2045 statewide goal, consideration of the 2 022 Plan is considered appropriate for evaluation of GHG emission impacts of the proposed Project.
In the 2022 Plan, CARB builds on and accelerates programs already in place to reduce anthropogenic sources of GHG emissions and introduces new strategies to capture and store carbon. Appendix D: Local Actions of the Draft Plan outlines local actions that residential and mixed-use projects can implement to address their largest sources of emissions including transportation electrification, VMT reduction, and building decarbonization. CARB identifies these three sources as “Priority Areas” given that they rep resent those with the highest GHG reduction potential and GHG reduction opportunities for which local governments and agencies have the most authority (CARB 2022a).
Importantly, the 2022 Update emphasizes that there is no realistic path to reaching the 2045 goal of carbon neutrality without removing and sequestering carbon from the atmosphere. So, in addition to programs that aim to reduce GHG emissions, the Draft Plan proposes strategies to capture and store carbon, highlighting the importance of nature-based solutions through preservation and climate smart management of the state’s natural and working lands (NWLs). Modeling conducted for the Draft Scoping Plan shows that California’s NWLs are projected to be a net source of emissions (i.e., releasing more CO2 emissions than they store) through 2045, which is historically due to human activities, such as land use change, and natural disturbances, such as wildfire. Therefore, the ability of the state’s NWLs to act as a net sink (i.e., sequester and store more at mospheric CO2 than they release) to help support the state’s carbon neutrality goals is dependent on climate smart land management.
If the project does not conflict with the regulations and actions outlined in the applicable state plans (i.e., 2022 Scoping Plan, and local plans (i.e., SANDAG RTP/SCS and City’s CAP and General Plan), the Project could appropriately rely on their use as showing compliance with performance -based standards adopted to fulfill the statewide goal for reducing GHG emissions. The project’s compliance with regulatory programs adopted by CARB, and other state and local agencies is therefore used to evaluate the significance of the project’s GHG emissions.
Nevertheless, and in accordance with Section 15064.4 of the State CEQA Guidelines, GHG emissions resulting from construction and operation of the project were quantitatively estimated in Section 5.7.3.7. The project site consists of developed land occupied by the former Rohr Aircraft Facility and includes several industrial buildings historically used for manufacturing, warehousing, research and development, and related office uses . The potential impacts
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from project related GHG emissions were assessed based on the increase in GHG emissions from the project by subtracting emissions from the existing land use s that were in operation up until 2020 and form the baseline conditions. The City’s GHG inventories use 1990, 2005, and 2012 as recent inventory dates. The 2021 SANDAG RTP/SCS uses 2016 as a baseline year. CARB’s Scoping Plan is based on reducing 1990 emissions 40% by 2030.
The GHG emissions associated with implementation of the project were estimated us ing industry standard and accepted software tools, techniques, and emissions factors, as described below for construction and operation.
Estimation of emissions is for informational purposes only, for comparison with existing environmental conditions.
Approach and Methodology
Calculations for construction and operation were based on the assumptions and methodology contained in Appendix C: Air Quality and Greenhouse Gas Emissions Technical Report Rohr Wohl Specific Plan Project, City of Chula Vista, California, specifically Appendix C Section 2.3.3 and Section 3.3.2.
Construction
CalEEMod Version 2022.1 was used to estimate potential project generated GHG emissions during construction.
Construction of the project would result in GHG emissions primarily associated with use of off -road construction equipment, on-road hauling, and vendor (material delivery) trucks, and worker vehicles. All details for construction criteria air pollutants discussed in Appendix C, Table 3 -9 and Section 5.2, Air Quality, are also applicable for the estimation of construction related GHG emissions. As such , see Section 5.2, Air Quality for a discussion of construction emissions calculation methodology and assumptions. Planning Area A is already built-out and is only requiring rezoning. Accordingly, no construction emissions for Planning Area A have been estimated and included in the analysis.
Operation
As with the air quality analysis, emissions from the operational phase of the project were estimated primarily using CalEEMod Version 2022.1 . All details for operational criteria air pollutants discussed in Appendix C, Table 3-10 and Section 5.2 Air Quality, are also applicable for the estimation of operation -related GHG emissions. An operational year of 2030 was assumed consistent with completion of project construction. Because there are existing uses on the project site those emissions were subtracted fr om the project’s emissions to arrive at the net increase in GHG emissions.
Area Sources
CalEEMod was used to estimate operational GHG emissions from area sources, such as landscape maintenance equipment (see Appendix C Section 2.3.3 and Section 3.3.2 for details). Emissions associated with natural gas usage in space heating and water heating are calculated in the building energy use module of CalEEMod, as described in the following text.
Landscape maintenance includes fuel combustion emissions from equipment such as lawn mowers, rototillers, shredders/grinders, blowers, trimmers, chain saws, and hedge trimmers. The emissions associated from landscape equipment use are estimated based on Ca lEEMod default values for emission factors (grams per square foot of nonresidential building space per day) and number of summer days (when landscape maintenance would generally be performed) and winter days. For San Diego County, the average annual “summe r” days are estimated to 365
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days; however, it is assumed that landscaping equipment would likely only operate during the week (not weekends), so operational days were assumed to be 180 days per year in CalEEMod (CAPCOA 2022).
Energy Sources
As represented in CalEEMod, energy sources include emissions associated with building electricity and natural gas usage (non-hearth). Electricity use would contribute indirectly to GHGs, since GHG emissions occur at the site of the power plant, which is typically off site. Annual natural gas (non -hearth) and electricity emissions were estimated in CalEEMod using the emission factors for San Diego Gas and Electric Company (SDG&E), which would be the energy source provider for the Project. SDG&E receives electric power from a variety of sources (see Appendix C Section 2.3.3 and Section 3.3.2). In 2021, 44.5% of SDG&E’s power mix came from eligible renewable energy sources, including biomass/waste, geothermal, solar, and wind sources (SDG&E 2022).
In CalEEMod 2022, the default energy use from nonresidential land uses is based on 2019 consumption estimates from the CEC’s 2018-2030 Uncalibrated Commercial Sector Forecast (Commercial Forecast), and the energy use from residential land uses is based on the 2019 Residential Appliance Saturation Survey (RASS). The Commercial Forecast and RASS datasets derive energy intensities of different end use categories for different land use subtypes for electricity demand forecast zones throughout the state. However, the energy use estimates are based on existing buildings and residences and are not representative of those constructed in compliance with energy efficiency requirements of the latest Title 24 Building Energy Efficiency Standards (e.g., the average resid ence surveyed in the RASS was constructed in 1974). Therefore, per Appendix D , Technical Source Documentation for Emissions Calculations, of the CalEEMod Version 2022.1 User Guide, “the default energy consumption estimates provided in CalEEMod based on the Commercial Forecast and RASS are very conservative, overestimating expected energy use compared to what would be expected for new buildings subject to the latest Energy Code with more stringent energy efficiency measures” (CAPCOA 2022).
Because the project may include refrigerated uses in the future, the industrial business park with commercial land uses were modeled with the energy estimates for a refrigerated warehouse, which represented a higher amount of energy use.
Mobile Sources
All details for criteria air pollutants discussed in Appendix C Section 2.3.3 and Section 3.3.2 and Section 5.2, Air Quality (Approach and Methodology, Operations subsection), are also applicable for the estimation of operational- related GHG emissions are also applicable for the estimation of operational mobile source GHG emissions.
Regulatory measures related to mobile sources include AB 1493 (Pavley) and related federal standards. AB 1493 required that CARB establish GHG emission standards for automobiles , light-duty trucks, and other vehicles that are primarily used for noncommercial personal transportation in the state. In addition, the NHTSA and EPA have established corporate fuel economy standards and GHG emission standards, respectively, for automobil es and light, medium, and heavy-duty vehicles. Implementation of these standards and fleet turnover (replacement of older vehicles with newer ones) will gradually reduce emissions from the Project’s motor vehicles. The effectiveness of fuel economy improvements was evaluated using the CalEEMod emission factors for motor vehicles in 2028 to the extent it was captured in CalEEMod 2022.1 which is based on EMFAC2021.
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Water and Wastewater
Supply, conveyance, treatment, and distribution of water for the project require the use of electricity, which would result in associated indirect GHG emissions. Similarly, wastewater generated by the project requires the use of electricity for conveyance and treatment, along with GHG emissions generated during wastewater treatment. The GHG emissions associated with Project water consumption were estimated using CalEEMod defaults. (see Appendix C, Section 2.3.3 and Section 3.3.2)
Solid Waste
The project would generate solid waste, and therefore, result in CO2e emissions associated with landfill off-gassing.
CalEEMod default values for solid waste generation were used to estimate GHG emissions associated with solid waste. (see Appendix C Section 2.3.3 and Section 3.3.2 for details) Refrigerants
Refrigerants are substances used in the equipment for air conditioning (A/C) and refrigeration. Most of the refrigerants used today are HFCs or blends thereof, which can have high GWP values. All equipment that uses refrigerants has a charge size (i.e. qua ntity of refrigerant the equipment contains) and an operational refrigerant leak rate, and each refrigerant has a GWP that is specific to that refrigerant. CalEEMod quantifies refrigerant emissions from leaks during regular operation and routine servicing over the equipment lifetime, and then derives average annual emissions from the lifetime estimates.
Refrigerant emissions are associated with buildings and mobile sources primarily from A/C usage.
As noted previously, the project may include refrigerated uses in the future, as such the industrial business park with commercial land uses were modeled as refrigerated warehouses to account for additional refrigerant . (see Appendix C Section 2.3.3 and Section 3.3.2 for details)
5.7.3 Impacts
Is should be noted that case law (North County Advocates v. City of Carlsbad (2015) 241 Cal.App.4th 94, 105-106) allows a credit for existing uses and structures, even when not currently in operation; however, to be conservative the following analysis does not take existing uses into consideration.
Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment, or would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases? As discussed previously, the project’s compliance with regulatory programs adopted by CARB, and other state and local agencies is used to evaluate the significance of the project’s GHG emissions. The project’s potential to conflict with applicable GHG reduction plans is evaluated below.
5.7.3.1 Project Potential to Conflict with the City’s Climate Action Plan The City’s most recent CAP adopted in 2017 identified new goals and policies to strengthen the City’s past climate action planning efforts. While the CAP is not qualified for tiering per CEQA Guidelines Section 15183.5, a project’s potential to conflict with the CAP is evaluated in context of ensuring the project does not conflict with broad regional
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5.7.5 Mitigation Measures
No mitigation measures are required.
5.7.6 Level of Significance After Mitigation
The proposed project would result in less than significant impacts related to GHG emissions and no mitigation measures are required.
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5.8 Hazards and Hazardous Materials
The project site consists of 11 assessor parcels and is divided into three separate planning areas , including Planning Areas A, B-1, and B-2. The eastern portion of the project site, closest to I-5 (between G Street and H Street), is designated as Planning Area A and is 9.29 acres (Figure 4 -2, Site Plan). The largest planning area is Planning Area B-1, totaling 26.13 acres. Planning Area B-2, which is located south of B-1, totals 9.36 acres.
This section describes the existing hazardous materials conditions of the project site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the proposed pr oject. The information provided is based in part on the following documents, included as appendices to this environmental impact report (EIR). ▪ Appendix H-1 Phase I Environmental Site Assessment, Parcel A and Land Parcels, completed by Partner Engineering and Science, Inc., March 2023
▪ Appendix H-2 Phase I Environmental Site Assessment, Parcel B – Rohr Inc., a Collins Aerospace Company, completed by Partner Engineering and Science, Inc., February 2021 ▪ Appendix H-3 Cleanup and Abatement Order No. R9-2021-0042, An Order Directing Rohr and Goodrich Corporation to Clean Up or Abate the Effects of Waste Discharged from the Rohr/Goodrich North Campus Property, Chula Vista, San Diego County, completed by San D iego Regional Water Quality Control Board, July 2021
5.8.1 Existing Conditions
5.8.1.1 Regulatory Framework
Federal
Federal Toxic Substances Control Act of 1976
The Federal Toxic Substances Control Act of 1976 tasked the U.S. Environmental Protection Agency (EPA) with authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures. The Federal Toxic Substances Control Act addresses the production, importation, use, and disposal of specific chemicals including polychlorinated biphenyls (PCBs), asbestos, radon, and lead-based paint.
Resource Conservation and Recovery Act
The objectives of the Resource Conservation and Recovery Act (RCRA) of 1976 are to protect human health and the environment from the potential hazards of waste disposal, conserve energy and natural resources, reduce the amount of waste generated, and ensure that wastes are managed in an environmentally sound manner. RCRA affirmed and extended the “cradle-to-grave” system of regulating hazardous wastes. The use of certain techniques for the disposal of some hazardous wastes was specifically prohibited by the Hazardous and Solid Waste Act. The Hazardous and Solid Waste Amendments of 1984 also added Subtitle I, which governs underground storage tanks.
Comprehensive Environmental Response, Compensation, and Liability Act The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) , commonly known as “Superfund,” was enacted by Congress on December 11, 1980. This law provided broad federal authority to
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respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment. CERCLA established requirements concerning closed and abandoned hazardous waste sites, provided for liability of persons responsible for releases of hazardous waste at these sites, and established a trust fund to provide for cleanup when no responsible party could be identified. CERCLA also enabled the revision of the National Contingency Plan , which provided the guidelines and pro cedures needed to respond to releases and threatened releases of hazardous substances, pollutants, or contaminants. The National Contingency Plan also established the National Priorities List, which is a list of contaminated sites warranting further investigation by EPA.
CERCLA was amended by the Superfund Amendments and Reauthorization Act on October 17, 1986.
Chemical Accident Prevention Provisions (Risk Management Plan) Code of Federal Regulations Title 40 Part 68, Chemical Accident Prevention Provisions, outlines the rules and requirements for regulated substances and thresholds of those substances. Owners and operators of stationary source1 facilities that store and handle over the threshold quantity of regulated substances, as identified in Table 1 of 40 CFR Section 68.130, List of Regulated Toxic Substances and Threshold Quantities for Accidental Release Prevention, are required to impleme nt accidental release prevention measures. This includes preparation of a Risk Management Plan (RMP), as described in 40 CFR Sections 68.150 through 68.185. The RMP would include management systems, hazards assessments, prevention programs, and emergency response procedures associated with the applicable regulated substances.
National Primary Drinking Water Regulations
The National Primary Drinking Water Regulations are legally enforceable primary standards and treatment techniques that apply to public water systems. Primary standards and treatment techniques protect public health by limiting the levels of contaminants in drinking water. The EPA sets legal limits on over 90 contaminants in drinking water. The legal limit for a contaminant (maximum contaminant level [MCL]} reflects the level that protects human health and that water systems can achieve using the best avail able technology. EPA rules also set water -testing schedules and methods that water systems must follow. The Safe Drinking Water Act gives individual states the opportunity to set and enforce their own drinking water standards if the standards are at a mini mum as stringent as EPA’s national standards.
Hazardous Materials Transportation Act
The U.S. Department of Transportation regulates hazardous materials transportation between states under the Code of Federal Regulations, Title 49, Chapter 1, Parts 100 –185. In California, the California Department of Transportation (Caltrans) and the Calif ornia Highway Patrol (CHP) enforce federal law related to the transport of hazardous materials. Together, these agencies determine driver training requirements, load labelling procedures, and specifications for container types.
Occupational Safety and Health Act
The Occupational Safety and Health Administration (OSHA) is responsible at the federal level for supporting worker safety. OSHA sets federal standards for implementing workplace training, exposure limits, and safety procedures
1 Stationary source is defined in 40 CFR 68.3, Definitions, and means any buildings, structures, equipment, installations, or substance emitting stationary activities which belong to the same industrial group, which are located on one or more contiguous properties, which are under the control of the same person (or persons under common control), and from which an accidental release may occur. See Chapter 5.2, Air Quality, for more information regarding stationary emission sources.
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for the handling of hazardous substances and hazardous materials (as well as other hazards). OSHA also establishes criteria by which each state can implement its own health and safety program.
Title 29 USC, Part 1926 et seq. requires employee training; personal protective equipment; safety equipment; and written procedures, programs, and plans for supporting worker safety when working with hazardous materials or in hazardous work environments during construction activities, including renovations and demolition projects and the handling, storage, and use of explosives. These standards also provide rules for the removal and disposal of asbestos, lead, lead-based paint, and other lead materials. Alt hough intended primarily to protect worker health and safety, these requirements also guide general facility safety. This regulation also requires that an engineering survey is prepared prior to demolition.
Title 29 USC, Part 1910 et seq. requires facilities that use, store, manufacture, handle, process, or move hazardous materials to conduct employee safety training; inventory safety equipment relevant to potential hazards; have knowledge on safety equipment use; prepare an illness prevention program; provide hazardous substance exposure warnings; prepare an emergency response plan; and prepare a fire prevention plan.
Universal Wastes
Title 40 USC, Chapter 1, Subchapter I, Part 273 governs the collection and management of widely generated waste, including batteries, pesticides, mercury -containing equipment, and bulbs. This regulation streamlines the hazardous waste management standards and allows that such waste is diverted to the appropriate treatment or recycling facility.
Oil Pollution Prevention
Oil Pollution Prevention regulations, Title 40 USC, Chapter 1, Subchapter D, Part 112, require the preparation of a spill prevention, control, and countermeasure (SPCC) Plan if oil is stored in excess of 10,000 gallons in aboveground storage (total on -site). SPCC regulations place restrictions on the management of petroleum materials and, therefore, have some bearing on hazardous materials management.
International Fire Code
The International Fire Code (IFC), created by the International Code Council, is the primary means for authorizing and enforcing procedures and mechanisms to support the safe handling and storage of any substance that may pose a threat to public health and safety. The IFC regulates the use, handling, and storage requirements for hazardous materials at fixed facilities. The IFC and the International Building Code use a hazard classification system to determine what measures are required to protect against structural fires. These measures may include construction standards, separations from property lines, and specialized equipment. To support that these safety measures are met, IFC employs a permit system based on hazard classification. The IFC is updated every 3 years.
Federal Response Plan
The Federal Response Plan of 1999 is a signed agreement among 27 federal departments and agencies, including the American Red Cross, that (1) provides the mechanism for coordinating delivery of federal assistance and resources to augment efforts of state and local governments overwhelmed b y a major disaster or emergency; (2) supports implementation of the Robert T. Stafford Disaster Relief and Emergency Act, as well as individual agency statutory authorities; and (3) supplements other federal emergency operations plans developed to address specific hazards. The Federal Response Plan is implemented in anticipation of a significant event likely to result in a need
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for federal assistance or in response to an actual event requiring federal assistance under a presidential declaration of a major disaster or emergency.
FEMA Hazard Mitigation Plan
Federal law (Disaster Management Act 2000) requires that, in order to remain eligible for post -disaster federal Emergency Management Agency (FEMA) funding after November 2004, every jurisdiction in the United States must have an approved Hazard Mitigation Plan (HAZMIT plan) to address the management of, and response to, emergency situations. In addition, to be eligible for pre -disaster FEMA funding for use in hazard mitigation, each jurisdiction's approved HAZMIT Plan must include the planned uses of those funds. The City of Chula Vista adopted a HAZMIT Plan in May 2004 (City of Chula Vista 2004) to help mitigate impacts to the City in the event of a natural or man-made disaster. The City's HAZMIT Plan was included in the San Diego County Multi -Jurisdictional HAZMIT Plan, submitted to FEMA for approval in compliance with federal law.
Federal Aviation Administration
The Federal Aviation Administration ( FAA) has primary responsibility for the safety of civil aviation. Title 14 USC, Chapter 1, Subchapter E, Part 77 establishes requirements for notifying the FAA of certain construction activities and alterations to existing structures, in order to ensure there are no obstructions to navigable airspace. For example, projects that include construction or alteration exceeding 200 f eet in height above ground level are required to notify the FAA.
International Wildland -Urban Interface Code
The International Wildland-Urban Interface Code establishes requirements for land use and the build environment within designated wildland-urban interface areas, using prescriptive and performance provisions. This code establishes minimum special regulations for the safeguarding of life and property from the intrusion of wildfire, including: 1) regulating ignition-resistant construction techniques and defensible space, as well as fire department access and available water supplies for fire suppression, 2) f ocusing on preventing ignition of buildings and vegetative fuels from direct exposure to wildfire and fire exposure from adjacent structures, and 3) helping prevent structure fires in the wildland -urban interface from spreading to wildland fuels, even in t he absence of fire department intervention.
State
Certified Unified Program
The California Environmental Protection Agency (CalEPA) implements and enforces a statewide hazardous materials program known as the Certified Unified Program, established by Senate Bill 1802 to consolidate, coordinate, and make consistent the administrative requirements, permits, inspections, and enforcement activities for the following environmental and emergency management programs for hazardous materials:
▪ Hazardous Materials Release Response Plans and Inventories (Hazardous Materials Business Plans) ▪ California Accidental Release Prevention Program
▪ Underground Storage Tank Program
▪ Aboveground Petroleum Storage Act Requirements for Spill Prevention, Control, and Countermeasure Plans ▪ Hazardous Waste Generator and On-Site Hazardous Waste Treatment Programs
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▪ California Uniform Fire Code, Hazardous Materials Management Plans, and Hazardous Material Inventory Statements
CalEPA certifies local government agencies as Certified Unified Program Agencies (CUPAs) to implement hazardous waste and materials standards. San Diego County Department of Environmental Health and Quality, Hazardous Materials Division, is designated as the local CUPA in Chula Vista and would facilitate hazardous material and hazardous waste permitting for the proposed project.
Title 19 CCR, Chapter 2, Subchapter 3, Sections 2729 -2734/California HSC Division 20, Chapter 6.95, Sections 25500-25520 requires the preparation of a hazardous materials business plan (HMBP) by facility operators. The HMBP identifies the hazards, storage locations, and storage quantities for each hazardous chemical stored on-site.
The HMBP is submitted to the CUPA for emergency planning purposes.
Cortese List
California Government Code Section 65962.5 requires that information regarding environmental impacts of hazardous substances and wastes be maintained and provided at least annually to the Secretary for Environmental Protection. Commonly referred to as the Cortese List, this information must include the following: sites impacted by hazardous wastes; public drinking water wells that contain detectable levels of contamination; underground storage tanks (USTs) with unauthorized releases; solid waste disposal facilities from which there is migration of hazardous wastes; and all cease and desist and cleanup and abatement orders. This information is maintained by various agencies, including the California Department of Toxic Substances Control (DTSC), the State Department of Health Services, State Water Resources Control Board (SWRCB), and the local CUPA. Each of the agencies has their own databases/records; thus, the Cortese List is not just a single list.
Regional Screening Levels
In California, the Department of Toxic Substances Control ( DTSC) Human and Ecological Risk Office (HERO) incorporated the EPA Regional Screening Levels (RSLs) into the HERO Human Health Risk Assessment (HHRA).
HERO created HHRA Note 3, which incorporates HERO recommendations and DTSC -modified screening levels based on review of the EPA RSLs. The DTSC-modified screening level should be used in conjunction with the EPA RSLs to evaluate chemical concentrations in environmental media at California sites and facilities.
Environmental Screening Levels
Environmental Screening Levels (ESLs) provide conservative screening levels for over 100 chemicals found at sites with contaminated soil and groundwater. ESLs are intended to help expedite the identification and evaluation of potential environmental concerns at contaminated sites. The ESLs were developed by the San Francisco Bay Regional Water Quality Control Board ( RWQCB); however, they are used throughout the state. While ESLs are not intended to establish policy or regulation, they can be used as a conservative screening level for sites with contamination. Other agencies in California currently use the ESLs (as opposed to RSLs). In general, the ESLs could be used at any site in the State of California, provided all stakeholders agree. Recently, regulatory agencies in various regions use ESLs as regulatory cleanup levels. The ESLs are not generally used at sites where the contamination is solely related to a leaking underground storage tanks; those sites are instead subject to the Low- Threat Underground Storage Tank Closure Policy.
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California Hazardous Waste Control Law
California Health and Safety Code Division 20, Chapter 6.5 establishes regulations to protect the public health and the environment by assisting generators of hazardous waste in meeting the responsibility for the safe disposal of hazardous waste. The Calif ornia Hazardous Waste Control Law is administered by CalEPA and pertains to administering a state hazardous waste program in lieu of the federal RCRA program, pursuant to Section 3006 of Public Law 94 -580, as amended. The Hazardous Waste Control Law lists 791 chemicals and approximately 300 common materials that may be hazardous; establishes criteria for identifying, packaging, and labeling hazardous wastes; prescribes management controls; establishes permit requirements for treatment, storage, disposal, and transportation; and identifies some wastes that cannot be disposed of in landfills.
Title 22 CCR, Division 4.5 denotes the DTSC regulates hazardous wastes. These regulations establish requirements for the management and disposal of hazardous waste in accordance with the provisions of the California Hazardous Waste Control Act and federal RCRA. As with federal requirements, waste generators must determine if their wastes are hazardous according to specified characteristics or lists of wastes. Hazardous waste generators must obtain identification numbers; prepare manifests before transportin g waste off -site; and use only permitted treatment, storage, and disposal facilities. Standards also include requirements for record-keeping, reporting, packaging, and labeling. Additionally, while not a federal requirement, California requires that hazardous waste be transported by registered hazardous waste transporters.
In addition, Chapter 31 of these regulations – Waste Minimization, Article 1 – Pollution Prevention and the Hazardous Waste Source Reduction and Management Review requires that generators of 12,000 kilograms/year of typical, operational hazardous waste eva luate their waste streams every four years and, as applicable, select and implement viable source reduction alternatives. This Act does not apply to non -typical hazardous waste, including asbestos-containing materials and PCBs, among others.
Unified Hazardous Waste and Hazardous Materials Management Regulatory Program The Unified Hazardous Waste and Hazardous Materials Management Regulatory Program was created in 1993 by Senate Bill 1082 to consolidate, coordinate, and make consistent the administrative requirements, permits, inspections, and enforcement activities of environmental and emergency management programs. The program is implemented at the local government level by CUPAs. The program consolidates, coordinates, and makes consistent the following hazardous materials and hazardous waste programs:
▪ Hazardous Waste Generation (including on-site treatment under Tiered Permitting) ▪ Aboveground Storage Tanks (only the spill prevention control and countermeasure plan) ▪ Underground Storage Tanks
▪ Hazardous Material Release Response Plans and Inventories ▪ California Accidental Release Prevention Program Uniform Fire Code Hazardous Material Management Plans and Inventories
California Accidental Release Prevention Program
Similar to the Federal Risk Management Program, the California Accidental Release Prevention Program includes additional state requirements and an additional list of regulated substances and thresholds. The regulations of the program are contained in CCR T itle 19, Division 2, Chapter 4.5. The intent of the California Accidental Release
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Prevention Program is to provide first responders with basic information necessary to prevent or mitigate damage to public health, safety, and the environment from the release or threatened release of hazardous materials.
The RMP, as described by the California Accidental Release Prevention Program , is required for any owner or operator of a stationary source that has more than a threshold quantity of regulated substances specified in Tables 1-3, CCR, Title 19 Section 2770.5.
California Health and Safety Code
The handling and storage of hazardous materials is regulated by Division 20, Chapter 6.95 of the California Health and Safety Code. Under Sections 25500–25543.3, facilities handling hazardous materials are required to prepare a HMBP that contains basic information on the location, type, quantity, and health risks of hazardous materials stored, used, or disposed of in the state.
Chapter 6.95 of the Health and Safety Code establishes minimum statewide standards for HMBPs. Each business shall prepare a HMBP if that business uses, handles, or stores a hazardous material (including hazardous waste) or an extremely hazardous material in quantities greater than or equal to 500 pounds of a solid substance , 55 gallons of a liquid, 200 cubic feet of compressed gas, a hazardous compressed gas in any amount (highly toxic with a Threshold Limit Value of 10 parts per million or less) , or extremely hazardous substances in threshold planning quantities. In addition, in the event that a facility stores quantities of specific acutely hazardous materials above the thresholds set forth by California code, facilities are also required to prepare a RMP and California Accidental Release Plan.
Aboveground Storage Tanks
Title 22 California HSC, Division 20, Chapter 6.67, Sections 25270 to 25270.13 applies if a facility is subject to SPCC regulations under Title 40 U.S.C. Part 112, or if the facility has 10,000 gallons or more of petroleum in any or combination of aboveground storage tanks (ASTs) and connecting pipes. If a facility exceeds these criteria, it must prepare a SPCC plan.
California Occupational Safety and Health Administration Hazard Handling Procedures The California Division of Occupational Safety and Health Administration (Cal/OSHA) is the primary agency responsible for worker safety in the handling and use of chemicals in the workplace. Cal/OSHA standards are generally more stringent than federal regulations. The employer is re quired to monitor worker exposure to listed hazardous substances and notify workers of exposure (8 CCR 337–340). The regulations specify requirements for employee training, availability of safety equipment, accident prevention pr ograms, and hazardous substance exposure warnings.
California Department of Transportation/California Highway Patrol The California DTSC administers the transportation of hazardous materials throughout the state. Regulations applicable to the transportation of hazardous waste include Title 22, Division 4.5, Chapter 13 and Chapter 29 of the CCR, as well as Division 20, Chapter 6.5, Articles 6.5, 6.6, and 13 of the California Health and Safety Code. The DTSC requires that drivers transporting hazardous wastes obtain a certificate of driver training that shows the driver has met the minimum requirements concerning the transport of hazardous materials, including proper labeling and
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marking procedures, loading/handling processes, incident reporting and emergency procedures, and appropriate driving and parking rules.
Under Title 13 CCR, Division 2, Chapter 6, California regulates the transportation of hazardous waste originating or passing through the state. The CHP and California Department of Transportation ( Caltrans) have primary responsibility for enforcing federal and state regulations and responding to hazardous materials transportation emergencies. CHP enforces materials and hazardous waste labeling and packing regulations that prevent leakage and spills of materi al in transit and provides detailed information to cleanup crews in the event of an incident.
Vehicle and equipment inspection, shipment preparation, container identification, and shipping documentation are all part of the responsibility of CHP. CHP conducts regular inspections of licensed transporters to support regulatory compliance. Caltrans has emergency chemical spill identification teams at locations throughout the state.
Hazardous waste must be regularly removed from generating sites by licensed hazardous waste transporters.
Transported materials must be accompanied by hazardous waste manifests.
California Disaster and Civil Defense Master Mutual Aid Agreement As provided for in the California Emergency Services Act, the California Disaster and Civil Defense Master Mutual Aid Agreement was developed in 1950 and adopted by all 58 California counties. This statewide mutual aid system is designed to ensure that ade quate resources, facilities, and other support is provided to jurisdictions whenever their own resources prove to be inadequate to cope with a given situation. San Diego County is located in Mutual Aid Region 6 of the state system, which also includes Imperial, Riverside, San Bernardino, Inyo, and Mono Counties (OES 2008).
Local
San Diego County Department of Environmental Health and Quality The San Diego County Department of Environmental Health and Quality serves to protect the environment and enhance public health by preventing disease, promoting environmental responsibility , and when necessary enforcing environmental and public health laws. Within the San Diego Department of Environmental Health and Quality , the Hazardous Materials Division protects human health and the environment by ensuring that hazardous materials, hazardous waste, medical waste and underground storage tanks are properly managed.
To accomplish this goal, the Hazardous Materials Division regulates facilities that handle or store hazardous materials, are part of the California Accidental Release Prevention Program, generate or treat hazardous wastes or medical waste, store at least 1 ,320 gallons of aboveground petroleum, and own or operate USTs.
Department of Environmental Health identifies disposal locations for household hazardous waste as well as scheduled household waste collection events .
San Diego Regional Water Quality Control Board
The San Diego RWQCB implements the California Water Code, which regulates waste discharges to land. If a discharge of waste threatens a water of the state, a report of waste discharge or an application for a waiver of a report of waste discharge must be filed with the RWQCB. The RWQCB accomplishes its permitting responsibility by issuing either a general or site-specific permit (Waste Discharge Permit), or a waiver of a permit.
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San Diego County Emergency Operations Plan
The San Diego County Emergency Operations Plan is a comprehensive emergency management system that provides for a planned response to disaster situations associated with natural disasters, technological incidents, and nuclear defense operations. The Emergency Plan includes operational concepts relating to various emergency situations, identifies components of the Emergency Management Organization , and describes the overall responsibilities for protecting life and property and assuring the overall well-being of the population. The plan also identifies the sources of outside support that might be provided (through mutual aid and specific statutory authorities) by other jurisdictions, state and federal agencies, and the private sector (County of San Diego and USDCESO 2022).
Wildland -Urban Interface Code
The City of Chula Vista adopted the International Wildland-Urban Interface Code in 1997, and subsequently in 2000, as part of Chula Vista Municipal Code, Chapter 15.38. The code was adopted as the urban-wildland interface code of the City for the purpose of prescribing regulations mitigating the hazard to life and property from intrusion of fire from wildland fire exposures, fire exposures from adjacent s tructures, and prevention of structure fires from spreading to wildland fires.
San Diego County Multi -Jurisdiction Hazard Mitigation Plan The San Diego County Multi-Jurisdiction Hazard Mitigation Plan was originally prepared in July 2010 and updated most recently in 2023 to meet federal and state requirements for disaster preparedness, as well as for the County to be eligible for funding and technical assistance from state and federal hazard mitigation programs. The plan includes a risk assessment to enable local jurisdictions to identify and prioritize appropriate mitigation actions to reduce losses from potential haz ards, including flooding, earthquakes, fires, and man -made hazards. To address potential hazards, the plan then incorporates mitigation goals and objectives, mitigation actions and priorities, an implementation plan, and documentation of the mitigation planning process for each of the 22 participating jurisdictions, including Chula Vista (County of San Diego 2023a).
Community Emergency Response Team Program
The City of Chula Vista provides a Community Emergency Response Team program that offers citizens training on how to respond to emergency situations effectively and efficiently , without placing themselves or others in unnecessary danger. Community Emergency Response Team training includes lessons on managing utilities, putting out small fires, providing basic emergency medical aid, searching for and rescuing victims safely, effectively organizing volunteers, and collecting disaster information to support first responders (City of Chula Vista 2023a).
Airport Land Use Compatibility Plan s
State law requires the San Diego County Airport Land Use Commission to prepare Airport Land Use Compatibility Plans (ALUCPs) for all public use and military airports in the County. The ALUCPs must be consistent with the safety and noise standards for military and civilian airports, and requires San Diego County Airport Land Use Commission review of land use plans and regulations, and other land use projects. The San Diego County Regional Airport Authority prepares ALUCPs for San Diego County. The proposed project site is not located within airport influence areas of the Naval Outlying Landing Field Imperial Beach (SDCRAA 2015) or Brown Field Airport (SDCRAA 2010) , located in nearby Imperial Beach and Otay Mesa, respectively.
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City of Chula Vista General Plan
Chapter 9, Environmental Element, Section 3.4, Hazardous Materials and Waste, of the City General Plan (City of Chula Vista 20 21) addresses hazardous materials related issues. Objectives and policies related to hazardous materials that pertain to the proposed project include the following:
Objective E17: Ensure the adequate remediation of contaminated sites as redevelopment occurs in order to protect public health and safety.
Policy E17.1: Clean contaminated sites to protective limits to ensure that planned future uses of such sites and public health and safety are not compromised.
Policy E17.2 : Prior to the redevelopment of contaminated sites, ensure adequate remediation in accordance with the recommendations of appropriate environmental assessments and consistent with all applicable regulations and standards.
Objective E18: Minimize the use of toxic products by residents and small businesses and facilitate the proper disposal of household hazardous waste.
Policy E18.1 : Provide convenient and affordable household hazardous waste collection facilities and services for residents and small businesses, including City facilities, community collection events, and curbside collection.
Policy E18.2 : Minimize the use of toxic products by residents and small businesses through public education on alternative products and methods.
Objective E20: Ensure that facilities using, storing, and handling hazardous materials and waste do not result in significant adverse effects to existing and planned surrounding land uses.
Policy E20.1: On a periodic basis, review and modify, where necessary, the City's zoning regulations to ensure that adequate provisions are in place to avoid adverse effects to surrounding land uses from facilities using, storing, and handling hazardous materials and waste.
Policy E20.2 : Through the environmental review of proposed developments, in accordance with the California Environmental Quality Act, the City shall ensure that significant and potentially significant adverse effects from facilities using, storing, and handling hazardous materials and waste to existing and planned surrounding land uses will be avoided.
Policy E20.3: Prior to the issuance or renewal of business licenses for businesses involving hazardous materials and/or generating hazardous waste, the City shall continue to require licensees to prepare and submit an acceptable Business Plan and Risk Management Prevent ion Program to the County Department of Environmental Health, as applicable, and to obtain all other necessary licenses and permits.
In addition, Chapter 8, Public Facilities and Services Element, Section 3.2.3, Emergency Response Program, and Section 3.2.4, Post Emergency Response, of the City General Plan (City of Chula Vista 20 21) address emergency
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response and disaster evacuation related issues. Objectives and policies related to these issues that pertain to the proposed project include the following:
Objective PFS7: Develop pre-disaster programs to ensure swift and efficient response to emergencies and disasters.
Policy PFS 7.1 : Implement a Citywide Emergency Response Plan to respond to local and regional emergencies, maintain and update it as needed to respond to changes in emergency response systems and threats to public safety. Identify minimum widths for the roads and for vege tation- clear areas for the identified evacuation routes.
Policy PFS 7.3: Educate the community about emergency preparedness and evacuation routes.
Policy PFS 7.4 : Prepare, maintain, and implement a current Hazard Mitigation Plan, in compliance with Federal law.
Policy PFS 7.5: When applicable and available, apply for Hazard Mitigation Grant Program funding from FEMA, with reference to the HAZMIT Plan.
Objective PFS8: Provide for the efficient and effective delivery of public health, safety, and welfare services in post-disaster situations.
Policy PFS 8.1 : Cooperate with local, state, and federal agencies, and with emergency response organizations such as the Red Cross, to ensure temporary housing for displaced residents following an emergency or disaster situation.
Policy PFS 8.2: Within six months of any area-wide disaster, analyze the response, the City-wide Emergency Response Plan, and the HAZMIT Plan, and propose revisions as needed.
Policy PFS 8.3 : Develop post-disaster development regulations to assist displaced residents to rebuild damaged and destroyed structures as expeditiously as possible.
Policy PFS 8.4: In the event of a disaster in Chula Vista, apply for and obtain Federal funding from FEMA, as applicable, to augment recovery efforts in the community.
5.8.1.2 Existing Setting
Historic Property Use
The project site consists of Planning Areas A, B-1, and B-2, as illustrated in Figure 5.8-1, Planning Areas. This portion of the Bayfront Planning Area is commonly referred to as the North Campus Property, which consists of developed land occupied by the former Rohr Aircraft Facility. The site is currently developed with one office building and two industrial buildings. One of the industrial buildings in Planning Area A, known as Building 29 (795 H Street), was used for research & development, tooling, and warehouse and distribution of aftermarket products until February 2021 (Figure 5.8-2, Former Site Uses). Planning Areas B-1 and B-2 were used for manufacturing operations, which ceased in approximately 2020. A 40-foot-wide San Diego Gas and Electric Company (SDG&E) right-of-way with an abandoned rail line and a 150- foot-wide SDG&E easement runs north–south through the project site. An SDG&E substation is also located on the north end of the project site. However, these latter two features are not part of the project.
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Prior to Rohr’s occupancy in 1941, the project site and adjacent areas had a variety of historical uses. In the 1920s, a business located within Planning Area B -1 (Figure 5.8-1) manufactured a cementitious material called Tycrete.
The facility included a rotary kiln, laboratory, and paint shop. Businesses occupied Planning Area A beginning in the early 1950s and included aircraft parts manufacturing, refrigeration unit repair, storage, junkyards, and a veterinary hospital. The off-site property immediately north of G Street was used for industrial purposes as early as 1918, when a magnesite ore processing company and aviation company occupied this area. In addition, where off-site Building 61 is currently located, the City of Chula Vista operated a sewage treatment plant from the late 1930s until the mid-1960s (Figure 5.8-2). Two settling ponds were present at the current location of Building 61 from about 1944 to 1959 and two settling ponds were located west of Building 61 around 1965. Treated effluent was discharged to San Diego Bay via an outfall. In 1960 -1962, the Unified Port of San Diego placed dredged fill from San Diego Bay along the historical shoreline on the western portions of Planning Areas B-1 and B-2, as well as the western portion of off-site Parcel C and the areas west of the site (Appendices H-1, H-2, and H-3).
Since 1941, structural and engine components for use in the aviation and aerospace industry have been manufactured within Planning Areas A, B-1, B-2, and offsite Parcel C. Historical environmental features that could be potential sources of chemicals beneath Parcel A included ASTs, USTs, paint booths, vapor degreasers, hydraulic equipment, and maintenance and storage areas (Figure 5.8-2). This equipment has been removed. Manufacturing operations in Planning Areas B-1 and B-2, which ceased approximately one year ago, included metal casting and fabrication, metal cutting, punching, bending, forming, anodizing, alodining and painting of metal parts, milling through the use of machining and chemical processes, tool and die casting and shaping, assembly, and storage.
Secondary activities that supported the manufacturing processes included maintenance and storage of vehicles, recycling of materials, hazardous materials storage in ASTs and USTs, and operation of an industrial wastewater treatment plant (Appendices H-1, H-2, and H-3).
Hazardous Material Sites
Chemicals stored and used on-site and immediately off-site during manufacturing operations have been found in the soil, soil gas, and groundwater as reported in environmental investigation reports and groundwater monitoring reports. The chemicals discharged include, but are not limited to, volatile organic compou nds (VOCs), metals, petroleum hydrocarbons, polycyclic aromatic hydrocarbons (PAHs), and polychlorinated biphenyls (PCBs) , all of which are considered chemicals of concern (COCs). The discharge of these COCs to the environment constitutes a discharge of waste, as defined in Water Code section 13050, subsection (d). In 1998, the San Diego RWQCB issued Cleanup and Abatement Order (CAO) No. 98-08 for the Rohr facility to abate discharges from its facility . CAO No. 98-08 includes directives to (1) conduct a site-wide environmental site assessment, (2) conduct a comprehensive storm water runoff sampling program, (3) conduct a comprehensive storm water conveyance system investigation, (4) perform a site-wide data compilation and evaluation, and (5) conduct interim remedial actions. The San Diego RWQCB subsequently issued CAO R9-2021-0042 in July 2021, which includes directives and timelines to remediate soil, soil gas, and groundwater at the property (Appendix H-3).
Soil Investigations
Soil investigations completed as part of the site -wide environmental site assessment concluded that COCs in the vadose-zone soil exceed the respective ESLs, which indicate they may leach into groundwater at concentrations impacting the municipal and domestic supply (MUN) beneficial use designation, as established by the San Diego RWQCB. Water quality objectives for MUN beneficial uses is the Maximum Contaminant Levels (MCLs), as specified in the EPA National Primary Drinking Water Regulations. Groundwater is present at a depth of approximately 20 to 35 feet beneath Planning Area A, and 2 to 10 feet beneath Planning Areas B-1 and B-2 (Appendices H-1 and H-2).
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In addition to groundwater impacts, COCs in soil in excess of ESLs may pose a c ancer risk and noncancer hazard to commercial/industrial and construction workers via ingestion, inhalation, and dermal exposures (Appendix H-3).
In addition, sampling to evaluate the potential presence of PFAS in soil was also conducted in 2021 in areas of historical features/operations where these chemicals may have been used. PFAS were not reported in the soil samples at detectable concentrations.
Groundwater Investigations
Groundwater investigations at the project site have identified the presence of COCs within the three water-bearing zones at the Site:
▪ Zone A – extends to a depth of approximately 25 feet below ground surface ( bgs), which generally corresponds to the artificial fill and Bay Deposits.
▪ Upper Zone B – extends approximately 25 to 55 feet bgs, which generally refers to the upper portion of the Bay Point Formation.
▪ Lower Zone B – extends approximately 55 to 125 feet bgs , which generally refers to the lower portion of the Bay Point Formation.
The concentrations of these COCs exceed the (1) MCLs, which indicate they are impacting the MUN beneficial use in the three zones, and (2) vapor intrusion ESLs, which indicate they may pose a potential vapor intrusion risk to current and future building occupants (Appendices H-2 and H-3).
Groundwater is impacted by the chlorinated solvents to a depth of about 100 feet. The groundwater in this interval is not suitable for drinking as it has high mineralization and salinity. This sequence of soil is also not very permeable.
An approximately 20-foot thick clay layer separates impacted groundwater from deeper formations. Potable water is present in a deeper aquifer (approximately 700 feet bgs and deeper) known as the San Diego Formation (Haley & Aldrich, personal communication).
Soil Gas Investigations
Soil gas investigations were conducted at Building 29 in Planning Area A (Figure 5.8 -2), in May 2018 and August 2020, and in Planning Area B-1 and B-2 in September 2019. These investigations assessed the presence of COCs in soil gas beneath building slabs and hardscape. The concentrations of certain VOCs exceeded the respective soil gas ESLs, which indicate they may pose a potential vapor intrusion risk to future building occupants (Appendix H-3).
Cleanup Levels Pursuant to Resolution No. 92 -49
SWRCB Resolution No. 92 -49, Policies and Procedures for Investigation, and Cleanup and Abatement of Discharges, under Water Code Section 13304, sets forth the policies and procedures used during an investigation or cleanup of a discharge of waste and requires that cleanup levels be consistent with SWRCB Resolution No. 68- 16, Statement of Policy with Respect to Maintaining High Quality of Waters in California . Resolution No. 92 -49 applies to the cleanup and abatement of the effects of waste discharged at the project site (Appendix H-3).
Resolution No. 92 -49 requires that Dischargers clean up or abate the effects of discharges in a manner that promotes the attainment of background water quality, or the best water quality that is reasonable if background water quality cannot be restored, considering all demands being made and to be made on those waters and the
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total values involved, beneficial and detrimental, economic and social, tangible and intangible. Any alternative cleanup level greater than background must (1) be consistent with the maximum benefit to the people of the state; (2) not unreasonably affect present and anticipated beneficial use of waters of the state; and (3) not result in water quality less than that prescribed in the Basin Plan and applicable Water Quality Control Plans and Policies of the SWRCB (Appendix H-3).
Site Cleanup or Abatement Orders
In addition to SWRCB Resolution No. 92-49, in accordance with CAO Nos. 98-08 and R9-2021-0042, the property waste Dischargers must take all corrective actions necessary to clean up or abate the effects of the discharges to soil, soil gas, and groundwater at the site, including:
Wastes in soil at the site must be cleaned up or abated in a manner that promotes attainment of background concentrations or alternative cleanup levels in groundwater and protects human health.
Wastes in groundwater at the site must be cleaned up or abated in a manner that attains background concentrations or alternative cleanup levels approved by the San Diego RWQCB.
Wastes in groundwater at the point -of-compliance wells located along San Diego Bay and Chula Vista Marina shorelines must be cleaned up or abated in a manner that attains (a) background concentrations in groundwater or (b) California Toxic Rule water quality standards for human ingestion of water/seafood and risk-based concentrations protective of aquatic receptors.
Wastes in soil gas at the site caused by soil and/or groundwater contamination must be cleaned up or abated in a manner that protects human health.
In addition, in compliance with the CAOs, the Discharger must complete additional conceptual site models, site data investigation reports, HHRAs, remedial action plans, site groundwater cleanup levels report, and groundwater monitoring program (Appendix H-3).
Site Feasibility Study for Cleanup to Background Levels The first four directives issued under CAO No. 98-08 pertaining to site investigations (listed above) are complete.
Interim remedial actions are currently underway at the off-property area (to the west) known as Parcel H-3, pursuant to CAO No. 98-08. Pursuant to Resolution No. 92-49, Rohr submitted a technical analysis to the San Diego RWQCB in October 2019 to identify the background cleanup levels for inorganic chemicals in soil and groundwater at the site. The cleanup levels for inorganic chemicals in (1) soil must lead to attainment of background water quality in groundwater, and (2) groundwater must attain background water quality. For all organic chemicals, the background soil and groundwater cleanup levels are non -detect concentrations. The detection limits for all organic chemicals in soil must not exceed the respective EPA Region 9 RSLs and the San Francisco Bay RWQCB ESLs. The detection limits for all organic chemicals in groundwater must not exceed the respective MCLs (Appendix H-3).
In April 2020, pursuant to Resolution No. 92-49, Rohr prepared a feasibility study to determine if it is technologically and economically feasible to clean up the wastes in groundwater at the site to the background cleanup levels. While Rohr concluded that it is infeasible based on (1) the results of the site-specific trend analysis and (2) the presumed slow back-diffusion of VOC mass stored in fine-grained layers beneath the site, the San Diego RWQCB requires that Rohr confirm its conclusion by collecting additional data during implementation of the site groundwater Remedial Action Plan. At a minimum, remediation performance monitoring data shall be used to reevaluate the technical feasibility and incremental cost benefit of remediating to background water quality conditions, including evaluating
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whether back-diffusion is a significant deterrent to reaching background water quality conditions. Because Rohr determined it was infeasible to clean up to the background cleanup levels in its April 2020 feasibility study, Rohr proposed alternative cleanup levels (Appendix H-3).
Site Remediation
As of July 2023, Rohr has met all the requirements of the CAO to-date with respect to site investigations (San Diego RWQCB 2023). A Remedial Action Plan to address chemically impacted soil has been submitted to the San Diego RWQCB and is pending approval. Site soil remediation, which is anticipated to begin in 2024, will be conducted to achieve groundwater protection and site-specific human health, risk-based cleanup goals, the latter of which were identified through the HHRA. The cleanup goals are protective of human health and the environment, as described above. A separate Remedial Action Plan to address chemically impacted groundwater beneath the site also is under regulatory review and groundwater cleanup activities also will commence in 2024. Remediation activities to address both soil and groundwater would be completed prior to initiation of project construction, and under the guidance of the San Diego RWQCB. Any new groundwater monitoring wells would be installed under the guidance of the San Diego Co unty Department of Environmental Health and Quality, Hazardous Materials Division (Susan Gallardo, personal communication February 2024).
Rohr is responsible for groundwater remediation on the site and adjacent areas formerly part of Rohr and/or that have been impacted by impacted groundwater migration. Rohr has implemented groundwater remediation programs approved by the San Diego RWQCB on the adjacent South Campus and H-3 Parcel, located south and west of the site, respectively. The groundwater remediation programs involve injecting microbes and nutrients to break down the trichloroethylene (TCE) and its breakdown products into harmless chemicals (i.e., in-situ bioremediation). Monitoring will be conducted in monitoring wells to monitor the performance of the remediation system. Initial results have been favorable. Additional injections may be conducted to fine tune the groundwater remediation and accelerate its progress.
The treatment and monitoring will occur for several years. A program similar to these will be implemented within Planning Area B. A groundwater remediation plan was submitted to the San Diego RWQCB in 2023 (Appendix H-2; Haley & Aldrich 2023, personal communication; Knapton, M. personal communication).
Based on the property sale agreement with Rohr, PW Wohl G Street, LLC, which is partially responsible for remediation efforts on Planning Area B -1, is required to mitigate vapors that may be generated by TCE and other volatile compounds in soil and groundwater.
Sensitive Receptors
Several schools are located within one mile of the project site, including:
▪ Mueller Charter School, located 0.2 mile to the southeast; ▪ Vista Square Elementary School, located 0.5 mile to the northeast; ▪ South Bay YMCA Preschool, located 0.5 mile to the northeast; and ▪ Chula Vista Middle School, located 0.7 mile to the northeast.
Airports
As described above in Section 5.8.1.1, the proposed project site is not located within airport influence areas of the Naval Outlying Landing Field Imperial Beach (SDCRAA 2015) or Brown Field Airport (SDCRAA 2010), located in nearby Imperial Beach and Otay Mesa, respectively.
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Wildland Fire Hazards
The project site is located in an urban area, adjacent to San Diego Bay, and is not located in an area of high, very high, or undetermined fire hazard (City of Chula Vista 2021).
Evacuation Routes
Portions of the shoreline in Chula Vista, not including the project site, are potential tsunami flood areas. Tsunami evacuation routes have been established from the marina area, Sweetwater Marsh National Wildlife Refuge, and the San Diego National Wildlife Refuge, which are all located in the vicinity of the project site (County of San Diego 2023b). However, the project site is not located within any of these evacuation routes (City of Chula Vista 2023a).
As discussed above, the project site is not located in a fire hazard area. In addition, the project site is not located in an evacuation route, in the event of a major disaster (City of Chula Vista 2021).
5.8.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts related to hazards and hazardous materials are based on Appendix G of the California Environmental Quality Act (CEQA) Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to hazards and hazardous materials would occur if the project would:
1. Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.
2. Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.
3. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.
4. Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as result, would it create a significant hazard to the public or the environment.
5. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area.
6. Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.
7. Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires.
5.8.3 Impacts
This impact analysis assumes that the proposed project would be constructed and operated in compliance with the policies and regulations applicable to hazards and hazardous materials, as described above in Section 5.8.1.1, Regulatory Framework. A review of project site investigations and applicable regulatory records was conducted to characterize the existing environmental setting in the study area, as described above in Section 5.8.1.2, Existing Setting, and to identify any existing hazardous waste and substances sites on or near the project site that could affect construction or operation of the proposed project. Impacts have been evaluated with respect to the
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thresholds of significance, as described above. In the event adverse environmental impacts would occur even with consideration of applicable policies, regulations, and standard construction practices, impacts would be potentially significant, and mitigation measures are provided to reduce impacts to less than significant.
The City has identified Project Design Features (PDFs) (see Section 4.4.5, Project Design Features) that would be implemented during construction to avoid or minimize impacts. PDF-6 PDF-Building Materials, which indicates that new construction should incorporate non -polluting and non -toxic materials and finishes with zero or low VOCs, applies to the proposed project. Where applicable, this practice and its effectiveness in avoiding or minimizing impacts related to hazardous material are described below.
The proposed project involves the preparation of a Specific Plan that would govern future development within the three Planning Areas (A, B -1, and B -2) at the project site. New land use designations would include Commercial Retail, Commercial Visitor, Comm ercial Office, Light Industrial, Regional Technology Park, and Business Park Flex, as described in more detail in Table 4 -1, Proposed Land Uses. It is anticipated that construction of the project would occur over approximately 5 years , and would include mi nor grading, utility installation, paving, and building construction.
Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Construction
The construction of the project may require the use of hazardous materials. Construction would require the use of heavy equipment and machinery. Hazardous materials that may be used during construction activities include, but are not limited to, gasoline, diesel fuel, lubricants, grease, adhesives, welding gases, solvents, paints, and vehicle - and equipment-maintenance-related materials. These materials would be stored in designated construction staging areas within the boundaries or adjacent to the project site. The construction contractor would be required to ensure that the transport, handling, use, storage, and disposal of any hazardous materials are in accordance with the manufacturer’s specifications and all applicable federal, state, and local laws and regulations. Many of the anticipated hazardous construction materials may be recycled and those that cannot be recycled would be transported by a licensed hazardous waste hauler and disposed of at an appropriately permitted off-site facility, in accordance with 22 CCR, Division 4.5, Environmental Health Standards for the Management of Hazardous Waste. The proper use and handling of these substances would not present a health risk to the public or environment. In addition, the City has identified PDFs (see Section 4.4.5, Project Design Features) that would be implemented during construction to avoid or minimize impacts.
PDF-6, which indicates that new construction should incorporate non-polluting and non-toxic materials and finishes with zero or low VOCs, applies to the proposed project. This practice would contribute to avoiding or minimizing impacts related to hazardous materials during construction. Therefore, the construction of the project is not anticipated to create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.
Impacts would be less than significant.
Operations
Based on proposed light industrial zoning, hazardous materials used during the operation of individual projects within the Specific Plan area would include various commercially available hazardous materials and cleaning products. When used in compliance with manufacturer’s recommendations and applicable regulations, these chemicals do not result in a risk to human health or the environment. The routine transport, use, and/or disposal
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of these substances would be subject to applicable federal, state, and local health and safety laws and regulations, which would minimize risks associated with their use.
Storage, use, and disposal of petroleum products and hazardous substances would be completed at individual businesses in accordance with a HMBP, which would identify the hazards, storage locations, and storage quantities for each hazardous chemical stored on -site. The HMBP would be submitted for approval to the San Diego County Department of Environmental Health and Quality, Hazardous Materials Division, the CUPA for emergency planning purposes in the City. In addition, a SPCC would be prepared for the individual businesses if oil is stored in ASTs in excess of 10,000 gallons (total on-site). The HMBP and SPCC would identify secondary containment and countermeasures to be in place during operations so that if any leaks or spills occur, responses would be made immediately.
Emergency spill supplies and equipment would be clearly marked and located adjacent to areas of work. The HMBP and SPCC would be updated as applicable to ensure ongoing compliance with all applicable federal, state, and local requirements re lated to hazardous materials. As a result , project operations are not anticipated to create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. Impacts would be less than significant.
Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? Construction
Soil Contamination
As described in detail in Section 5.8.1.2, c hemicals associated with historical operations at the project site have been identified in soil and groundwater, including, but not limited to, VOCs, metals, petroleum hydrocarbons, PAHs, and PCBs. On-site structures in Planning Areas B -1 and B-2 have been demolished, all building debris has been hauled off-site to appropriate disposal facilities, and Raytheon Technologies Corporation, of which Rohr is a wholly owned company, is completing soil and groundwater remediation in accordance with San Diego RWQCB CAO R9- 2021-0042, which was issued to Rohr in July 2021. The CAO includes directives and timelines to remediate soil, soil gas , and groundwater at the property. Soil remediation goals are protective of human health and the environment, based on site specific health-based remediation goals identified through HHRAs.
The cleanup levels for inorganic chemicals in (1) soil must lead to attainment of background water quality in groundwater, and (2) groundwater must attain background water quality. For all organic chemicals, the background soil and groundwater cleanup levels are non -detect concentrations. The detection limits for all organic chemicals in soil must not exceed the respective EPA Region 9 RSLs and the San Francisco Bay RWQCB ESLs. The detection limits for all organic chemicals in groundwater must not exceed th e respective MCLs. Soil remediation would be completed prior to initiation of project construction, and under the guidance of the San Diego RWQCB and San Diego County Department of Environmental Health and Quality, Hazardous Materials Division. Minor amounts of site grading and trenching for utilities installation would occur as part of project construction. Because soil contamination would be remediated to San Deigo RWQCB and San Diego Department of Environmental Health and Quality standards prior to project construction, minor grading and trenching would not encounter contaminated soil that could result in a significant hazard to on-site construction personnel or the environment, and would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Impacts would be less than significant.
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Incidental Spills of Hazardous Substances
Relatively small amounts of commonly used hazardous substances such as gasoline, diesel fuel, lubricating oil, adhesive materials, grease, solvents, and architectural coatings would be used during construction. These materials are not considered extremely hazardous and are used routinely for both construction projects and structural improvements. These materials would be transported and handled in accordance with all federal, state, and local laws regulating the management and use of hazardous materials, and would be managed in accordance with the federal, state, and local rules and regulations.
As discussed in more detail in Section 5.9, Hydrology and Water Quality, the proposed project would be subject to the provisions of the Construction General Permit, including preparation of a stormwater pollution prevention plan (SWPPP) and implementation of best management practices (BMPs), designed to prevent and minimize incidental spills of petroleum products and hazardous materials during construction. Additionally, the City’s BMP Design Manual (City of Chula Vista 2023b provides guidance for development and public improvement projects to comply with the 2013 Municipal Separate Storm Sewer System (MS4) Permit (Order No. R9 -2013-0001, as amended by R9-2015-0001 and R9 -2015-0100). With compliance with the Construction General Permit and MS4 Permit, project construction would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of h azardous materials into the environment.
Impacts would be less than significant.
Operation
Groundwater Contamination and Soil Gas
As discussed in Section 5.8.1.2, concentrations of COCs in groundwater exceed the vapor intrusion ESLs, which indicate they may pose a potential vapor intrusion risk to future building occupants . Groundwater is impacted by chlorinated solvents to a depth of about 100 feet. Resolution No. 92-49 requires that Dischargers clean up or abate the effects of discharges in a manner that promotes the attainment of background water quality, or the best water quality that is reasonable if background water quality cann ot be restored . In addition, CAO Nos. 98-08 and R9 - 2021-0042 require that the property waste Dischargers take all corrective actions necessary to clean up or abate the effects of the discharges to soil, soil gas, and groundwater at the site, including wastes in soil gas at the site caused by soil and/or groundwater contamination.
Rohr is responsible for groundwater remediation on the site and adjacent areas formerly part of Rohr and/or that have been impacted by impacted groundwater migration. Rohr has implemented groundwater in-situ bioremediation programs, approved by the San Diego RWQCB , on the adjacent South Campus and H -3 Parcel, located south and west of the site, respectively. Monitoring will be conducted in monitoring wells to monitor the performance of the remediation system. Initial results have been favorable. The treatment and monitoring will occur for several years. A program similar to these will be implemented within Planning Area B. A groundwater remediation plan was submitted to the San Diego RWQCB in 2023 (Appendix H -2; Haley & Aldrich 2023, personal communication; Knapton, M. personal communication).
In addition, based on the property sale agreement with Rohr, PW Wohl G Street, LLC, which is partially responsible for remediation efforts on Planning Area B -1, is required to mitigate vapors that may be generated by TCE and other volatile compounds in soil and groundwater. Vapor barriers will be placed beneath the new building slabs so that vapors cannot enter the new buildings and cause a human health risk (Haley & Aldrich 2023, personal communication). With implementation of groundwater remediation, unde r the guidance of the
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San Diego RWQCB and San Diego County Department of Environmental Health and Quality, Hazardous Materials Division, in combination with installation of vapor barriers beneath proposed building slabs, soil gas beneath proposed individual buildings within the Specific Plan area would not create a significant hazard to the public or the environment , and would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of haz ardous materials into the environment . Impacts would be less than significant .
Hazardous Materials Use in Proposed Businesses
Operation of individual projects within the Specific Plan area would likely involve the use of chemicals used in the day-to-day operation of each business, as well as commercially available cleaning products, landscaping chemicals and fertilizers, and various other commercially available products. While these materials could be stored on the project site, storage would likely occur in compliance with the gui delines established by the manufacturer’s recommendations. As required by the above referenced federal, state, and local regulations, the transport, removal, storage, use and disposal of hazardous materials from the individual businesses would be conducted by a permitted and licensed service provider. Any handling, transport, use, or disposal must also comply with all applicable federal, state, and local agencies and regulations.
The City of Chula Vista currently reports hazardous materials to the local CUPA ( San Diego County Department of Environmental Health and Quality, Hazardous Materials Division ), as required by state and local laws requiring HMBPs, SPCCs, RMPs, and Emergency Response Plans (see Section 5.8.1.1, Regulatory Framework).
Transportation of these hazardous materials and wastes would also be conducted in accordance with federal, state, and local laws (Caltrans and U.S. Department of Transportation). With the adherence to applicable federal, state, and local rules and regulations and implementation of standard construction practices and standard operating practices, the operational impac t of the proposed project related to the creation of hazards due to the routine transport, use, and disposal of hazardous materials , would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment, and would be less than significant.
Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? As discussed in Section 5.8.1.2, Mueller Charter School is located 0.2 mile to the southeast of the project site.
However, as previously discussed, the project is not anticipated to result in significant impacts associated with the release of hazardous materials into the environment. All hazardous materials used on-site during construction and operation would be used, handled, and stored in compliance with all applicable federal, state, and local health and safety regulations. Additionally, any on-site hazardous materials that may require transportation off -site would be transported by a licensed contractor and properly disposed of. Therefore, although the project is located within one- quarter mile of an existing school, impacts to this school from emission and/or handling of hazardous materials, substances, or waste would be less than significant.
Would the project be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
As described in detail in Section 5.8.1.2, chemicals associated with historical operations at the project site have been identified in soil and groundwater, including, but not limited to, VOCs, metals, petroleum hydrocarbons, PAHs,
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and PCBs. As a result, the project site is listed on the Cortese list database, pursuant to Government Code Section 65962.5, including the SWRCB GeoTracker database (leaking underground storage tank sites) (SWRCB 2024) and CalEPA active CAO database (CalEPA 2024). The site is not listed on the DTSC EnviroStor database (hazardous waste sites) (California DTSC 2024).
However, as previously discussed, because soil contamination would be remediated to San Diego RWQCB and San Diego Department of Environmental Health and Quality standards prior to commencement of project construction, minor grading and trenching activities associated with the project are not anticipated to encounter contaminated soil that could result in a significant hazard to on-site construction personnel or the environment. In addition, with implementation of groundwater remediation, under the guidance of the San Diego RWQCB and San Diego County Department of Environmental Health and Quality, Hazardous Materials Division, in combination with installation of vapor barriers beneath proposed building slabs, soil gas beneath proposed individual buildings within the Specific Plan area would not create a significant hazard to the public or the environment. Impacts would be less than significant.
For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
As described above in Section 5.8.1.1, the proposed project site is not located within airport influence areas of the Naval Outlying Landing Field Imperial Beach or Brown Field Airport, located in nearby Imperial Beach and Otay Mesa, respectively. No other airports are located within 2 miles of the project site. Therefore, no impacts would occur.
Would the project i mpair implementation of or physically interfere with an adopted emergency response pl an or emergency evacuation plan?
Portions of the shoreline in Chula Vista, not including the project site, are potential tsunami flood areas. Tsunami evacuation routes have been established from the marina area, Sweetwater Marsh National Wildlife Refuge, and the San Diego National Wildlife Refuge, which are all located in the vicinity of the project site. However, the project site is not located within any of these evacuation routes. In addition, the project site is not located in an evacuation route, in the event of any other major disaster. Therefore, no impacts would occur.
Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
The project site is located in an urban area, adjacent to San Diego Bay, and is not located in an area of high, very high, or undetermined fire hazard. Therefore, no impacts would occur.
5.8.4 Level of Significance Prior to Mitigation
The proposed project would have a less-than-significant impact with respect to hazards and hazardous materials.
5.8.5 Mitigation Measures
No mitigation measures are required.
5.8.6 Level of Significance After Mitigation
No mitigation measures are required and impacts related to hazards and hazardous materials would be less than significant .
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5.9 Hydrology and Water Quality
This section describes the existing hydrology and water quality conditions of the project site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the proposed project. The information provided is based in part on the following documents, included as appendices to this environmental impact report. ▪ Appendix I-1 Preliminary Drainage Report, Yards at the Bay, completed by Project Design Consultants , July 2023
▪ Appendix I-2 Priority Development Project, Storm Water Quality Management Plan, completed by Project Design Consultants, August 2023
5.9.1 Existing Conditions
5.9.1.1 Regulatory Framework
Federal
Clean Water Act
The federal Clean Water Act (CWA) was enacted with the primary purpose of restoring and maintaining the chemical, physical, and biological integrity of the nation’s navigable waters. The State Water Resources Control Board (SWRCB) and the Regional Water Qu ality Control Boards (RWQCBs) are responsible for enforcing water quality standards within the state. As mandated by Section 303(d) of the CWA, the SWRCB maintains and updates a list of “impaired water bodies” (i.e., water bodies that do not meet state and federal water quality standards). This list is known as the Section 303(d) list of impaired water bodies. The state is required to prioritize waters/watersheds for development of total maximum daily loads (TMDLs). Section 303(d) of the CWA bridges the technology -based and water-quality-based approaches for managing water quality and requires each state to make a list of waters that are not attaining standards after implementation of the technology-based limits. For waters on this list (and where the U.S. Environmental Protection Agency [EPA] administrator deems it appropriate), the states develop TMDLs that are established at the level necessary to implement applicable water quality standards. A TMDL must account for all sources of pollutants that cause the water to be listed. Federal reg ulations require that TMDLs, at a minimum, account for contributions from point sources and nonpoint sources. This information is compiled in a list and submitted to the EPA for review and approval. Section 303(c)(2)(b) of the CWA requires states to update the TMDLs every 3 years (SWRCB 2023).
Section 319 of the CWA mandates specific actions for the control of pollution from nonpoint sources. The EPA has delegated responsibility for implementation of portions of the CWA, including water quality control planning and programs such as the National Pollutant Discharge Elimination System (NPDES) program, to the SWRCB and the RWQCBs.
National Pollutant Discharge Elimination System Permit
Section 402 of the CWA establishes the NPDES, a permitting system for the discharge of any pollutant (except for dredged or fill material) into waters of the United States. This permit program is administered by the SWRCB and the nine RWQCBs, who have several programs that imple ment individual and general permits related to
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construction activities, stormwater runoff quality, and various kinds of non -stormwater discharges. The NPDES Construction General Permit (CGP) is discussed below under state regulations. In general, in California, a NDPES permit also provides waste discharge requirements (WDRs), although WDRs can be issued for discharges that are not within the coverage of the Section 402 NPDES program.
The Municipal Stormwater Permitting Program under CWA Section 402 regulates stormwater discharges from municipal separate storm sewer systems (MS4s). MS4 permits are issued in two phases: Phase I, for medium and large municipalities, and Phase II for small municipalities. The Phase II Small MS4 General Permit requires the discharger to develop and implement best management practices (BMPs) through a coordinated stormwater program, with the goal of reducing the discharge of pollutants to the maximum extent p racticable, which is the performance standard specified in Section 402(p) of the CWA. See the Local section below for the City’s Storm Water Management Program.
Federal Antidegradation Policy
The federal Antidegradation Policy (40 CFR 131.12) requires states to develop statewide antidegradation policies and identify methods for implementing those policies. Pursuant to this policy, state antidegradation policies and implementation methods will, at a minimum, protect and maintain (1) existing in -stream water uses; (2) existing water quality where the quality of the waters exceeds levels necessary to support existing beneficial uses, unless the state finds that allowing lower water quality is necessary to accommodate economic and social development in the area; and (3) water quality in waters considered an outstanding national resource. State permitting actions must be consistent with the federal Antidegradation Policy.
National and State Safe Drinking Water Acts
The federal Safe Drinking Water Act, established in 1974, is administered by the EPA and sets drinking water standards throughout the country. The drinking water standards established in the act, as set forth in the Code of Federal Regulations (CFR), are referred to as the National Primary Drinking Water Regulations (Primary Standards; 40 CFR 141), and the National Secondary Drinking Water Regulations (Secondary Standards; 40 CFR 143).
According to the EPA, the Primary Standards are legally enforceable standards that apply to public water systems.
The Secondary Standards are non -enforceable guidelines regulating contaminants that may cause cosmetic or aesthetic effects in drinking water. The EPA recommends the Secondary Standards for water systems but does not require systems to comply. California passed its own Safe Drinking Water Act in 1986 that authorizes the state’s Department of Health Services to protect the public from contaminants in drinking water by establishing maximum contaminant levels (as set forth in the California Code of Regulations (CCR), Title 22, Division 4, Chapter 15) that are at least as stringent as those developed by the EPA, as required by the federal Safe Drinking Water Act.
State
Responsibility for the protection of water quality in California rests with the SWRCB and nine RWQCBs. The SWRCB establishes statewide policies and regulations for the implementation of water quality control programs mandated by federal and state water qua lity statutes and regulations. The RWQCBs develop and implement water quality control plans that consider regional beneficial uses, water quality characteristics, and water quality problems. The project site is located within the jurisdiction of the San Diego RWQCB.
All projects resulting in discharges, whether to land or water, are subject to Section 13263 of the California Water Code and are required to obtain approval of WDRs by the RWQCBs. WDRs related to land and groundwater (i.e.,
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non-NPDES WDRs) regulate discharges of privately or publicly treated domestic wastewater and process/wash - down wastewater. WDRs for discharges to surface water also serve as NPDES permits, which are further described in this section.
Porter -Cologne Water Quality Control Act
The Porter-Cologne Water Quality Control Act authorizes the SWRCB to adopt, review, and revise policies for all waters of the state (including surface water and groundwater) and directs the RWQCBs to develop regional water quality control plans. Section 13 170 of the California Water Code authorizes the SWRCB to adopt water quality control plans on its own initiative.
Waste Discharge Requirements
All dischargers of waste to waters of the state are subject to regulation under the Porter -Cologne Water Quality Control Act, and the requirements for WDRs are incorporated into the California Water Code. This includes point - source and nonpoint -source dischargers. All current and proposed nonpoint -source discharges to land must be regulated under WDRs, waivers of WDRs, a water quality control plan prohibition, o r some combination of these administrative tools. Discharges of waste directly to state waters ar e subject to an individual or general NPDES permit, which also serves as WDRs. The RWQCBs have primary responsibility for issuing WDRs to cover a category of discharges. WDRs may include effluent limitations or other requirements that are designed to imple ment applicable water quality control plans, including designated beneficial uses and the water quality objectives established to protect those uses and prevent the creation of nuisance conditions. Violations of WDRs may be addressed by issuing Cleanup and Abatement Orders or Cease and Desist Orders, assessing administrative civil liability, or seeking imposition of judicial civil liability or judicial injunctive relief.
NPDES Construction Stormwater General Permit
Effective September 1, 2023, Construction Stormwater General Permit Order 2022-0057-DWQ supersedes SWRCB Order No. 2009-009-DWQ, as amended by 2010-0014-DWQ and 2012-0006-DWQ (i.e., the former CGP). SWRCB adopted the current CGP on September 8, 2022. The order requires that, prior to beginning any construction activity, the permit applicant obtain coverage under the CGP by preparing and submitting to the SWRCB a Permit Registration Document that includes a Notice of Intent , stormwater pollution prevention plan (SWPPP), and other compliance related documents required by the CGP. Regulating many stormwater discharges under one general permit greatly reduces the administrative burden associated with permitting individual stormwater discharges.
Construction activities subject to the NPDES CGP include clearing, grading, and disturbances to the ground (e.g., stockpiling or excavating), which result in soil disturbances of at least 1 or more acres of land surface, or that are part of a common plan of development or sale that disturbs more than 1 acre of land surface. Because construction of individual projects within the Specific Plan area would cumulatively disturb more than 1 acre, all improvements and development activities would be subject to these permit requirements. The SWPPP has two main objectives: to help identify the sources of sediment and other pollutants that affect the quality of stormwater discharges, and to describe and ensure the implementation of BMPs to reduce or eliminate sediment and other pollutants in stormwater and non-stormwater discharges.
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Sustainable Groundwater Management Act
On September 16, 2014, Governor Jerry Brown signed into law a three-bill legislative package—Assembly Bill 1739 (Dickinson), Senate Bill 1168 (Pavley), and Senate Bill 1319 (Pavley) —collectively known as the Sustainable Groundwater Management Act (SGMA). S GMA requires governments and water agencies of high - and medium- priority basins to halt overdraft and bring groundwater basins into balanced levels of pumping and recharge. Under SGMA, these basins should reach sustainability within 20 years of implementin g their sustainability plans. For critically overdrafted basins, sustainability should be achieved by 2040. For the remaining high- and medium-priority basins, 2042 is the deadline. Through SGMA, the California Department of Water Resources (DWR) provides ongoing support to local agencies through guidance, financial assistance, and technical assistance. SGMA empowers local agencies to form Groundwater Sustainability Agencies to manage basins sustainably and requires those Groundwater Sustainability Agencies to adopt Groundwater Sustainability Plans for medium- and high-priority groundwater basins in California.
California Water Code, Section 12924
Under California Water Code Section 12924, t he California DWR, in conjunction with other public agencies, conducts investigations of the state ’s groundwater basins. The DWR identifies the state’s groundwater basins on the basis of geological and hydrologic conditions and with consideration of political boundary lines whenever practical. The DWR also investigates existing general patterns of groundwater extraction and groundwater recharge within those basins to the extent necessary to identify basins that are subject to critical conditions of overdraft.
Local
San Diego Basin Plan
The RWQCB Water Quality Control Plan for the San Diego Basin (Basin Plan) is designed to preserve and enhance water quality and protect the beneficial uses of all regional waters. Specifically, the Basin Plan: (1) designates beneficial uses for surface and ground waters; (2) sets narrative and numerical objectives that must be attained or maintained to protect the designated beneficial uses and conform to the state's antidegradation policy; (3) describes implementation programs to protect the beneficial use s of all waters in the Region; and (4) describes surveillance and monitoring activities to evaluate the effectiveness of the Basin Plan (California Water Code Sections 13240–13244 and Section 13050[j]) (San Diego RWQCB 2021).
Chula Vista BMP Design Manual
In May 2013, the San Diego RWQCB issued Order No. R9- 2013-0001, and as amended by Order Nos. R9-2015- 0001 and R9-2015-0100, which is the Regional MS4 Permit for the San Diego Region, including the City of Chula Vista. In accordance with the Regional MS4 Permit, the City is required to adopt a jurisdiction-specific BMP Design Manual. The City of Chula Vista Best Management Practices ( BMP) Design Manual modifies the content of the Model BMP Design Manual to include City -specific guidelines and requirements. The City BMP Design Manual addresses updated on -site post -construction stormwater r equirements for Standard Projects and Priority Development Projects (PDPs), and provides updated procedures for planning, preliminary design, selection, and design of permanent storm water BMPs, based on the performance standards presented in the MS4 Permit (City of Chula Vista 2023a).
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Chula Vista Jurisdictional Runoff Management Program Document The 2018 Chula Vista Jurisdictional Runoff Management Program outlines City -wide programs and activities designed to prevent and reduce stormwater pollution within City boundaries. This program describes the pollution prevention activities that the City im plements, as well as pollution prevention requirements for homes and businesses. Minimum BMPs for construction sites, commercial and industrial businesses, municipal areas, and residential areas are also included in the Chula Vista Jurisdictional Runoff Ma nagement Program (City of Chula Vista 2018).
San Diego Bay Watershed Urban Runoff Management Program Document The City of Chula Vista, along with other responsible San Diego Bay Copermittees, have been actively implementing a Watershed Urban Runoff Management Program since January 2002. The County of San Diego, Port of San Diego, San Diego County Regional Airport Authority, and the cities of Chula Vista, Coronado, Imperial Beach, La Mesa, Lemon Grove, National City, and San Diego (San Diego Bay Copermittees) are continuing their efforts t o develop and implement watershed -based programs in the San Diego Bay Watershe d Management Area. This document discusses the San Diego Bay Copermittees’ efforts to meet the requirements of Section E of Municipal Stormwater Permit, Order Number R9-2007-0001, as well as reduce MS4 discharge, and prevent urban runoff discharges from causing or contributi ng to a violation of water quality standards. The Watershed Urban Runoff Management Program’s primary goal is to cooperatively and through collaborative strategic planning decrease the sources and reduce the discharge of pollutants from the MS4 that have been identified as causing high priority water quality problems (City of Chula Vista et al. 2008).
San Diego Bay Watershed Management Area Water Quality Improvement Plan The City of Chula Vista, along with other responsible agencies, developed a water quality improvement plan (WQIP) for the San Diego Bay Watershed. T he WQIP is a requirement of updated stormwater regulations adopted by the RWQCB, according to Order No. R9 -2013-0001, as amended by Order Nos. R9 2015 -0001 and R9 -2015-0100.
The ultimate goal of the WQIP is to protect, preserve, enhance, and restore water quality of receiving water bodies.
These improvements in water quality are accomplished through an adaptive planning and management process that identifies the highest priority water quality conditions within the San Diego Bay W atershed and implements strategies to address them (San Diego Bay Responsible Parties 2016).
Chula Vista Municipal Code Chapter 14.20, Storm Water Management and Discharge Control The purpose of this ordinance is to promote the health, safety, and general welfare of the citizens of Chula Vista by prohibiting non -stormwater discharges to the stormwater conveyance system, preventing discharges to the stormwater conveyance system from disposal of materials other than stormwater, reducing pollutants in stormwater discharges to the maximum extent practicable, and reducing pollutants in stormwater discharges to achieve applicable water quality objectives for surface waters in San Diego Cou nty (Chula Vista Municipal Code Section 14.20, Storm Water Management and Discharge Control). This ordinance states that it is unlawful for any person to cause either individually or jointly, any discharge into or from the stormwater conveyance system that results in or contributes to a violation of any NPDES permit. Any person engaged in activities that may result in
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pollutants entering the stormwater conveyance system shall, to the maximum extent practical, undertake all measures to reduce the risk of illegal discharges. The following requirements apply (CVMC Section 14.20):
▪ Best Management Practices Implementation. It is unlawful for any person not to comply with the BMPs and pollution control requirements established by the City or other responsible agency to eliminate or reduce pollutants entering the City stormwater conveyance system. BMPs shall be complied with throughout the life of the activity.
▪ Stormwater Pollution Prevention Plan. When the enforcement official determines that a business or business-related activity causes or may cause an illegal discharge to the stormwater conveyance system , the enforcement official may require the business to develop and implement a SWPPP. Businesses which may be required to prepare and implement a SWPPP include, but are not limited to, those which perform maintenance, storage, manufacturing, assembly, equipm ent operations, vehicle loading , and/or cleanup activities partially or wholly out of doors.
▪ Coordination with Hazardous Materials Response Plans and Inventory. Any activity subject to the hazardous materials inventory and response program, pursuant to Chapter 6.95 of the California Health and Safety Code, shall include provisions for compliance with this chapter in its hazardous materials response plan, including prohibitions of unlawful non -stormwater discharges and illegal discharges and provisions requiring the use of BMPs to reduce the discharge of pollutants in stormwater. ▪ Impervious Surfaces. Persons owning or operating a parking lot or an impervious surface (including, but not limited to, service station pavements or paved private streets and roads) used for automobile -related or similar purposes shall clean those surfaces as frequently and a s thoroughly as is necessary, in accordance with BMPs, to prevent the discharge of pollutants to the City stormwater conveyance system.
Sweepings or cleaning residue from parking lots or impervious surfaces shall not be swept or otherwi se made or allowed to go into any stormwater conveyance, gutter or roadway, but must be disposed of in accordance with regional solid waste procedures and practices. ▪ Compliance with NPDES Permit for Storm Water Discharges. Each discharger subject to any NPDES permit for stormwater discharges shall comply with all requirements of such permit.
The BMP Design Manual is incorporated into this ordinance by reference. The ordinance states that no landowner or development project proponent in Chula Vista shall receive any City permit or approval for land development activity or significant redevelopment activity unless t he project meets or would meet the requirements of the Development Storm Water Manual (CVMC Section 14.20).
City of Chula Vista General Plan
Chapter 8, Public Facilities and Services Element, Section 3.1, Water, Sewer and Drainage, of the City General Plan (City of Chula Vista 2021) addresses water, sewer, and drainage related issues. Objectives and policies related to water and drainage that pertain to the proposed project include the following:
Objective PFS 1: Ensure adequate and reliable water, sewer, and drainage service and facilities.
Policy PFS 1.1 : Coordinate with water districts by providing growth forecast information to allow the districts to plan and design water facilities and ensure adequate supply needed to accommodate anticipated growth.
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Policy PFS 1.3: Plan and design drainage facilities, and upgrade existing facilities, as necessary , to meet current needs, accommodate growth, and satisfy state and federal requirements.
Policy PFS 1.4 : For new development, require on -site detention of storm water flows such that, where practical, existing downstream structures will not be overloaded. Slow runoff and maximize on-site infiltration of runoff.
Objective PFS 2: Increase efficiencies in water use, wastewater generation and its re -use, and handling of storm water runoff throughout the City through use of alternative technologies.
Policy PFS 2.1: Promote and encourage local water resource development and explore all opportunities for viable water supplies, including desalination. If appropriate, reserve suitable land areas to accommodate such potentially viable facilities and to protect groundwater sources and water storage aquifers.
Policy PFS 2.2 : As part of project construction and design, assure that drainage facilities in new development incorporate stormwater runoff and sediment control, including state of-the-art technologies, where appropriate.
Policy PFS 2.3 : In designing water, wastewater, and drainage facilities, limit the disruption of natural landforms and water bodies. Encourage the use of natural channels that simulate natural drainage ways while protecting property.
Chapter 9, Environmental Element, Section 3.1, Conservation, of the City General Plan (City of Chula Vista 20 21) addresses water quality, flooding, and water demand related issues. Objectives and policies related to these issues that pertain to the proposed project include the following:
Objective E 2: Protect and improve water quality within surface water bodies and groundwater resources within and downstream of Chula Vista.
Policy E 2.1: Ensure safely swimmable and fishable surface waters through careful management of land uses and activities within Chula Vista.
Policy E 2.3: Educate residents, business owners and City departments about feasible methods to minimize the discharge of pollutants into natural drainages and the municipal storm drainage system.
Policy E 2.4 : Ensure compliance with current federal and state water quality regulations, including the implementation of applicable NPDES requirements and the City's Pollution Prevention Policy.
Policy E 2.5: Encourage and facilitate construction and land development techniques that minimize water quality impacts from urban development.
Policy E 2.6: Maximize the protection of potable water supply resources from pollutants.
Policy E 2.7 : Collaborate with other applicable jurisdictions in the development and funding of regional watershed management plans that will provide a balance between watershed protection, regional economic growth, and development of public infrastructure and services consistent with the goals and objectives of the General Plan.
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Objective E 15: Minimize the risk of injury and property damage associated with flood hazards.
Policy E 15.1: Prohibit proposals to subdivide, grade, or develop lands that are subject to potential flood hazards, unless adequate evidence is provided that demonstrates that such proposals would not be adversely affected by potential flood hazards and that such proposals would not adversely affect surrounding properties. Require site-specific hydrological investigations for proposals within areas subject to potential flood hazards; and implement all measures deemed necessary by the City Engineer to avoid or adequately mitigate potential flood hazards.
Policy E 15.2: Wherever feasible, land uses, buildings, and other structures determined to be unsafe from flood hazards shall be discontinued, removed, or relocated.
Zoning Code and Growth Management Ordinance
In accordance with Chula Vista Municipal Code Section 19.80.030, development is not permitted in the City of Chula Vista that would degrade stormwater collection systems below acceptable standards. Similarly, Section
19.09, Growth Management, provides policies and programs that tie the pace of develop ment to the provision of public facilities and improvements. Section 19.09(F) specifically requires that (1) stormwater flows and volumes shall not exceed City engineering standards as set forth in the subdivision manual and (2) the Growth Management Oversight Commission shall annually review the performance of the City’s storm drain system to determine its ability to meet the goals and objectives for drainage. Section 19.09 also requires a Public Facilities Financing Plan (PFFP) and the demonstration that public services, such as police services, meet the Growth Management Oversight Commission quality of life threshold standards. The analysis of storm drain systems provided in this section, along with the public facilities financing plan, to ensure funding for any needed expansion of services, would ensure that storm drain systems are provided commensurate with development and demand.
5.9.1.2 Existing Setting
Climate
The climate of San Diego County is characterized by warm, dry summers and mild, wet winters. The average rainfall is about 10 to 13 inches per year, most of which falls between November and March. The average mean temperature for the area is approximately 65°F in the coastal zone and 57°F in the surrounding foothills (San Diego RWQCB 2021). The proposed project is located in a Mediterranean climate region with seasonally influenced precipitation. Seasons consist of hot, dry summers and cooler, wetter winters, although San Diego is more arid than most areas with a similar climate classification. Global climate change is expected to cause a future warming trend in Southern California even under moderate emissions scenarios; however, there is no clear trend in annual precipitation. Current climate projections suggest an increase in extreme events in the San Diego region in the future, with 16% fewer rainy days and 8% more rainfall during the biggest rainstorms (San Diego Foundation 2014).
Drainage
The project site is located with in the Telegraph Canyon Creek watershed of the larger San Diego Bay watershed (San Diego RWQCB 2021) . However, the project site drains directly into San Diego Bay. The specific drainage patterns of Planning Area A (Figure 4 -2, Site Plan) are not provided as part of this EIR, as the drainage conditions would not be altered as a result of the proposed project. With respect to Planning Areas B-1 and B-2, approximately
0.3 acres of off-site run-on occurs as sheetflow in the northeast portion of the site. Planning Area B is roughly split
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into northern and southern portions with respect to stormwater flow. The north half of the site is conveyed to a 36- inch storm drain on the north side of G Street, which in turn feeds into a 54 -inch reinforced concrete pipe (RCP) and then into an existing slough northwest of the site. The slough is connected to San Diego Bay. The southern half of the site is conveyed to the southwest corner and into an existing 60-inch storm drain beneath H Street, which in turn feeds into a 72-inch and 84-inch RCP under H Street, followed by outlets directly into San Diego Bay at the Chula Vista Marina (Figure 5.9-1, Existing Drainage Conditions) (Appendix I-1, I-2).
Water Quality
As previously discussed for project drainage, stormwater runoff from the project site flows directly into the San Diego Bay Shoreline and Chula Vista Marina. Based on the San Diego RWQCB Basin Plan, beneficial uses of water bodies form the cornerstone of water quality protection under the Basin Plan. Once beneficial uses are designated, appropriate water quality objectives can be established and programs that maintain or enhance water quality can be implemented to ensure the protec tion of beneficial uses. Beneficial uses are defined as the uses of water necessary for the survival or well -being of humans, plants, and wildlife. These uses of water serve to promote the tangible and intangible economic, social , and environmental goals of mankind. Beneficial uses of San Diego Bay include industrial service supply, navigation, contact water recreation, non -contact recreation, commercial and sports fishing, preservation of biological habitats of special significance, estuarine habitat, wildlife habita t, rare/threatened/endangered species, marine habitat, migration of aquatic organisms, spawning/reproduction/early development, and shellfish harvesting (San Diego RWQCB 2021).
San Diego Bay Shoreline and Chula Vista Marina are listed as impaired waterbodies, per Section 303(d) of the CWA.
As discussed in Section 5.9.1.1, Regulatory Framework, the SWRCB maintains and updates a list of impaired water bodies (i.e., water bodies that do not meet state and federal water quality standards). The state is required to prioritize waters/watersheds for development of TMDLs. San Diego Bay as a whole is impaired with mercury, polycyclic aromatic hydrocarbons (PAHs), and polychlorinated biphenyls (PCBs). The San Diego Bay Shoreline at the Chula Vista Marina is impaired with copper. TMDLs have not been established for these pollutants. At the watershed scale, Telegraph Canyon Creek is listed as impaired with nitrogen and selenium. Similarly, TMDLs have n ot been established for these pollutants. No plans are currently in -place to restore the water quality of Telegraph Canyon Creek (SWRCB 2017, 2023; EPA 2023; Appendix I-2).
As discussed in Section 5.9.1.1, the Regional MS4 Permit for the San Diego Region required local co-permittees to implement a comprehensive Urban Runoff Management Program at both the jurisdictional and watershed level. In compliance with the Regional MS4 Permit , Chula Vista prepared a Jurisdictional Urban Runoff Management Program. Additionally, the City, along with seven other municipalities, San Diego County, and the Unified Port District, prepared the San Diego Bay Watershed Urban Runoff Management Program and San Diego Bay Watershed Management Area WQIP, which are collaborative and comprehensive watershed plan s for the San Diego Bay Watershed. Each of these watershed planning programs have been developed to identify and prioritize areas where local water quality can be improved and provide solutions to mitigate problems attributable to local urban runoff.
Groundwater
Groundwater is present at a depth of approximately 20 to 35 feet beneath Planning Area A, and 2 to 10 feet beneath Planning Areas B-1 and B-2. Three shallow groundwater zones are present beneath the site, including:
▪ Zone A – extends to a depth of approximately 25 feet below ground surface ( bgs), which generally corresponds to the artificial fill and Bay Deposits.
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▪ Upper Zone B – extends approximately 25 to 55 feet bgs, which generally refers to the upper portion of the Bay Point Formation.
▪ Lower Zone B – extends approximately 55 to 125 feet bgs , which generally refers to the lower portion of the Bay Point Formation (Appendices H-1, H-2, and H-3).
An approximately 20-foot thick clay layer separates these shallow aquifers from deeper formations. Potable water is present in a deeper aquifer known as the San Diego Formation. A deep monitoring well located east of the project site (well SDSW-3), immediately east of I -5, is screened within the San Diego Formation at depths of 145 to 204 feet bgs and 690 to 800 feet bgs (Blankenship 1997).
The Otay Water District and Sweetwater Authority provide water for the City of Chula Vista (City of Chula Vista 2023b). The Otay Water District imports surface water from regional water importers, including the San Diego County Water Authority, the Metropolitan Water District of Southern California, and the Helix Water District (Otay Water District 2023). The Sweetwater Authority owns and operates Loveland Reservoir, Sweetwater Reservoir, a brackish groundwater desalination facility, and deep freshwater wells (Sweetwater Authority 2023).
The Sweetwater Authority produces groundwater from the Coastal Plain of San Diego ( CPSD) Groundwater Basin, identified in the California DWR Bulletin 118 as Basin Number 9-033. The Sweetwater Authority adopted an interim groundwater management plan in November 2001 that governs groundwater management until a groundwater management plan could be prepared in accordance with Water Code Section 10750 ( Assembly Bill [ AB] 3030).
However, in 2014, the State of California passed SGMA, which recognizes the importanc e of groundwater to California’s overall water supplies and addresses undesirable results caused by overreliance on groundwater. DWR has designated the CPSD Basin a low priority basin, per section 10722.4 of the Water Code. Because DWR has not identified the CPSD Basin as being overdrafted, subject to critical conditions of overdraft, or projected to become overdrafted if present management conditions continue, a Groundwater Sustainability Plan is not required for the CPSD Basin (HDR 2021a).
The principal aquifer units of the CPSD Basin include recent alluvium with offshore marine sediment, Quaternary marine and non -marine deposits, and the San Diego Formation. Although groundwater occurs in the overlying sedimentary deposits, the San Diego Formation is the principal aquifer within the basin. The CPSD Basin is bounded to the east by the La Nacion Fault, to the south by the U.S./Mexico International Border, to the west by San Diego Bay, and to the north by the Mission Valley Basin. Basin recharge is derived from seasonal runoff from precipitation, discharge from the Sweetwater and Loveland Reservoirs, and underflow from the reservoirs. Within the CPSD Basin, the Sweetwater Authority operates the National City Wells, which produce potable groundwater ( total dissolved solids approximately 600 milligrams per liter) and the Desal Facility, which produces drinking water from brackish groundwater (total dissolved solids between 1,600 and 2,500 milligrams per liter). Both well fields pump from the San Diego Formation. The National City Wells consist of three wells: Nos. 2, 3, and 4. Well Nos. 3 and 4 operate daily, while the oldest well, No. 2 serving as a backup. From 2010 to 2020, the Sweetwater Authority has produced an average of 1,740 acre-feet per year from the National City Wells (HDR 2021a).
Flooding
Excluding the northern approximate one-quarter of the project site, the majority of the site is located within Federal Emergency Management Agency ( FEMA) Zone X, which is an area with a 0.2% annual chance flood hazard (i.e., 500-year flood hazard), or area of 1% annual chance flood (i.e., 100 -year flood) with average depth less than one foot, or with drainage areas of less than one square mile. The northern portion of the site is located within Zone X, Area of Minimal Flood Hazard (Figure 5.9-2, FEMA Flood Zones) (FEMA 2023).
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The project site is not located within a tsunami runup area (CGS 2022, County of San Diego 2023).
5.9.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to hydrology and water quality are based on Appendix G of the California Environmental Quality Act (CEQA) Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to hydrology and water quality would occur if the project would:
1. Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality.
2. Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin.
3. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
a. result in substantial erosion or siltation on or off site; b. substantially increase the rate or amount of surface runoff in a manner which would result in flooding on or off site;
c. create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or d. impede or redirect flood flows.
4. In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.
5. Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
5.9.3 Impacts
This impact analysis assumes that the proposed project would be constructed and operated in compliance with the policies and regulations applicable to hydrology and water quality , as described above in Section 5.9.1.1, Regulatory Framework. The results of a project hydrology report (Appendix I-1), water quality report (Appendix I-2), and water supply and infrastructure report (Appendix I -3) were used to characterize the existing environmental setting in the study area, as described above in Section 5.9.1.2, Existing Setting, and to identify any hydrologic issues that could affect construction or operation of the proposed project. Impacts have been evaluated with respect to the thresholds of significance, as described above. In the event adverse environmental impacts would occur even with consideration of applicable policies, regulations, and standard construction practices, impacts would be potentially significant, and mitigation measures are provided to reduce impacts to less than significant.
The project has identified project design features (PDFs) (see Section 4.4.5, Project Design Features) that would be implemented during construction to avoid or minimize impacts. PDF-3, which indicates that new construction should minimize impervious surfaces; PDF-8, which indicates that landscaping should be drought tolerant to reduce water demand; and PDF-10, which indicates that fugitive dust control measures should be in -place during construction, apply to the proposed project. Where applicable, this pr actice and its effectiveness in avoiding or minimizing impacts related to hydrology and water quality are described below.
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The proposed project involves the preparation of a Specific Plan that would govern future development within the three Planning Areas (A, B-1, and B-2) at the project site. No new grading and construction would occur in Planning Area A. Planning Areas B -1 and B -2 would include minor grading, utility installation, paving, and building construction. New land use designations would include Commercial Retail, Commercial Visitor, Commercial Office, Light Industrial, Regional Technology Park, and Business Park Flex , as described in more detail in Table 4 -1, Proposed Land Uses. It is anticipated that construction of the project would occur over approximately 18 months, beginning in September 2024.
Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
Construction
Planning Areas B-1 and B-2 would include minor grading, utility installation, paving, and building construction. In the absence of proper soil management, grading and construction could result in wind and water erosion and associated sedimentation of San Diego Bay. C onstruction-related activities that primarily result in sediment releases are related to exposing previously stabilized soils to potential mobilization by rainfall/runoff and wind.
Erosion and sedimentation affects water quality and interfer es with photosynthesis; oxygen exchange; and the respiration, growth, and reproduction of aquatic species. Additionally, other pollutants, such as nutrients, trace metals, and hydrocarbons, can attach to sediment and be transported downstream, which could cont ribute to degradation of water quality.
Non-sediment-related pollutants that are also of concern during construction relate to construction materials and non-stormwater flows and include construction materials (e.g., paint) ; chemicals, liquid products, and petroleum products used in construction or the maintenance of heavy equipment; and concrete-related pollutants.
Construction impacts would be minimized through compliance with the Small MS4 Permit and the SWRCB’s CGP, which is the NPDES General Permit for Storm Water Associated with Construction Activities ( Construction Stormwater General Permit Order 2022 -0057-DWQ). Because the proposed project is greater than 1 acre in size, the applicant would be required to submit a Notice of Intent to the SWRCB in order to obtain approval to complete construction activities under the CGP. This permit requires the discharger to p erform a risk assessment for the proposed development (with differing requirements based upon the determined level) and to prepare and implement a SWPPP. A Construction Site Monitoring Program that identifies monitoring and sampling requirements during construction is a required component of the SWPPP. The SWPPP is also required to include construction - phase BMPs to be implemented. Typical BMPs that would be implemented during grading and construction of the proposed project that would minimize degradation of surface water quality include the following.
Erosion Control
▪ Physical soil stabilization through hydraulic mulch, soil binders, straw mulch, bonded and stabilized fiber matrices, compost blankets, and erosion control blankets. ▪ Contain and securely protect stockpiled materials from wind and rain at all times, unless actively being used. ▪ Soil roughening of graded areas to slow runoff, enhance infiltration, and reduce erosion. ▪ Vegetative stabilization through temporary seeding and mulching to establish interim vegetation. ▪ Wind erosion (dust) control through the application of water or other dust palliatives as necessary to prevent and alleviate dust nuisance.
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Sediment Control
▪ Perimeter protection to prevent sediment discharges (e.g., silt fences, fiber rolls, gravel bag berms, sand bag barriers, and compost socks)
▪ Storm drain inlet protection
▪ Sediment capture and drainage control through sediment traps and sediment basins ▪ Velocity reduction through check dams, sediment basins, and outlet protection/velocity dissipation devices ▪ Reduction in off -site sediment tracking through stabilized construction entrance/exit, construction road stabilization, and/or entrance/exit tire wash.
▪ Slope interruption at prescribed intervals (e.g., fiber rolls, gravel bag berms, sand bag berms, compost socks, biofilter bags)
Waste and Materials Management
▪ Management of the following types of materials, products, and wastes: solid, liquid, sanitary, concrete, hazardous, and equipment-related wastes. Management measures include covered storage and secondary containment for material storage areas, secondary co ntainment for portable toilets, covered dumpsters, dedicated and lined concrete washout/waste areas, proper application of chemicals, and proper disposal of all wastes.
▪ A spill response and prevention program will be incorporated as part of the SWPPP and spill response materials will be available and conspicuously located at all times on site.
Non-Stormwater Management
▪ BMPs or good housekeeping practices to reduce or limit pollutants at their source before they are exposed to stormwater, including such measures as water conservation practices, vehicle and equipment cleaning and fueling practices, illicit connection/discharge eliminat ion, and concrete curing and finishing. All such measures will be recorded and maintained as part of the project SWPPP.
Training and Education
▪ Inclusion of CGP-defined Qualified SWPPP Developers and Qualified SWPPP Practitioners. These staff shall have required certifications and shall attend SWRCB sponsored training. ▪ Training of individuals responsible for SWPPP implementation and permit compliance, including contractors and subcontractors
▪ Signage (bilingual, if appropriate) to address SWPPP -related issues (such as site cleanup policies, BMP protection, and washout locations)
Inspections, Maintenance, Monitoring, and Sampling
▪ Performing routine site inspections and inspections before, during (for storm events > 0.5 inches), and after storm events
▪ Where applicable, preparing and implementing Rain Event Action Plans prior to any storm event with 50% probability of producing 0.5 inches of rainfall, including performing required preparatory procedures and site inspections.
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▪ Implementing maintenance and repairs of BMPs as indicated by routine, storm-event, and Rain Event Action Plan inspections.
▪ Implementation of the Construction Site Monitoring Plan for non-visible pollutants if a leak or spill is detected. ▪ Where applicable, sampling of discharge points for turbidity and pH at minimum three times per qualifying storm event and recording and retention of results.
In addition, in compliance with the CGP, temporary sediment traps would be constructed for separate work areas/staging areas (i.e., north and south of the river) that would remain in a mass graded condition for a temporary period of time (Figure 5.9-3, Proposed Drainage Conditions).
Based on the shallow depth to groundwater beneath Planning Areas B-1 and B-2, dewatering may be necessary if groundwater is encountered during temporary excavations . If groundwater is encountered and displaced, the pumped groundwater cannot be discharged into surface waters unless the City applies for a separate groundwater dewatering permit. Dewatering BMPs, such as dewatering tanks or weir tanks that would temporaril y hold the excavated groundwater, may be used during the construction phase. All dewaterin g would be conducted in compliance with the CGP ( Order 2022 -0057-DWQ) and the San Diego RWQCB’s General Waste Discharge Requirements for Groundwater Extraction Discharges to Surface Waters within the San Diego Region (Order No.
R9-2015-0013, NPDES No. CAG919003). In general, the CGP authorizes other construction -related non - stormwater discharges (such as dewatering) as long as they (a) comply with Section III.C of the CGP, (b) do not cause or contribute to violation of any water quality standards, (c) do no t violate any other provisions of the CGP, (d) do not require a non-stormwater permit as issued by some Regional Water Boards, and (e) are not prohibited by a Basin Plan provision.
As discussed in Section 5.8, Hazards and Hazardous Materials, chemicals stored and used on-site and immediately off-site during manufacturing operations have been found in the soil, soil gas, and groundwater as reported in environmental investigation reports and groundwater monitoring reports. Discharge of these chemicals of concern to the environment constitutes a discharge of waste, as defined in Water Code section 13050, subsection (d) . In 1998, the San Diego RWQCB issued Cleanup and Abatement Order (CAO ) No. 98-08 for the Rohr facility to abate discharges from its facility. CAO No. 98 -08 includes directives to (1) conduct a site -wide environmental site assessment, (2) conduct a comprehensive storm water runoff sampling program, (3) conduct a comprehensive storm water conveyance system investigation, (4) perform a site -wide data compilation and evaluation, and (5) conduct interim remedial actions . The San Diego RWQCB subsequently issued CAO R9 -2021-0042 in July 2021, which includes directives and timelines to remediate soil, soil gas, and groundwater at the property (Appendix H-3).
On-site structures in Planning Areas B-1 and B-2 have been demolished, all building debris has been hauled off-site to appropriate disposal facilities, and Raytheon Technologies Corporation, of which Rohr is a wholly owned company, is completing soil and g roundwater remediation in accordance with San Diego RWQCB CAO R9 -2021- 0042. Soil remediation would be completed prior to initiation of project construction, and under the guidance of the San Diego RWQCB and San Diego County Department of Environmental Health and Quality, Hazardous Materials Division. Minor amounts of site grading and trenching for utilities installation would occur as part of project construction. Because soil contamination would be remediated to San Deigo RWQCB and San Diego Department of Environmental Health and Quality standards prior to project construction, minor grading and trenching would not encounter contaminated soil that could result in a significant hazard to on -site construction personnel or the environment. Project construction in compliance with CAO R9 -2021-0042 would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality.
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Through implementation of the requirements outlined in the CGP and CAO R9-2021-0042, construction-related impacts to surface water and groundwater would be minimized and impacts would be less than significant.
Operations
Once operational, Planning Area A of the Specific Plan development would remain unchanged with respect to impervious surfaces. However, development of Planning Areas B -1 and B -2 represent an increase in impervious surfaces associated with proposed industrial, mixed use, and business park development , as the project site is recently graded and unpaved. The Priority Development Project (PDP) Storm Water Quality Management Plan (SWQMP) for the project (Appendix I-2) assumed that the total new and/or replaced impervious surface area within Planning Areas B -1 and B -2 would be 958,269 square feet. It can be assumed that urban land uses, including impervious surfaces such as parking lots and buildings, would be a source of pollution from incidental spills of vehicle oils and other chemicals , including incidental emissions of heavy metals from vehicle brakes, that can be conveyed by stormwater and landscape irrigation flows.
The impervious surfaces would prevent polluted surface waters from absorbing into the ground surface. The on-site watersheds following grading are depicted on Figure 5.9-3. During storm events, pollutants from paved areas lacking in proper stormwater controls and BMPs could enter the municipal storm drain system, before eventually being discharged to San Diego Bay. Between periods of rainfall, surface pollutants tend to accumulate, and runoff from the first significant storm of the year (“first flush”) would likely have the largest concentration of pollutants.
As discussed in Section 5.9.1 .2, San Diego Bay Shoreline and Chula Vista Marina are listed as impaired waterbodies, per Section 303(d) of the CWA. San Diego Bay as a whole is impaired with mercury, PAHs, and PCBs.
The San Diego Bay Shoreline at the Chula Vista Marina is impaired with copper. TMDLs have not been established for these pollutants. At the watershed scale, Telegraph Canyon Creek is listed as impaired with nitrogen and selenium. Similarly, TMDLs have not been established for these pollutants.
As discussed in Section 5.9.1.1, the Regional MS4 Permit for the San Diego Region required local co-permittees to implement a comprehensive Urban Runoff Management Program at both the jurisdictional and watershed level. In compliance with the Regional MS4 Permit , Chula Vista prepared a Jurisdictional Urban Runoff Management Program. Additionally, the City, along with seven other municipalities, San Diego County, and the Unified Port District, prepared the San Diego Bay Watershed Urban Runoff Management Program and San Diego Bay Watershed Management Area WQIP, which are collaborative and comprehensive watershed plan s for the San Diego Bay Watershed. Each of these watershed planning programs have been developed to identify and prioritize areas where local water quality can be improved and provide solutions to mitigate problems attributable to local urban runoff.
In addition, the City BMP Design Manual addresses updated on-site post-construction stormwater requirements for Standard Projects and PDPs, and provides updated procedures for planning, preliminary design, selection, and design of permanent storm water BMPs, based on the performance standards presented in the MS4 Permit. Because the project would create and/or replace 5,000 square feet or more of impervious surfaces, the proposed project classifies as a PDP. As a result, a PDP Stormwater Quality Management Plan (SWQMP) has been prepared for the project (Appendix I-2).
Pursuant to the City BMP Design Manual, the standard for storm water pollutant control is retention of the 24-hour 85th percentile storm volume, defined as the event that has a precipitation total greater than or equal to 85 % of all daily storm events larger than 0.01 inches , over a given period of record , in a specific area or location. For situations where onsite retention of the 85th percentile storm volume is technically not feasible, biofiltration must be provided to satisfy specific “biofiltration standards”. These standards consist of a set of siting, selection, sizing,
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design and operation and maintenance criteria that must be met for a BMP to be considered a “biofiltration BMP”.
If biofiltration is infeasible, the project must implement flow -through BMPs on -site and participate in an off -site alternative compliance project (City of Chula Vista 2023a).
Based on the PDP SWQMP, the proposed site drainage conveyance network would include trench drains, grate inlets, B-Inlets, ribbon gutters, earthen swales in the westerly dispersion area, and storm drains. The majority of the site drainage would be collected and then directed to modular wetland units for water treatment. Stormwater runoff would enter the modular wetland units via pipe inflows and curb openings. One 3,130-square foot biofiltration basin would be located at the northeast corner of the site (Fi gure 5.9-3). The basin would be lined because the project geotechnical engineer determined the subsurface soils are not suitable for stormwater infiltration. The biofiltration basin would include 18 inches of engineered sandy loam, growing media on top of a minimum depth of 12 inches of gravel. In addition to these biofiltration layers, a barrier/filter layer would also be installed beneath the soil media, and above the gravel layer. The filter layer would include a 3-inch layer of washed sand on top of a 3 inch layer of #8 choking stone (Appendix I-2).
No other biofiltration basins are proposed due to subsurface soil contamination in other areas of the site, as well as shallow groundwater conditions (i.e., locally as shallow as 2 feet). As a result, vegetated modular wetland units would be installed to treat stormwater runoff across the majority of the site, in combination with two stormwater runoff dispersion areas and a biofiltration planter for stormwater retention . The volume retention requirements would be met on a composite basis rather than on a drainage management area basis. Harvest and re-use would not be feasible for this project. Proposed structural BMPs would be verified by the City at the completion of construction. PDP BMPs must be maintained into perpetuity. In addition, because the project proposes to treat an equivalent or larger amount of impervious surface due to treating the run -on, the perimeter areas of the site that could not be graded to drain to on -site treatment BMPs are addressed through a proposed treatment swap along the eastern portion of the property, as illustrated in Figure 5.9-3 (Appendix I-2).
The proposed loading docks would be depressed areas below the building finish floor and would include trench drains to collect stormwater runoff in those areas. Trench drains would also be used on the east side of the site, within the SDG&E easement. The project area east of the SDG&E easement drains is not proposed to be disturbed by the project. Rather, only re-striping is proposed in that area and that portion of the drainage area is considered run-on (Appendix I-2).
Similar to existing conditions, the site drainage would be roughly split north and south, with the north side being conveyed to the 36 -inch stub, and then westerly transitioning to the 54 -inch RCP, ultimately discharging into an existing slough northwest of the site. The slough is directly connected to San Diego Bay. Stormwater runoff on the south side of the site would be conveyed to the H Street 60-inch storm drain, and then southwesterly to an 84-inch RCP that outlets directly to San Diego Bayand will continue to discharge to existing outfall connections (Appendix I- 2 and I-3).
In addition, the project would include several sustainability design features to reduce potential water usage, reduce paving, and reduce fugitive dust emissions during construction . The proposed sustainability features related to hydrology and water quality include the following:
PDF-3 Where possible, developments should reduce the amount of site paving; provide paving material that stays cool and allows water to filter through the soil; increase landscaped areas; and provide shade throughout the site in order to reduce ambient temperatu res and solar heat gain on constructed surfaces.
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PDF-8 To maximize water efficiency, new landscape designs should incorporate landscape material that is drought tolerant, native, and/ or water efficient in accordance with the Chula Vista Landscape Water Conservation Ordinance (CVMC 20.12). The use of Californi a-friendly plants, shrubs and trees is also encouraged.
PDF-10 Standard construction practices that would be employed to reduce fugitive dust emissions include watering of the active sites two times per day, depending on weather conditions. Construction of Project components would be subject to SDAPCD Rule 55 – Fugitive Dust Control. Compliance with Rule 55 would limit fugitive dust that may be generated during grading and construction activities.
As previously stated, because soil contamination would be remediated to San Deigo RWQCB and San Diego Department of Environmental Health and Quality standards prior to project construction, minor grading and trenching would not encounter contaminated soil that could result in a significant hazard to on -site construction personnel or the environment. Project construction in compliance with CAO R9-2021-0042 would not violate any water quality standards or waste discharge requirements or otherwise substantiall y degrade surface or ground water quality.
With incorporation of water quality BMPs and project design features, as described above for construction and operation, the project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. Impacts would be less than significant.
Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? As discussed in Section 5.9.1.2, the Otay Water District and Sweetwater Authority provide water for the City of Chula Vista. Only the Sweetwater Authority uses groundwater as a partial water supply source. Otay Water District supplies are limited to surface water. The Sweetwater Authority produces groundwater from the CPSD Groundwater Basin, which has been designated a low priority basin by DWR. Because DWR has not identified the CPSD Basin as being overdrafted, subject to critical conditions of overdraft, or projected to become overdrafted if present management conditions continue, a Groundwater Sustainability Plan is not required for the CPSD Basin.
A water demand analysis has been prepared for Planning Areas B -1 and B -2 of the project (Appendix I -3, Water Supply and Demand Report). Planning Area A is undergoing renovation and is on a separate track for occupancy of its space. Because the exact uses o f Planning Areas B -1 and B -2 are uncertain, water demand estimates were completed (1) based on Sweetwater Authority standard land uses, which would provide the low end of expected water use, and (2) based on a more intensive use of water to accommodate potential higher uses within the project.
Based on Sweetwater Authority standard land uses, the project water demand would be 64,093 gallons per day (gpd). Based on more intensive water use, the demand would be 84,718 gpd. The existing water demand for Planning Areas B-1 and B-2 is 70,417 gpd; the refore, the net increase in water demand for the project, using the higher water demand, would be 14,301 gpd, which is equivalent to 16.0 acre-feet per year.
Based on Sweetwater Authority’s Water Distribution System 2020 Master Plan, dated December 2021, the annual water production for the year ending in June 2020 was 16,458 acre-feet (HDR 2021b). Thus, the additional water demand estimated for the Yards at the Bay project is 0.10 percent of the total water production for the Sweetwater Authority (based on 2020 data), including surface water and groundwater supplies. This additional water supply is expected to be accounted for in the typical increase in normal growth in the Sweetwater Authority service area, as
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well as in the updated projections which Sweetwater Authority makes as part of its 5-year update of its Urban Water Management Plan (Appendix I-3).
Based on 1) the low priority status of the CPSD Groundwater Basin, 2) the numerous other surface water sources available for use by the Otay Water District and Sweetwater Authority, and 3) the stated ability of the Sweetwater Authority to supply water throughout their service area in association with typical increased growth, the project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin. Impacts would be less than significant.
Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
result in substantial erosion or siltation on or off site; As previously discussed for operational water quality impacts, the project site is currently unpaved and pervious.
Therefore, proposed Specific Plan development would result in an increase in impervious surfaces. However, the project would not substantially alter the existing drainage pattern of the site or area. Similar to existing conditions, the site drainage would be roughly split north and south, with the north side being conveyed to the 36 -inch stub, and then westerly transitioning to the 54-inch RCP, ultimately discharging into an existing slough northwest of the site. The slough is directly connected to San Diego Bay. Stormwater runoff on the south side of the site would be conveyed to the H Street 60-inch storm drain, and then southwesterly to an 84-inch RCP that outlets directly to San Diego Bayand will continue to discharge to existing outfall connections (Figure 5.9-3) (Appendix I-1 and I-2, and I- 3). However, the proposed drainage plan would direct more flow to the south because there is more capacity in the on-site storm drain stub on the south side of the site. The north storm drain would connect to a 36 -inch stub, whereas the south storm drain would connect to a 60-inch stub.
A project-specific drainage analysis calculated the 100-year storm flow for the proposed drainage system , under existing and proposed drainage conditions. The analysis concluded that the total peak 100-year flows under post- project conditions would be less than the pre -project conditions, which would alleviate downstream pipe capacity concerns for the north outlet, since the stub for the outlet has more pipe conveyance capacity than the storm drain stub for the north outlet. As a result, the proposed storm d rain system would be sufficient to satisfy Chula Vista criteria in the post -development condition (Appendix I -1) and would not result in erosive scour and associated siltation of San Diego Bay. Impacts would be less than significant. substantially increase the rate or amount of surface runoff in a manner which would result in flooding on or off site;
As discussed for the previous threshold, the project stormwater analysis (Appendix I -1) concluded that the total peak 100-year flows under post -project conditions would be less than the pre -project conditions. As a result, the rate or amount of surface runoff would not increase and on- and off-site flooding would not occur. Impacts would be less than significant.
create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or As discussed for the previous threshold, the project stormwater analysis (Appendix I -1) concluded that the total peak 100-year flows under post-project conditions would be less than the pre-project conditions. As a result, post-
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existing or planned stormwater drainage systems. In addition, as previously discussed, with incorporation of water quality BMPs and project design features, as described above, the project would not provide substantial additional sources of polluted runoff. Impacts would be less than significant. impede or redirect flood flows?
As discussed in Section 5.9.1.2, the majority of the site is located within FEMA Zone X, which is an area with a 0.2% annual chance flood hazard (i.e., 500 -year flood hazard), or area of 1% annual chance flood (i.e., 100 -year flood) with average depth less than one foot, or with drainage areas of less than one square mile. The northern portion of the site is located within Zone X, Area of Minimal Flood Hazard (Figure 5.9 -2). Because the project would not be developed within a 100-year Special Flood Hazard Area, as designated by FEMA on a Flood Hazard Boundary Map or Flood Insurance Rate Map, the potential for proposed structures in the southern portion of the site to impede or redirect flood flows is low. Impacts would be less than significant.
In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation? The project site is not located within a 100 -year Special Flood Hazard Area or tsunami runup area. In addition, the project site is not located immediately adjacent to an enclosed body of water susceptible to seiches. As a result, project development would not risk release of pollutants due to project inundation. Impacts would be less than significant .
Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Construction
The project would be required to comply with the CGP requiring preparation and implementation of a SWPPP to control runoff from construction work sites. The SWPPP must include BMPs to address transport of sediment and protect properties from erosion, flooding, or the deposition of mud, debris, or construction -related pollutants .
Implementation of BMPs , including physical barriers to prevent erosion and sedimentation, construction of sedimentation basins, limitations on work periods during storm events, use of infiltration swales, protection of stockpiled materials, and a variety of other measures would substantially reduce the potential for impacts to surface water quality from occurring during construction. In addition, because soil contamination would be remediated to San Deigo RWQCB and San Diego Department of Environmental Health and Quality standards prior to project construction, in compliance with CAO R9-2021-0042, minor grading and soil trenching for utilities would not violate any water quality objec tives or waste discharge requirements. Therefore, the project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan, and impacts from construction would be less than significant.
Operations
The Sweetwater Authority produces groundwater from the CPSD Groundwater Basin, which has been designated a low priority basin by DWR. Because DWR has not identified the CPSD Basin as being overdrafted, subject to critical conditions of overdraft, or projected to become overdrafted if present management conditions continue, a Groundwater Sustainability Plan is not required for the CPSD Basin.
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The project is subject to the requirements of the San Diego RWQCB Basin Plan. Compliance with the Basin Plan is ensured through WDRs for all surface water discharges including stormwater. As discussed in Section 5.9.1.1, the Regional MS4 Permit for the San Diego Region required local co-permittees to implement a comprehensive Urban Runoff Management Program at both the jurisdictional and watershed level. In compliance with the Regional MS4 Permit, Chula Vista prepared a Jurisdictional Urban Runoff Management Program. Additionally, the City, along with seven other municipalities, San Diego County, and the Unified Port District, prepared the San Diego Bay Watershed Urban Runoff Management Program and San Diego Bay Watershed Management Area WQIP, which are collaborative and comprehensive watershed plans for the San Diego Bay Watershed. In addition, the City BMP Design Manual addresses updated on-site post-construction stormwater requirements for Standard Projects and PDPs, and provides updated procedures for planning, preliminary design, selection, and design of permanent storm water BMPs , based on the performance standards presented in the MS4 Permit.
Based on the PDP SWQMP, the majority of the site drainage would be collected and then directed to modular wetland units for water treatment. One 3,130 -square foot biofiltration basin would be located at the northeast corner of the site (Figure 5.9-3). No other biofiltration basins are proposed due to subsurface soil contamination in other areas of the site, as well as shallow groundwater conditions (i.e., locally as shallow as 2 feet). As a result, vegetated modular wetland units would be installed to treat stormwater runoff across the majority of the site, in combination with two stormwater runoff dispersion areas and a biofiltration planter for stormwater retention.
Proposed structural BMPs would be verified by the City at the completion of construction. P DP BMPs must be maintained into perpetuity. In addition, because the project proposes to treat an equivalent or larger amount of impervious surface due to treating the run -on, the perimeter areas of the site that could not be graded to drain to on-site tre atment BMPs are addressed through a proposed treatment swap along the eastern portion of the property, as illustrated in Figure 5.9-3 (Appendix I-2). Compliance with the NPDES MS4 permit and LID requirements would ensure that the Project is consistent with the Basin Plan’s water quality objectives. As a result, impacts would be less than significant.
5.9.4 Level of Significance Prior to Mitigation
The proposed project would have a less-than-significant impact on hydrology and water quality.
5.9.5 Mitigation Measures
No mitigation measures are required.
5.9.6 Level of Significance After Mitigation
No mitigation measures are required and impacts to hydrology and water quality would be less than significant.
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5.10 Land Use and Planning
This section of the environmental impact report (EIR) describes the existing land use and planning conditions of the project site and vicinity, identifies associated regulatory requirements, and evaluates potential impacts related to implementation of the proposed Rohr Wohl Specific Plan Project (project or proposed project).
5.10.1 Existing Conditions
5.10.1.1 Regulatory Framework
State
California Planning and Zoning Law
The legal framework under which California cities and counties exercise local planning and land use functions is set forth in California Planning and Zoning Law, Government Code Sections 65000 –66499.58. Under state planning law, each city and county must adopt a comprehensive, long-term general plan. State law gives cities and counties wide latitude in how a jurisdiction may create a general plan, but there are fundamental requirements that must be met. These requirements include the provision of seven mandatory elements described in the Government Code, including a land use element. Each of the elements must contain text and descriptions setting forth objectives, principles, standards, policies, and plan proposals; diagrams and maps that incorporate data an d analysis; and mitigation measures.
California Government Code, Section 65450 et seq.
California Government Code (Sections 65450–65457) governs the content and consistency of specific plans with the adopted general plan of the jurisdiction within which they are located. Specific plans shall include text and a diagram(s) that include the following in detail: (1) the distribution, location, and extent of the uses of land, including open space, within the area covered by the plan; (2) the proposed distribution, location, and extent and intensity of major components of public and private transportation, sewage, water, drainage, solid waste disposal, energy, and other essential facilities proposed to be located within the area covered by the plan and needed to support the land uses described in the plan; (3) standards and criteria by which develop ment will proceed and standards for the conservation, development, and utilization of natural resources, where applicable; and (4) a program of implementation measures including regulations, programs, public works projects, and financing measures necessary to carry out the above -mentioned details. In addition, a specific plan shall include a statement of the relationship of the specific plan to the general plan.
Regional
San Diego Association of Governments – San Diego Forward: The Regional Plan The San Diego Association of Governments (SANDAG) adopted the 2021 Regional Plan in December 2021 (SANDAG 2021a). The 2021 Regional Plan combines the region’s two most important existing planning documents: the Regional Comprehensive Plan and the 2050 Regional Transportation Plan (RTP) and its Sustainable Communities Strategy (SCS) (2050 RTP/SCS). The Regional Comprehensive Plan, adopted in 2004 , laid out key principles for managing the region’s growth while preserving natural resources and limiting urban sprawl. The plan covers policy areas including urban form, transportation, housing, healthy environment, economic prosperity, public facilities, our
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borders, and social equity. These policy areas were addressed in the 2050 RTP/SCS and are now fully integrated into the 2021 Regional Plan (SANDAG 2021a). The goal of the SCS is to establish a development plan for the region, which, after considering transportation measures and policies, will achieve, if feasible, the greenhouse gas reduction targets. The greenhouse gas reduction target to be achieved through the adoption of SANDAG’s SCS is a 20% reduction in emissions per capita by 2035. The 2021 Regional Plan serves as the blueprint for how the San Diego region will grow and how SANDAG will invest in transportation infrastructure to provide more choices, strengthen the economy, promote a healthy environment, and support thriving communities. The 2021 Regional Plan sets forth the following six general objectives: habitat and open space preservation, regional economic prosperity, environmental stewardship, providing mobility choices, partnerships/collaboration with neighboring entities, and creating healthy and complete communities (SANDAG 2021a).
At the core of the 2021 Regional Plan is an SCS that charts a course toward lowering greenhouse gas emissions and includes the following five building blocks (SANDAG 2021a):
▪ A land use pattern that accommodates our region’s future employment and housing needs, and protects sensitive habitats, cultural resources, and resource areas. ▪ A transportation network of public transit, managed lanes and highways, local streets, bikeways, and walkways built and maintained with reasonably expected funding. ▪ Managing demands on our transportation system (also known as Transportation Demand Management, or TDM) in ways that reduce or eliminate traffic congestion during peak periods of demand. ▪ Managing our transportation system (also known as Transportation System Management, or TSM) through measures that maximize the overall efficiency of the transportation network. ▪ Innovative pricing policies and other measures designed to reduce the number of miles people travel in their vehicles, as well as traffic congestion during peak periods of demand.
The 2021 Regional Plan includes the following set of principles that will guide the development of the region’s future transportation network (SANDAG 2021a):
▪ The SANDAG investment plan will be built with financial resources that are reasonably expected to be available between now and 2050.
▪ A more efficient transportation network will be achieved through two key strategies: effectively managing the overall system (TSM) and effectively managing demands on the system (TDM) with innovative technologies integrated into both. The result will be ma ximized efficiency in the transportation network, which ultimately can lower greenhouse gas emissions.
▪ Managing parts of the network, such as adding managed lanes and transit only lanes on freeways, which encourage people to carpool and use public transit to bypass bottlenecks. ▪ The road toward a more sustainable San Diego region should include vehicles that use cleaner, alternative sources of energy with SANDAG playing an important role in promoting this transition.
SANDAG also prepared a 2019 Federal Regional Transportation Plan (2019 Federal RTP), which was adopted December 2021. The 2019 Federal RTP builds on the 2015 Regional Plan with updated project costs and revenues and a new regional growth forecast. The 2019 Federal RTP is consistent with the Final EIR approved in conjunction with the 2021 Regional Plan on December 10, 2021.
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San Diego Air Pollution Control District
The State of California has 35 specific air districts, which are each responsible for ensuring that the criteria pollutants are below the National Ambient Air Quality Standards ( NAAQS) and California Ambient Air Quality Standards (CAAQS). Air basins that exceed either the NAAQS or the CAAQS for any criteria pollutants are designated as “nonattainment areas” for that pollutant. Currently, there are 15 nonattainment areas for the federal ozone (O3) standard and two nonattainment areas for the fine particulate matter ( PM2.5) standard; many areas are in nonattainment for coarse particulate matter ( PM10) as well. Therefore, California created the California State Implementation Plan (SIP), which is designed to provide control measures needed to attain the NAAQS and CAAQS.
San Diego Air Pollution Control District ( SDAPCD) and the San Diego Association of Governments (SANDAG) are responsible for developing and implementing the clean air plan for attainment and maintenance of the ambient air quality standards in the SDAB. The RAQS for the SDAB was initially adopted in 1991 and is updated every 3 years. The RAQS outlines SDAPCD’s plans and control measures designed to attain the CAAQS for O 3. The RAQS relies on information from CARB and SANDAG, including mobile and area source emissions, as well as information regarding projected growth in the County and the cities in the County, to forecast future emissions and then determine from that the strategies necessary for the reduction of emissions through regulatory controls. The CARB mobile source emission projections and SANDAG growth projections are based on population, vehicle trends, and land use plans developed by the County and the cities in the County as part of the development of their general plans (SANDAG 2021).
On March 9, 2023, SDAPCD adopted the 2022 Regional Air Quality Strategy (RAQS). The RAQS plan demonstrates how the San Diego region will further reduce air pollution emissions to meet state health -based standards for ground-level O 3. The 2022 RAQS guides the SDAPCD in deploying tools, strategies, and resources to continue reducing pollutants that are precursors to ground -level O3, including oxides of nitrogen (NOx) and volatile organic compounds (VOCs). The 2022 RAQS emphasizes O3 control measures but also identifies complementary measures and strategies that can reduce emissions of Greenhouse Gases (GHGs) and PM. It also includes new analyses exploring O 3 and its relationship to public health, mobile sources, under -resourced communities, and GHGs an d climate change (SANDAG 2023). Further, the 2022 RAQS identifies strategies to expand SDAPCD regional partnerships, identify more opportunities to engage the public and communities of concern, and integrate environmental justice and equity across all proposed measures and strategies.
Regarding particulate matter emissions reduction efforts, in December 2005, SDAPCD prepared a report titled “Measures to Reduce Particulate Matter in San Diego County” to address implementation of Senate Bill (SB) 656 in San Diego County (SB 656 required a dditional controls to reduce ambient concentrations of PM 10 and PM 2.5) (SDAPCD 2005). In the report, SDAPCD evaluated the implementation of source -control measures that would reduce particulate matter emissions associated with residential wood combustion; various construction activities including earthmoving, demolition, and grading; bulk material storage and handling; carryout and trackout removal and cleanup methods; inactive disturbed land; disturbed open areas; unpaved parking lots/staging areas; unpaved roads; and windblown dust (SDAPCD 2005).
Local
City of Chula Vista General Plan
The City of Chula Vista General Plan was updated by the City on December 13, 2005, and most recently amended in 2020. The General Plan provides a long-term strategy to address planning issues for the growth and development of the City and is composed of th e following six elements: land use and transportation, economic development,
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public facilities and services, environmental, and housing (City of Chula Vista 2005). The project site is located in the Bayfront Planning Area and Harbor District subarea of the General Plan (City of Chula Vista 2005).
Land Use and Transportation Element
The Land Use and Transportation Element establishes the land use categories, roadway classifications, and generalized land use patterns for City development and focuses on themes that (1) support strong community character and image, (2) support strong and safe neighborhoods, and (3) improve mobility. This element establishes plans and policies to identify the general distribution of housing, businesses, industry, open space (including parks), education facilities, and public buildings. Standards for population density and building intensity in each land use classification are also provided (City of Chula Vista 2005).
Economic Development Element
The Economic Development Element establishes policies to ensure the long-term vitality of the local economy and to help develop, guide, and encourage appropriate employment and business ownership in the City. It promotes a sustainable local economy to benefit present and future generations without detrimentally affecting resources.
Employment land, or land designated for commercial, industrial and other non-residential, or open space use, is concentrated in three principal areas: the tideland area, the Montgomery area, and the Otay Ranch area (City of Chula Vista 2005).
Public Facilities and Services Element
The Public Facilities and Services Element establishes the plan to provide and maintain infrastructure and public services for future growth, without diminishing services to existing development within the City. The overall goal of this element is to provi de and maintain public facilities and services within the City through abundant public infrastructure and community services that support and enhance the well-being of the City and its residents (City of Chula Vista 2005).
Environmental Element
The Environmental Element establishes the policy framework for improving sustainability through the City’s stewardship of natural and cultural resources, promotion of environmental health, and protection of persons and property from environmental hazards a nd noise. Sustainable development is identified as a means of balancing current growth and economic progress with protection of future resources (City of Chula Vista 2005).
City of Chula Vista Multiple Species Conservation Program Subarea Plan The City of Chula Vista Multiple Species Conservation Program (MSCP) Subarea Plan has been prepared as an implementing plan of the MSCP Subregional Plan and is the basis for federal and state incidental take permits for 86 plant and animal species within the City's jurisdiction. The MSCP Subarea Plan was approved by the City of Chula Vista (City) in May 2003 and the City received take authorization in January 2005. The Subarea Plan provides for conservation of upland habitats and species through Preserve de sign, regulation of impacts and uses, and management of the preserve. The MSCP Subregional Plan, dated August 1998, was prepared for 12 local San Diego jurisdictions, including the City of Chula Vista, and is to be implemented through MSCP Subarea Plans. The MSCP Subarea Plan is implemented through individual Subarea Plans adopted by each jurisdiction receiving Take authorization for covered species. Subarea Plans approved under the Natural Community Conservation Planning
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Act would allow “take” of various sensitive species through specific conditions of coverage pursuant to Section 4(d) of the federal ESA. The City has an adopted MSCP Subarea Plan (City of Chula Vista 2003) and the Habitat Loss and Incidental Take (HLIT) Ordinance (City of Chula Vista 2019) regulates the implementation of the Subarea Plan.
The City MSCP Subarea Plan states that of the 86 covered species, 19 sensitive plant and wildlife species are considered adequately protected within the Preserve lands, and the City has obtained Incidental Take Authorization for the remaining 67 plant and wildlife species within the City of Chula Vista. Sensitive plants, animals, and habitats are defined in the MSCP Subarea Plan as rare, endangered, depleted, or declining according to the U.S. Fish and Wildlife Service, California Department of Fish and Wildlife, California Native Plant Society, and/or the City.
MSCP Preserved Lands
The MSCP Conservation Plan identifies specific areas as preserved lands. These lands are set aside for habitat conservation and the preservation of vegetation and wildlife communities within San Diego County. The City and multiple wildlife agencies have a legal agreement to protect and monitor the approximately 80,000 acres of preserved lands. The proposed project site and study area are within the Chula Vista MSCP Planning Area, but not within or adjacent to designated preserved lands under the City MSCP Subarea Plan.
MSCP Non -Covered Projects
Development projects within Development Areas outside of covered projects are regulated by the HLIT ordinance.
The HLIT ordinance establishes mitigation standards for biological resources and implements the City’s MSCP Subarea Plan for development projects outside the Covered Projects category, as identified in the City’s MSCP Subarea Plan. Provisions for protection of Narrow Endemic Species apply to all areas regulated by the HLIT ordinance. The HLIT ordinance calls for impacts to wetlands to be avoided an d minimized to the maximum extent practicable and requires mitigation for all permanent impacts to wetlands and natural vegetation at ratios provided in the MSCP Subarea Plan.
Narrow Endemic Species Protection
Narrow Endemic Species have a very restricted habitat that can only occur only in the San Diego County region.
Specific protections apply to Narrow Endemic Species pursuant to the City MSCP Subarea Plan. The following specific provisions are applicable to the project site.
Development Areas. Impacts to Narrow Endemic Species from development outside of Covered Projects will be avoided to the maximum extent practicable. Where impacts are demonstrated to be unavoidable, impacts within these Development Areas will be limited to 20% of the total Narrow Endemic Species population within the project site. Findings of equivalency, as defined in Section 5.2.3.6 of the Subarea Plan (City of Chula Vista 2003), will be made by the City for such Take Authorization of the covered Narrow Endemic Species.
City of Chula Vista Municipal Code
Zoning Ordinance
Title 19 of the City of Chula Vista Municipal Code (CVMC) is the City’s Zoning Code, which is intended to implement the General Plan. The project site is designated as a General Industrial Zone (I). As defined in Chapter 19.46 of the CVMC, the purposes of the I-G zone are to encourage sound industrial development by providing and protecting an environment exclusively for such development, subject to regulations necessary to ensure the purity of the airs and
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waters in Chula Vista and San Diego County, and to protect nearby residential, commercial and industrial uses of the land from hazards and noise or other disturbances. Permitted uses (City of Chula Vista 2001) are as follows:
▪ Any manufacturing, processing, assembling, research, wholesale, or storage uses except as hereinafter modified; ▪ Automobile and metal appliance manufacturing and assembly, structural steel fabricating shops and machine shops;
▪ Brick or pottery manufacturing and stone or monument works; ▪ Trucking yards, terminals, and distributing operations; ▪ Liquefied natural gas plants;
▪ Temporary tract signs, subject to the provisions of CVMC 19.58.320 and 19.60.600(E)(2); ▪ Any other use which is determined by the Commission to be of the same general character as the above uses.
Chula Vista Bayfront Specific Plan
Chapter 19.81 of the CVMC defines the scope and purpose of the Bayfront Specific Plan. This chapter of the CVMC is intended to implement the Chula Vista General Plan and the Chula Vista Local Coastal Program (LCP) Land Use Plan (LUP) and their goals, objectives, and policies. Chapter 19.84 of the CVMC provides for the classification of land use and the regulation of development by land use and zoning parcel. The project is zoned as Industrial in the Bayfront Specific Plan. Chapter 19.85 of the CVMC outlines the development criteria for the Bayfront Specific Plan.
Chula Vista Bayfront Local Coastal Program Land Use Plan The Chula Vista Bayfront LCP Amendment Bayfront Specific Plan was adopted in 2012 and amended in 2017. It governs the development of 722 acres of the City’s bayfront. The LCP provides a detailed plan for the orderly growth, development, redevelopment, and conservation of the City jurisdictional parcels located within the Chula Vista Bayfront coastal area. Each coastal city and county’s LCP is required to be pursuant to the California Coastal Act and approved by the California Coastal Commission. This LCP is consistent with the City General Plan and represents a step toward systematic implementation of the General Plan in the bayfront. The LUP provides land use and development policies to ensure that development within the bayfront will be consistent with the provisions of the California Coastal Act. The project site is within the Harbor District subarea, described in the LCP. The LUP outlines objectives and policies as the standard review for coastal development permits (City of Chula Vista 2012).
5.10.1.2 Existing Conditions on Project Site
The project site consists of approximately 44.8 acres located in the City of Chula Vista, California. The site is in the northwest portion of the City of Chula Vista, directly adjacent to the City of San Diego. More specifically, the project site is located west of Interstate (I) 5, north of H Street, south of G Street, east of Marina Parkway , and 0.5 miles east of San Diego Bay.
Planning Area A is currently developed with an approximately 282,004-square-foot building. Known as Building 29 (795 H Street), the building was used for research and development, tooling, and warehousing and distribution of aftermarket products until February 2021. The buildings in Planning Areas B-1 and B-2 included 2 large buildings totaling 733,977 square feet and 11 outbuildings totaling 32,860 square feet, for a total building square footage of approximately 766,837. The buildings were used for manufa cturing, warehouse, and distribution operations, which ceased in approximately 2020. On-site structures in Planning Areas B-1 and B-2 have been demolished, All building debris has been hauled off-site to appropriate disposal facilities, and Raytheon Technologies Corporation, of which Rohr is a wholly
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owned company, is completing soil and groundwater remediation in accordance with San Diego Regional Water Quality Control Board (RWQCB) CAO R9-2021-0042, which was issued to Rohr in July 2021.The existing building in Planning Area A remains and will not be demolished as part of the CAO or the proposed project.
A 40-foot-wide San Diego Gas and Electric Company (SDG&E) right-of-way with an abandoned rail line and a 150 - foot-wide SDG&E easement runs north–south through the project site. An SDG&E substation is also located on the north end of the project site.
5.10.1.3 Surrounding Land Uses
Land uses surrounding the project site include vacant properties, Collins Aerospace, F&G Street Marsh, and Seven Mile Casino to the north; Marina, Chula Vista Harbor, and future development as part of the Chula Vista Bayfront Master Plan to the south; Bay Boulevard and I-5 to the east; and Chula Vista RV Resort and future development site for the Gaylord Pacific Resort Hotel and Convention Center to the west.
5.10.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to land use and planning are based on Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). According to Appendix G, a significant impact related to land use and planning would occur if the project would:
1. Physically divide an established community.
2. Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.
5.10.3 Impacts
Would the project physically divide an established community? The physical division of an established community typically refers to the construction of a linear feature, such as an interstate highway or railroad tracks, or removal of a means of access, such as a local road that would impact mobility within an existing community or between a community and outlying area. The project does not include the construction of a highway or railroad tracks, or the removal of a means of access that would impact mobility within an existing community or between communities.
The proposed project site is currently developed with two main industrial buildings and several smaller outbuildings.
The existing buildings were used for manufacturing, warehouse, and distribution operations, which ceased in approximately 2020. Land uses surrounding the project site include vacant properties, Collins Aerospace, and Seven Mile Casino to the north; Marina, Chula Vista Harbor, and future development as part of the Chula Vista Bayfront Master Plan to the south; Bay Boulevard and I -5 to the eas t; and Chula Vista RV Resort and future development site for the Gaylord Pacific Resort Hotel and Convention Center to the west. The project site is bounded to the north by G Street, to the east by Bay Boulevard, and to the south by H Street. All these streets currently provide direct access to the project site. The project does not propose components that would impede or present barriers to existing circulat ion networks. Additionally, a pedestrian and bicycle path extension of the Bayshore Bikeway would cr oss through the project site between Planning Area A and Planning Areas B-1 and B-2. This extension of the Bayshore Bikeway would be a new multi-use path that would run along a portion of the San Diego
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Gas and Electric Company ( SDG&E) and Rail easement from G Street to H Street . The project site was previously developed with industrial uses and would be further developed with uses consistent with existing and surrounding uses.
Implementation of the proposed project would not physically divide an established community. Therefore, impacts would be less than significant.
Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? The proposed project would include multiple discretionary actions and/or approvals, as discussed in Section 4.4.1, Approvals and Amendments, of this EIR. These would include amendments to the Chula Vista General Plan, Chula Vista LCP, Bayfront Specific Plan, and the Chula Vista Municipal Code Chapter 19. These amendments would be processed concurrently with Specific Plan adoption and would result in consistency between the proposed project and applicable provisions of the Chula Vista General Plan, Chula Vista LCP , the Bayfront Specific Plan , and the Chula Vista Municipal Code Chapter 19.
In accordance with California Government Code (Title 7, Division 1, Chapter 3, Article 8, Sections 65450 through 65457), cities are authorized to adopt Specific Plans to implement their General Plan. The City of Chula Vista will adopt the proposed Specific Plan by ordinance, requiring public hearings by both the Planning Commission and City Council. The Specific Plan is a regulatory plan constituting the development concept and zoning for the subject properties. Site Development Plans, tract or parcel maps, development agreements, local public works projects, zoning ordinances (Government Code Sections 65455, 65867.5 [b]), and any action requiring ministerial or discretionary approval related to the project must be consistent with the final adopted Specific Plan.
Chula Vista General Plan
The proposed project would amend the General Plan to change the land use designation on the project site from Industrial (I) to Rohr Wohl Specific Plan; allowed uses on site would be governed by the Specific Plan. The Specific Plan would allow for permitted, conditionally permitted , and prohibited uses within six land use categories:
Commercial Retail (CR), Commercial Visitor (CV), Commercial Office (CO), Light Industrial (LI), Regional Technology Park (RTP), and Business Park Flex (BPF). The purpose of the Specific Plan is to permit and regulate the orderly development of the Specific Plan area in furtherance of the City’s General Plan, as it may be amended for implementation of the Specific Plan.
The General Plan is the primary source of long-range planning and policy direction that is used to guide development within the City and serves as a policy guide for determining the appropriate physical development and character of Chula Vista. While specific plans are not required to rigidly conform to the City’s General Plan, they must demonstrate consistency with the goals and policies set forth in the General Plan to demonstrate that the specific plan and General Plan are in general harmony. The Specific Plan has been prepared in conformance with the goals and policies of the City of Chula Vista General Plan as amended, in providing a commercial/light Industrial use on an underutilized property, creating new employment opportunities, and provi ding regulations that support the success of an employment area of the City. Table 5.10-1, General Plan Consistency Table, identifies all the goals and policies applicable to the proposed project and describes the project’s consistency, or inconsistency.
As discussed above and in Table 5.10-1 below, the proposed project would not conflict with any goals or policies of the General Plan. Thus, the proposed project would be consistent with the General Plan.
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Chula Vista Bayfront Local Coastal Program /Land Use Plan and Bayfront Specific Plan The Chula Vista Bayfront LUP is implemented by the Bayfront Specific Plan. The proposed project would remove the project site from the LUP and the Bayfront Specific Plan, which would require an amendment to the plans. However, the properties surrounding the project site would still be required to demonstrate general conformance to the LUP and the Bayfront Specific Plan. The land uses proposed under the Rohr Wohl Specific Plan are intended as a departure from heavy industrial uses to light industrial uses, b usiness park, and visitor -serving uses, which are more compatible with and complement other uses planned in the Bayfront Specific Plan.
The proposed Rohr Wohl Specific Plan generally conforms to the objectives and policies of the Bayfront Local Coastal Program LUP by encouraging a mix of uses in the bayfront and allowing for continued industrial use in areas already designated for those uses. Although the project site is near the Bay, it is separated from the Bay by major development, including the new Gaylord Hotel, and contains no special coastal resources such as a beach, wetlands, or inlet. Table 5.10-2 identifies policies and objectives applicable to the proposed project and describes the project’s consistency, or inconsistency, with these.
As discussed above and in Table 5.10 -2 below, the proposed project would not conflict with the Local Coastal Program LUP. Therefore, the proposed project would be consistent with the Local Coastal Program.
City of Chula Vista Zoning Code
To comply with state law and bring zoning of the project site into conformance with the General Plan, the Specific Plan proposes new zoning, which would amend the existing zoning designation to three new zoning designations:
PA-1 (for Planning Area A), PA-2 (for Planning Area B-1), and PA-3 (for Planning Area B-2). The new zoning provides provisions for land uses, building intensity, form, mass, height , and design within the Specific Plan area . The proposed zoning and development regulations identified in t he Specific Plan would replace the provisions of the CVMC Sections 19.81, 19.84, and 19.85.
Upon adoption of the proposed zoning and development standards, the proposed project would replace existing zoning designations on the project site. The new zoning and development standards would provide for orderly development of each planning area and assist in providing new opportunities for investment and revitalization along the bayfront. Application of proposed zoning regulations is specifically intended to provide for and ensure the most appropriate use of the project site, to create a harmonious relationship among land uses, and to protect the health, safety, and welfare of the community. Accordingly, the new zoning and development standards would not conflict with the overall intent and purpose of the CVMC.
City of Chula Vista Multiple Species Conservation Program Subarea Plan The City of Chula Vista Multiple Species Conservation Program (MSCP) Subarea Plan is a local policy document that provides for conservation of upland habitats and species through preserve design, regulation of impacts and uses, and management of the preserve (City of Chula Vista 2003). The project site lies within the boundaries of the City’s MSCP Subarea Plan, within Development Areas outside of covered projects and outside of the preserve area.
However, a preserve area does occur approximately 500 feet north of the project site. The project would not result in impacts to any wildlife corridors or linkages, including lands identified within the City’s MSCP Subarea Plan as Significant Biological Linkages or other areas of local or regional wildlife movement importance. Nonetheless, all new developments must adhere to specific guidelines under MSCP Adjacency Management Issues. Following is an
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analysis of the project’s compliance with each of the MSCP Adjacency Management Issues (identified in Section
5.3, Biological Resources, 5.3.1.1 Regulatory Framework):
Drainage. Construction activities would be required to implement best management practices (BMPs) including, but not limited to, the use of silt fencing or fiber rolls around active work areas. Once operational, a storm drainage system (curbs, gutters, inlets etc.) would convey water through the site to detention basins that would allow for control, treatment, and filtration. BMPs would be integrated into the project design to ensure water quality impacts to downstream drainages would be avoided.
Toxic Substances. The project does not propose the use or release of toxic substances that could harm biological resources. Further, the project would implement BMPs to ensure no toxic substances are discharged from the project site. All methods used would be consistent with requirements of the Regional Water Quality Control Board and National Pollutant Discharge Elimination System standards.
Lighting. Construction activities would be performed during daylight hours to avoid the need for light shielding. Should nighttime lighting be required on site, the project would implement BMPs to protect preserve lands and sensitive species from night lighting. All lighting for operation of the project would provide adequate shielding as necessary.
Noise. The project site is not occupied by the coastal California gnatcatcher (Polioptila californica) or the least Bell’s vireo (Vireo bellii pusillus). Raptors, such as osprey (Pandion haliaetus), are known to use the project site and the potential for other nesting raptors is moderate, due to the presence of ornamental trees and manmade structures suitable for nesting. If demolition or ground -disturbing activities are initiated during the raptor breeding season (generally January 15–July 31), a survey will be required to identify any potential noise impacts on nesting raptors.
If necessary, noise reduction techniques will be implemented.
Invasives. Per the project’s landscape plans, no invasive plant species would be used during ornamental landscaping associated with the project. Invasive species are those determined by the City of Chula Vista and identified in the MSCP Subarea Plan, Appendix N, List of Invasive Species.
Buffers. The project would not occur within or immediately adjacent to any reserve lands. As such , no buffers are proposed.
Moreover, all impacts to biological resources would be mitigated to a less -than-significant level . As such, no conflicts with the City’s MSCP Subarea Plan would occur.
Conclusion
As demonstrated throughout the analysis for Threshold 2, the proposed project would not result in a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Impacts would be less than significant.
5.10.4 Level of Significance prior to Mitigation
Impacts to land use and planning would be less than significant.
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5.10.5 Mitigation Measures
No mitigation measures are required.
5.10.6 Level of Significance after Mitigation
No mitigation measures would be required. Impacts to land use and planning would be less than significant.
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5.11 Noise
This section describes the existing noise conditions at the project site, identifies associated regulatory requirements, evaluates potential noise impacts as a result of construction and operation, and identifies mitigation measures related to implementation of the proposed project. The discussion in this section is based on the Noise Technical Report prepared for the project by Dudek in 2024. The complete report is provided in Appendix J of this EIR.
5.11.1 Existing Conditions
Fundamentals of Noise and Vibration
Sound, Noise, and Acoustics
Sound is actually a process that consists of three components: the sound source, sound path, and sound receptor.
All three components must be present for sound to exist. Without a source to produce sound, there is no sound.
Similarly, without a medium to transmit sound pressure waves, there is no sound. Finally, sound must be received; a hearing organ, sensor, or object must be present to perceive, register, or be affected by sound or noise. In most situations, there are many different sound sources, paths, and receptors rather than just one of each. Acoustics is the field of science that deals with the production, propagation, reception, effects, and control of sound. Noise is defined as sound that is loud, unpleasant, unexpected, or undesired.
Sound Pressure Levels and Decibels
The amplitude of a sound wave determines its loudness. Loudness of sound increases with increasing amplitude.
Sound pressure amplitude is measured in units of micronewtons per square meter, also called micropascals. One micropascal is approximately one -hundred billionth (0.00000000001) of normal atmospheric pressure. The pressure of a very loud sound may be 200 million micropascals, or 10 million times the pressure of the weakest audible sound. Because expressing sound levels in terms of micropascals would be very cumbersome and the sensitivity of human hearing to changes in micropascals is rather coarse (e.g., a doubling of micropascals is just audible to most people), sound pressure level in logarithmic units is used instead to describe the ratio of actual sound pressure to a reference pressure squared. These units are called Bels. To provide a finer resolution, a Bel is subdivided into 10 decibels (dB).
A-Weighted Sound Level
Sound pressure level alone is not a reliable indicator of loudness. The frequency, or pitch, of a sound also has a substantial effect on how humans will respond. Although the intensity (energy per unit area) of the sound is a purely physical quantity, the loudness, or human response, is determined by the characteristics of the human ear.
Human hearing is limited not only in the range of audible frequencies, but also in the way it perceives the sound in that range. In general, the healthy human ear is most sensitive to sounds between 1,000 and 5,000 hertz, and it perceives a sound within th at range as more intense than a sound of higher or lower frequency with the same magnitude. To approximate the frequency response of the human ear, a series of sound level adjustments is usually applied to the sound measured by a sound level meter. The adj ustments (referred to as a weighting network) are frequency-dependent.
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sound level during the same time period. For instance, the 1 -hour A-weighted equivalent sound level, Leq(h), is the energy average of the A-weighted sound levels occurring during a 1-hour period.
People are generally more sensitive to and thus potentially more annoyed by noise occurring during the evening and nighttime hours. Hence, another noise descriptor used in community noise assessments—the community noise equivalent level (CNEL)—represents a time-weighted, 24-hour average noise level based on the A -weighted sound level. However, unlike an unmodified 24-hour Leq value, the CNEL descriptor accounts for increased noise sensitivity during the evening (7 p.m. to 10 p.m.) and nighttime (10 p.m. to 7 a.m.) by adding 5 dBA and 10 dBA, respectively, to the average sound levels occurring during these defined hours within a 24 -hour period. Whereas CNEL is used mostly in California, the L dn descriptor (day-night average noise level, which is the same as CNEL with the only exception of not including the 5 dBA evening correction) is used more often for environmental noise evaluations for federal projects.
Sound Propagation
Sound propagation (i.e., the traverse of sound from a noise emission source position to a receptor location) is influenced by multiple factors that include geometric spreading, ground absorption, atmospheric effects, and occlusion by natural terrain and/or features of the built environment.
Sound levels attenuate (or diminish) geometrically at a rate of approximately 6 dBA per doubling of distance from an outdoor stationary point -type source due to the spherical spreading of sound energy with increasing distance traveled. The effects of atmospheric conditions such as humidity, temperature, and wind gradients are typically distance-dependent and can also temporarily either increase or decrease sound levels measured or perceived at a receptor location. In general, the greater the distance the receptor is from the source of sound emission, the greater the potential for variation in sound levels at the receptor due to these atmospheric effects. Additional attenuation can result from sound path occlusion and diffraction due to intervention of natura l (ridgelines, dense forests, etc.) and built features (such as solid walls, buildings, and other structures).
Ground -borne Vibration Fundamentals
Ground-borne vibration is fluctuating or oscillatory motion transmitted through the ground mass (i.e., soils, clays, and rock strata). The strength of ground-borne vibration attenuates rapidly over distance. Some soil types transmit vibration quite efficiently; other types (primarily sandy soils) do not. Several basic measurement units are commonly used to describe the intensity of ground vibration. The descriptors used by the Federal Transit Administration (FTA) are peak particle velocity (PPV), in units o f inches per second (ips), and velocity decibel (VdB) that is based on a root-mean square (RMS) of the vibration signal magnitude. The calculation to determine PPV at a given distance is as follows:
PPVdistance = PPVref*(25/D)1.5
Where:
PPVdistance = the peak particle velocity in inches per second of the equipment adjusted for distance PPVref = the reference vibration level in inches per second at 25 feet D = the distance from the equipment to the receptor
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5.11.1.1 Regulatory Framework
Federal
Federal Transit Administration
In its Transit Noise and Vibration Impact Assessment guidance manual, the FTA recommends a daytime construction noise level threshold of 80 dBA Leq over an 8-hour period (FTA 2018) when detailed construction noise assessments are performed to evaluate potential impacts to community residences surrounding a project. Although this FTA guidance is not a regulation, it can serve as a quantified standard in the absence of such noise limits at the state and local jurisdictional levels.
Federal Interagency Committee on Noise
Some guidance regarding the determination of a substantial permanent increase in ambient noise levels in the project vicinity above existing levels is provided by the 1992 findings of the Federal Interagency Committee on Noise (FICON 1992), which assessed the annoyance effects of changes in ambient noise levels resulting from aircraft operations. The FICON recommendations are based upon studies that relate aircraft and traffic noise levels to the percentage of persons highly annoyed by the noise. Annoyance is a qualitative measure of the adverse reaction of people to noise that generates speech interference, sleep disturbance, or interference with the desire for a tranquil environment.
The rationale for the FICON recommendations is that it is possible to consistently describe the annoyance of people exposed to transportation noise in terms of Ldn. The changes in noise exposure that are shown below are expected to result in equal changes in annoyance at sensitive land uses. Although the FICON recommendations were specifically developed to address aircraft noise impacts, they are used in this analys is to define a substantial increase in community noise levels related to all transportation n oise sources and permanent non -transportation noise sources.
▪ Outdoor ambient sound level without the project is less than 60 dBA Ldn, then a project-attributed increase of 5 dBA or more would be considered significant;
▪ Outdoor ambient sound level without the project is between 60 and 65 dBA Ldn, project-attributed increase of 3 dBA or more would be considered significant; and
▪ Outdoor ambient sound level without the project is greater than 65 dBA Ldn, then project-attributed increase of 2 dBA or more would be considered significant..
State
California Code of Regulations, Title 24
Title 24 of the California Code of Regulations sets standards that new development in California must meet.
According to Title 24, interior noise levels are not to exceed 45 A-weighted decibel Community Noise Equivalent Level (dBA CNEL) in any habitable room (ICC 2019).
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California Department of Health Services Guidelines
The California Department of Health Services has developed guidelines of community noise acceptability for use by local agencies (OPR 2017). Selected relevant levels are listed here:
▪ Below 60 dBA CNEL: normally acceptable for low-density residential use ▪ 50 to 70 dBA: conditionally acceptable for low-density residential use ▪ Below 65 dBA CNEL: normally acceptable for high-density residential use and transient lodging ▪ 60 to 70 dBA CNEL: conditionally acceptable for high -density residential, transient lodging, churches, educational, and medical facilities
The normally acceptable exterior noise level for high-density residential use is up to 65 dBA CNEL. Additionally, this exterior noise level limit is consistent with the City of Chula Vista General Plan Noise Element, which considers multi- family units to be noise-sensitive land uses (City of Chula Vista 2005).
California Department of Transportation
In its Transportation and Construction Vibration Guidance Manual (Caltrans 2020), the California Department of Transportation (Caltrans) recommends 0.5 ips PPV as a threshold for the avoidance of structural damage to typical newer residential buildings exposed to continuous or frequent intermittent sources of ground -borne vibration. For transient vibration events, such as blasting, the damage risk threshold would be 1.0 ips PPV (Caltrans 2020) at the same type of newer residential structures. For older structures, these guidance thresholds would be more stringent:
0.3 ips PPV for continuous/intermittent vibration sources, and 0.5 ips PPV for transient vibration events. With respect to human annoyance, Caltrans guidance indicates that building occupants exposed to continuous ground- borne vibration in the range of 0.2-0.6 ips PPV would find it “unpleasant or “annoying” and thus a likely significant impact. Although these Caltrans guidance thresholds are not regulations, they can serve as quantified standards in the absence of such limits at the local jurisdictional level.
Local
City of Chula Vista Noise Level Compatibility Standards The City of Chula Vista Noise Ordinance (Chula Vista Municipal Code [CVMC] Section 19.68) (City of Chula Vista 2022) contains regulations restricting land use related noise -generating activities and operations, so as to avoid noise nuisance in the community. Section 19.68.030 of the CVMC establishes the maximum allowable exterior noise limits, based upon the classifica tion of the receiving land use. These standards typically apply to stationary sources such as noise from mechanical equipment (including mech anical ventilation and air conditioning noise, pool pump noise, etc.) or event noise, as opposed to traffic noise. For instance, a school, commercial enterprise, or industrial operation must not generate noise that exceeds a certain specified noise level at any property boundary where an adjacent residential use exists. The property-line noise standards are presented in Table 5.11-2.
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also occurring during the building construction phase of Planning Area B-2. The highest number of daily haul truck trips is yet to be determined.
Based upon available data from the project’s Transportation Technical Memorandum, H Street in the project vicinity carries approximately 12,070 daily trips (peak hour multiplied by a k-factor of 10) in the project vicinity. Comparing the maximum number of daily construction-related trips (292 worker trips, 150 vendor trips and to-be-determined haul truck trips) to the average daily traffic volume, the additional vehicle trips would amount to an increase of approximately 4%1.
Based upon the fundamentals of acoustics, a doubling (i.e., a 100% increase) would be needed to result in a 3 -dB increase in noise levels, which is the level corresponding to an audible change to the typical human listener. Additionally, although the number of daily haul trucks is yet to be determined, it is not anticipated that the number of haul trucks would double the number of trips on nearby roadways. Therefore, traffic related to construction activities would not result in a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. Impacts from project-related construction traffic noise would be less than significant.
Long -Term Operational
Off-Site Traffic Noise Exposure
The project is expected to generate a subtotal of 7,520 average daily trips to the roadway system, as shown in Appendix K. During the afternoon (PM) peak -hour (the highest of the AM and PM peak hours), approximately 903 passenger car equivalent vehicles for Planning Area B -1 analysis and 767 passenger car equivalent vehicles for Planning Areas A/B -2 analysis are estimated to enter or exit the project site. Utilizing this information as well as additional traffic data provided in Appendix J, the FHWA’s Highway Traffic Noise Prediction Model RD -77-108 was used to estimate potential noise impacts at adjacent noise-sensitive uses. Information used in the model included Average Daily Traffic (ADT), posted traffic speeds, truck mix percentage, and day/evening/nigh t mix percentage.
Consistent with Caltrans guidance (Caltrans 2013), this analysis assumes 80% of the ADT occurs during daytime hours (7:00 a.m. to 7:00 p.m.), 5% during the evening (7:00 p.m. to 10:00 p.m.), and 15% during the nighttime (10:00 p.m. to 7:00 a.m.).
The future modeled traffic speed was assumed to be the anticipated speed limit for the studied future roads, which is 35 miles per hour (mph) for Bay Boulevard, F Street, G Street, H Street, and Marina Parkway. The truck percentages used in the noise model were 2.0% medium trucks and 1.0% heavy trucks. This truck mix is based on vehicle surveys conducted for a number of similar roads in San Diego County that allow truck traffic.
The change in roadway noise levels was predicted for opening year 2026 and opening year 2026 plus project .
Traffic noise levels were calculated for roadway segments bounded by intersections within the project area and are listed as follows:
▪ Bay Boulevard – From F Street to G Street;
▪ Bay Boulevard – From G Street to H Street;
▪ Bay Boulevard – From H Street to J Street;
1 It is noted that the estimated percentage of trucks in the project’s construction traffic mix is greater than a typical urban arterial, which may result in a greater temporary change than the 4% increase would represent; however, the project site is locate d in an industrial/commercial area with high percentages of trucks as well. Thus, the estimated temporary increase would be less than 3 dB as stated, and less than significant.
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Project Sound Sources
On-Site Outdoor Mechanical Equipment
The completion of Planning Area B -1 buildings will add a variety of noise -producing mechanical equipment that include those presented and discussed in the following paragraphs. Most of these noise -producing equipment or sound sources would be considered stationary or limited in mobility to a defined area. Planning Areas A and B-2 are programmed for future portions of the project site. Planning Area A is expected to maintain warehouse uses, which may have similar loading dock and HVAC noise as the analyzed portion for Planning Area B -1. However, land uses adjacent to Planning Areas A and B-2 appear to be industrial land uses or vacant at the present time. Because the expected uses for Planning Areas A and B -2 are similar to the uses for Planning Area B -1 and are generally less noisy than a warehouse use with active loading docks, and because the surrounding land uses are industrial land uses, it is assumed that the noise levels and contours predicted for Planning Area B -1 would be applicable to Planning Areas A and B-2.
Prediction Method and Parameters
The aggregate noise emission from outdoor -exposed sound sources (mechanical equipment) has been predicted with the Datakustik CadnaA sound propagation program. CadnaA is a commercially available software program for the calculation, presentation, assessment, and prediction of environmental noise based on algorithms and reference data per In ternational Organization for Standardization (ISO) Standard 9613 -2, “Attenuation of Sound During Propagation Outdoors, Part 2: General Method of Calculation” (ISO 1996). The CadnaA computer software allows one to position sources of sound emission in a simulated three-dimensional (3-D) space having heights and footprints consistent with project architectural plans and elevations. In addition to the above -mentioned sound source inputs and building -block structures that define the 3-D sound propagation model space, the following assumptions and parameters are included in this CadnaA-supported stationary noise source assessment:
▪ Ground effect acoustical absorption coefficient equal to 0.5, which intends to represent an average or blending of ground covers that are characterized largely by hard reflective pavements and existing building surfaces across the project site and the surroundings;
▪ Reflection order of 1, which allows for a single reflection of sound paths on encountered structural surfaces such as the modeled building masses;
▪ Off-site residential structures and buildings have not been rendered in the model; ▪ Calm meteorological conditions (i.e., no wind) with 68 degrees Fahrenheit and 50% relative humidity; and ▪ All of the modeled noise sources are operating concurrently and continuously for a minimum period of 1 hour.
Based on the available plans and other design information, proposed buildings in Planning Area B -1 would be served by roof-mounted air-conditioning equipment that includes outdoor-exposed packaged air-handling units and air-cooled condensers that provide the expected cooling demand (expressed as refrigeration “tonnage”) for a building. The following ar e descriptions of modeled sound sources, with Table 5.11-8 exhibiting modeled sound power level (PWL) data at octave -band center frequency (OBCF) resolution. Detailed information supporting these summary descriptions and quantities appear in Appendix J.
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peak hour truck movement is reduced to a single truck for each docking area. Figure 5.11-3, Predicted Nighttime On-site Operations Noise Contours, displays the predicted noise contours associated with aggregate sound propagation from operating HVAC and nighttime loading dock sound sources.
Figures 5.11-2 and 5.11-3 illustrate predicted aggregate SPL propagation solely from operation of the proposed project sound sources as described above. The color -coded annular bands of SPL are calculated across a field parallel with and 5 feet above local grade.
Based on the noise level contours appearing in Figures 5.11-2 and 5.11-3, the proposed project Planning Area B-1 is predicted to be up to 45 dBA Leq in the daytime and 42 dBA Leq in the nighttime for a calculated Ldn of 49 dBA at the nearby future hotel land use and is therefore expected to be lower than and thus comply with the City’s 60 dBA Leq daytime threshold and 50 dBA Leq nighttime threshold for multi-family residential land uses.
Planning Areas A and B -2 are programmed for future portions of the project site. Planning Area A is expected to maintain warehouse uses, which may have similar loading dock and HVAC noise as the analyzed portion for Planning Area B-1. However, land uses adjacent to Planning Areas A and B -2 appear to be industrial land uses or vacant at the present time. Because the expected uses for Planning Areas A and B -2 are similar to the uses for Planning Area B-1 and are generally less noisy than a warehouse use with active loading docks, and because the surrounding land uses are industrial land uses, it is assumed that the noise levels and contours predicted for Planning Area B -1 would be applicable to Planning Areas A and B -2. Thus, noise generated by the programmed Planning Areas A and B-2 are expected to be below the City’s 70 dBA Leq threshold for industrial land uses.
Planning Area B -2 may contain a hotel and restaurant, which may have exterior areas subject to lower City thresholds. Further analysis may be necessary to determine on -site impacts from loading dock and HVAC noise sources associated with other areas of the project. However, and as shown in Figure 5.11-2, impacts from Planning Area B-1 are likely due to project building orientation. With additional consideration for Planning Area A building orientation, warehouse and loading dock noise may be reduced at future hotel uses associated with Planning Area B-2. Thus, noise generated by Planning Areas A, B -1, and B -2 are expected to be below the City’s 50 dBA L eq nighttime threshold for multi-family residential land uses Note that the multi-family residential land use threshold is applied to this analysis due to an absence of City thresholds for hotel land uses.
Therefore, impacts associated with stationary operations noise would be less than significant.
On-site Parking Lot Activity
A comprehensive study of noise levels associated with surface parking lots was published in the Journal of Environmental Engineering and Landscape Management (Baltrënas et al. 2004). The study found that average noise levels for parking lots of similar size during the peak period of use of the parking lot (generally in the morning with arrival of commuters, and in the evening with the departure of commuters), was 47 dBA L eq at 1 meter (3.28 feet) from the outside boundary of the parking lot. The parking are as would function as point sources for noise, which means that noise would attenuate at a rate of 6 dBA with each doubling of distance. Employee parking lots are proposed to be distributed throughout the project site adjacent to the warehouse/office buildings, no closer than 180 feet from the edge of the parking lot to the future hotel to the west. At a distance of 180 feet, parking lot noise levels would not be audible to the human ear at the future hotel recept or locations. The combination of the parking lot noise (~12 dBA L eq) and the loading dock equipment level (45 dBA Leq during the daytime and 42 dBA
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Leq during the nighttime at the nearest receptor) would be 45 dBA L eq2, during the daytime and 42 dBA L eq during the nighttime which is below the applicable limits (i.e. , 60 dBA L eq during daytime hours and 50 dBA L eq during nighttime hours for multi-family residential land uses). Note that the multi-family residential land use threshold is applied to this analysis due to an absence of City thresholds for hotel land uses. Therefore, impacts associated with parking lot noise would be less than significant.
Would the project result in generation of excessive groundborne vibration or groundborne noise levels? Construction activities may expose persons to excessive ground -borne vibration or ground-borne noise, causing a potentially significant impact. Caltrans has collected ground -borne vibration information related to construction activities (Caltrans 2020). In formation from Caltrans indicates that continuous vibrations with a PPV of approximately 0.2 ips is considered annoying. For context, heavier pieces of construction equipment, such as a bulldozer that may be expected on the project site, have peak particle velocities of approximately 0.089 ips or less at a reference distance of 25 feet (DOT 2006).
Ground-borne vibration attenuates rapidly, even over short distances. The attenuation of ground-borne vibration as it propagates from source to receptor through intervening soils and rock strata can be estimated with expressions found in FTA and Caltrans g uidance. By way of example, for a bulldozer operating on -site and as close as the northern project boundary (i.e., ~70 feet from the nearest occupied property), the estimated vibration velocity would be 0.018 ips per the equation as follows (FTA 2018):
PPVrcvr = PPVref * (25/D)1.5 = 0.018 = 0.089 * (25/70)1.5 In the above equation, PPV rcvr is the predicted vibration velocity at the receptor position, PPV ref is the reference value at 25 feet from the vibration source (the bulldozer), and D is the actual horizontal distance to the receptor.
Therefore, at this predicted PPV, the impact of vibration-induced annoyance to occupants of nearby existing homes would be less than significant.
Construction vibration, at sufficiently high levels, can also present a building damage risk. However, anticipated construction vibration associated with the proposed project would yield a maximum amplitude of 0.018 ips, which does not surpass the guidance limit of 0.2 to 0.3 ips PPV for preventing damage to residential structures (Caltrans 2020). Because the predicted vibration level at 70 feet is less than this guidance limit and because there are no residential structures adjacent to the project, the ris k of vibration damage to nearby structures is considered less than significant.
Once operational, the proposed project would not be expected to feature major producers of ground-borne vibration.
Anticipated mechanical systems like heating, ventilation, and air-conditioning units are designed and manufactured to feature rotating (fans, motors) and reciprocating (compressors) components that are well-balanced with isolated vibration within or external to the equipment casings. On this basis, potential vibration impacts due to proposed project operation would be less than significant.
2 Because noise levels are summed in the energy (that is, the logarithmic) domain, a noise level that is 10 decibels or more lo wer than another noise level becomes negligible, because the sound energy from the higher noise source is completely dominant.
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For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? There are no private airstrips within the vicinity of the project site. The closest airport to the proposed project site is the Imperial Beach Airport approximately 4 miles south of the project boundary. Therefore, airport noise impacts would be less than significant.
5.11.4 Level of Significance Prior to Mitigation
Noise impacts associated with the proposed project would be less than significant.
5.11.5 Mitigation Measures
No mitigation measures are required.
5.11.6 Level of Significance After Mitigation
Noise impacts associated with the proposed project would be less than significant.
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5.12 Population and Housing
This section describes the existing population and housing conditions of the project site and vicinity, identifies associated regulatory requirements, and evaluates potential impacts related to implementation of the proposed Rohr Wohl Specific Plan Project (proposed project or project), which does not include the development of any residential land uses.
5.12.1 Existing Conditions
5.12.1.1 Regulatory Framework
Federal
No federal regulations or guidelines relating to population and housing apply to the proposed project.
State
California Government Code (Sections 65580 –65590)
State law mandates local communities plan for enough housing to meet projected growth in California. Article 10.6 of the California Government Code (Sections 65580 –65590) requires each county and city to prepare a housing element as part of its general plan. The housing element is one of seven state -mandated elements that every general plan must contain, and it is required to be updated every 5 to 8 years and must be determined to be legally adequate by the state. The purpose of the housing element is to identify the community’s housing needs; state the community’s goals and objectives with regards to housing production, rehabilitation, and conservation to meet those needs; and define the policies and programs that the community will implement to achieve the stated goals and objectives.
Regional
San Diego Association of Governments
The San Diego Association of Governments (SANDAG) is a public agency, composed of 18 cities and the County of San Diego, which builds strategic plans guiding the San Diego region in land use, growth, economics, and the environment. SANDAG also provides population and housing estimates for the region that inform regional planning and that are based, in part, on local jurisdictional planning data.
Regional Comprehensive Plan
The SANDAG Regional Comprehensive Plan, adopted in 2004, provides a long -term planning framework for the San Diego Region. The Regional Comprehensive Plan identifie s smart growth and sustainable development as important strategies to direct the region’s future growth toward compact, mixed -use development in urbanized communities that already have existing and planned infrastructure, and then toward connecting those communities with a variety of transportation choices.
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2050 Regional Transportation Plan/Sustainable Communities Strategy In 2011, SANDAG approved the 2050 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS).
This approval marked the first time SANDAG’s RTP included an SCS, consistent with Senate Bill 375, the Sustainable Communities and Climate Protection Act of 2008. This RTP/SCS provided a blueprint to improve mobility, preserve open space, and create communities, all with transportation choices to reduce greenhouse gas emissions and meet specific targets set by the California Air Resources Board as required by Senate Bill 375. 2021 Regional Plan
SANDAG is required to update its RTP every 4 years. In December 2021, SANDAG adopted the latest update to its RTP/SCS. SANDAG’s 2021 RTP/SCS, known as the 2021 Regional Plan, builds upon SANDAG’s 2019 RTP/SCS, known as the 2019 Federal Regional Transportation Plan.
The 2021 Regional Plan updates growth forecasts and is based on the most recent planning assumptions, including adopted land use plans including the City’s General Plan and other factors from the cities in the region and the County (SANDAG 2021a). SANDAG’s Regional Plan will change in response to the ongoing land use planning of the City and other jurisdictions. For example, the City’s General Plan, and other local general plans, may change based on general plan amendments initiated by the jurisdiction or landowner applicants. The general plan amendments may result in increases in development densities by amending the regional category designations or zoning classifications. Accordingly, the latest forecasts from the SANDAG RTP/SCS for future development in the San Diego region, including location, must be coordinated closely with each jurisdiction’s ongoing land use planning because plans are not static, as reflected by the need for updates to SANDAG’s RTP/SCS every 4 years.
Series 14 Regional Growth Forecast
The SANDAG Series 14 Regional Growth Forecast serves as the foundation for the 2021 Regional Plan and other planning documents across the region (SANDAG 2018) . This summary includes an overview of the regional demographic, economic, and housing trends expected over the next 34 years. 6th Cycle Regional Housing Needs Assessment
State law requires that jurisdictions provide their fair share of regional housing needs. The California Department of Housing and Community Development is mandated to determine the statewide housing need. In cooperation with Department of Housing and Comm unity Development, local governments and councils of government are charged with determining the City’s or region’s existing and projected housing need as a share of the statewide housing need.
5.12.1.2 Existing Population and Housing Setting
The approximately 44.78-acre project site was used for agriculture until 1941, when it was developed as the Rohr Aircraft Facility, which employed thousands of Chula Vista residents for more than 60 years. The site was previously developed with two main industrial buildings and several smaller outbuildings . One of the buildings was approximately 282,004 square feet and was used for research and development, tooling, and warehous ing and distribution of aftermarket products until early 2021. The other two larger buildings had a combined square footage of 733,977. There were also 11 smaller outbuildings totaling 32,860 square feet. These buildings were used for manufacturing, warehouse, and distribution operations until approximately 2020. All structures in Planning Areas
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opportunities, however, this population growth would not be considered unplanned because the proposed project would restore what was previously a major job center for the City of Chula Vista.
The project site has been developed for decades and the surrounding area is substantially developed with mixed uses of commercial, and industrial uses. In addition, there are new development projects currently underway consisting of hotel, residential, and retail uses. Consequently, there is already significant existing infrastructure surrounding the project site. The project would be required to upgrade utility infrastructure and improve ingress and egress to the site. These improvements would serve the pr oposed project directly and would not indirectly induce unplanned population growth in the area.
Furthermore, the Growth Management Element of the City of Chula Vista’s General Plan outlines the measures necessary to direct and coordinate growth and development in ways to improve the quality of life for current and future residents of Chula Vista. The proposed project fosters a development pattern that promotes orderly growth by developing on a site with previous industrial uses and improving the quality of life for current and future Chula Vista residences by restoring employment opportunities.
The proposed project would directly contribute to population growth in the area that is comparable to previous existing conditions and would not be considered substantial. Impacts would be less than significant.
Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No existing residential uses occupy the project site as the site was previously developed with industrial buildings, which have since been demolished. The proposed project does not include the construction of any residential units and would not displace existing housing or people or necessitate the construction of replacement housing elsewhere. No impact would occur.
5.12.4 Level of Significance prior to Mitigation
Impacts to housing and population would be less than significant.
5.12.5 Mitigation Measures
No mitigation is required.
5.12.6 Level of Significance after Mitigation
Impacts to housing and population would be less than significant.
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5.13 Public Services
This section describes the existing public services conditions of the project site , which includes police and fire protection, schools, and libraries; identifies associated regulatory requirements; and evaluates potential impacts related to implementation of the proposed project. Impacts to parks and recreation facilities are addressed in Section 5.14, Recreation.
5.13.1 Regulatory Framework
Federal
National Fire Protection Association
The National Fire Protection Association recommends that fire departments respond to fire calls within six minutes of receiving the request for assistance 90% of the time. These time recommendations are based on the demands created by a structural fire. It is crucial to attempt to arrive and intervene at a fire scene prior to the fire spreading beyond the room of origin. Total structural destruction typically starts within 8 to 10 minutes after ignition. Response time is generally defined as 1 minute to receive and dispatch the call, 1 minute to prepare to respond to the fire station or field, and 4 minutes (or less) travel time.
State
2019 California Fire Code
The California Fire Code (CFC; 24 CCR, Part 9) was published on July 1, 2019, and effective January 1, 2020. The CFC establishes regulations to safeguard life and property against hazards of fire, explosion, or dangerous conditions in new and existing buildings, structures, and premises. The CFC also establishes requirements intended to provide safety and assistance to firefighters and emergency responders during emergency operations. The provisions of the CFC apply to the construction, alteration, movement , enlargement, replacement, repair, equipment, use and occupancy, location, maintenance, removal, and demolition of every building or structure throughout the State of California. The CFC includes regulations regarding fire -resistance-rate construction, fire protection systems such as alarm and sprinkler systems, fire service features such as fire apparatus access roads, means of egress fire safety during construction and demolition, and wildland–urban interface areas.
Mello -Roos Community Facilities Act of 1982
The Mello -Roos Community Facilities Act of 1982 permits the establishment of Community Facilities Districts (CFDs), commonly referred to as “Mello -Roos.” CFDs are special districts established by local governments as a means of financing public facilities, including schools, through a special tax imposed on the property within the CFD. The project site is located within existing CFDs for both the Chula Vista Elementary School District ( CVESD) and the Sweetwater Union High School District (SUHSD).
Leroy F. Greene School Facilities Act/California Senate Bill 50/Proposition 1A Two public school districts provide primary and secondary school facilities and services within the City: CVESD (kindergarten through 6th grade) and SUHSD (7th through 12th grade). Senate Bill 50 of 1998 enacted the Leroy F. Greene School Facilities Act an d allows school districts to levy a fee, charge, dedication, or other requirement
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against any development project within its boundaries for the purpose of funding the construction or reconstruction of school facilities. Some provisions of SB 50 were contingent on later voter approval of a bond issue, which the voters approved via Proposition 1A in November 1998. The statutes have been amended several times. Currently, the amount of fees varies by square footage, type of use, and the availability of other State funds for school facilities, and is subject to an inflation factor. Pursuant to California Government Code Section 65996, the payment of these fees by a developer serves to fully mitigate all potential project impacts on school facilities.
Local
City of Chula Vista General Plan
The City’s General Plan (General Plan) was adopted on December 13, 2005, and last amended on March 17, 2020.
The Public Facilities and Services Element establishes the City’s plan to provide and maintain infrastructure and public services for future growth (City of Chula Vista 2005a).
Fire Protection Services
The General Plan recognizes that fire protection and emergency services will need to expand as the population in the City of Chula Vista grows. The Public Facilities and Services Element includes objectives to maintain sufficient levels of fire protection and emergency medical service to protect public safety and property (Objective PFS 5) and provide adequate fire protection services to newly developing and redeveloping areas of the City (Objective PFS 6).
Additionally, GM 1 and Policy GM 1.11 provide for withholding discretionary approvals and subsequent building permits from projects demonstrated to be out of compliance with applicable threshold standards for fire and emergency medical services (City of Chula Vista 2005a).
Police Protection Services
The Public Facilities and Services Element of the General Plan includes objectives to maintain sufficient levels of police service to protect public safety and property (Objective PFS 5) and to provide adequate police protection services to newly developing and redeveloping areas of the City (Objective PFS 6). Additionally, Growth Management Objective GM 1 and Policy GM 1.11 provide for withholding discretionary approvals and subsequent building permits from projects demonstrated to be out of compliance with applicable threshold standards for police services (City of Chula Vista 2005a).
Schools
The General Plan recognizes that demand for school facilities will continue to increase as the City’s population grows and states that it is the intent of the City to facilitate the efforts of the districts to provide school services.
The Public Facilities and Services Element includes objectives to efficiently locate and design school facilities (Objective PFS 9 and10) (City of Chula Vista 2005a).
Libraries
The General Plan recognizes that demand for library facilities will continue to increase as the City’s population grows in the eastern areas of the City through new development, and that location is the most important reason residents choose to patronize a particular public library. The General Plan Public Facilities and Services Element includes objectives for the City to provide a library system of facilities and programs that meets the needs of Chula Vista residents of all ages (Objective PFS 11) and to efficiently locate and design library facilities (Objective PFS 12).
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Additionally, Growth Management Objective GM 1 and Policy GM 1.11 provide for withholding discretionary approvals and subsequent building permits from projects demonstrated to be out of compliance with applicable threshold standards for library services (City of Chula Vista 2005a).
Chula Vista Public Facilities Development Impact Fee
In August 1989, the Chula Vista City Council adopted Ordinance No. 2320 establishing a Public Facilities Development Impact Fee (PFDIF), which helps cover the cost of new or expanding public facilities within the City (City of Chula Vista 2005b). The facil ities are required to support future development within the City, and the fee schedule has been adopted in accordance with California Government Code Section 66000. The proposed project would be subject to the payment of the fee at the rate in effect at the time building permits are issued. The PFDIF amount is determined through evaluation of the need for new facilities as it relates to the level of service demanded by new development, which varies in proportion to the equivalent dwelling unit generated by a specific land use.
The PFDIF addresses the project’s proportional impact on capital facilities, such as structures and equipment. It does not address the impact associated with operations and maintenance for those facilities. Public funds such as property taxes, sales taxes, and fees generated by the project would be used to cover the incremental costs associated with providing services. The project would be required to pay the PFDIF, which would be used exclusively for future facility improvements necessary to ensure that the development contributes its fair share of the cost of facilities and equipment determined to be necessary to adequately accommodate new development in the City.
Chula Vista Municipal Code
CVMC Section 19.80.030 is intended to ensure that new development would not degrade existing public services and facilities below acceptable standards.
City of Chula Vista Public Library Strategic Facilities Plan The City of Chula Vista Public Library (CVPL) Strategic Facilities Plan is intended as a foundation for the City and the library in planning the future of library facilities in Chula Vista. The CVPL Strategic Facilities Plan includes goals and objectives for implementing the library’s vision and miss ion. These goals include maintaining an excellent and responsive materials collection, ensuring high quality of public library services through appropriate planning processes, ensuring that library programs and services are accessible to the broadest range of potential users, and increasing the visibility and community awareness of the library, its services, programs, and funding needs (City of Chula Vista 2011).
City of Chula Vista Public Library Strategic Vision Plan The CVPL Strategic Vision Plan is a companion volume to the CVPL’s 2011 Strategic Facilities Plan (City of Chula Vista 2014). The 2014 CVPL Strategic Vision Plan would guide the CVPL’s service directions for the next decade, and summarizes the community’s vision for the CVPL, strategic discussions for library services and facilities, and associated updates to the Strategic Facilities Plan.
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5.13.1.1 Existing Public Services Setting
Police Protection
Police protection for the City of Chula Vista (City) is provided by the Chula Vista Police Department (CVPD), with its singular headquarters located at 315 4 th Avenue, Chula Vista, California. The CVPD provides full -service police protection operating 24 hours a day, 7 days a week and staffed by 283 officers, 120 civilian employees, and dozens of volunteers. The current ratio of police officers required to adequately serve the residents of the City is 1.02 sworn police officers per 1,000 residents. CVPD has primary law enforcement jurisdiction in the city and responds to all reports of criminal activities and emerg encies. All police officers and dispatchers meet requirements set by the California Commission on Peace Officer Standards and Training. Under the Chief of Police, CVPD is split into five divisions: Community Engagement Division, Patrol Operations, Investig ations, Support Operations, and Administrative Services. The Community Engagement division includes the Research, Crime and Intelligence Analysis Unit, the Public Information Unit, the Community Policing Unit, the Public Information Unit, the Police Technology Unit, and the Audit and Accountability Unit. The Patrol Operations Division consists of the Community Patrol Unit, School Resource Officer Unit, Traffic Unit, and the Street Team and Gang Suppression Unit. The Investigation Division consists of the Cr iminal Investigations Division, the Special Operations Division, and the Strategic Operations Unit. The Support Operations Division consists of the Communications Center, City Jail, and the Professional Standards Unit. The Administrative Services Division consists of Fiscal Operations and Police Support Services.
Priority 1 calls are defined as emergency calls, which include life threatening calls, felony in progress, probability of injury (crime or accident), robbery or panic alarms, and/or urgent cover calls from officers (City of Chula Vista 2020a).
Priority 1 calls may require a response such as an immediate response by two officers from any source or assignment and/or immediate response by paramedics/fire if injuries are believed to have occurred. Priority 2 calls are defined as urgent calls, which include: misdemeanor in progress, possibility of severe injury, serious non -routine calls (domestic violence or other disturbances with potential for violence), and/or burglar alarms (City of Chula Vista 2020a). Priority 2 calls may require a response such as an immediate response by one or two officers, from clear units, or those on interruptible activities (traffic, field interviews, etc.).
The CVPD has an average response time of 6 minutes and 14 seconds and responds to 76.43% of calls within 7 minutes and 30 seconds (City of Chula Vista 2021). For Priority 2 calls, the average actual response time is 14 minutes and 47 seconds. As of January 2021, the CVPD does not meet the threshold standards for Priority 1 threshold standards (for both Goal 1 and Goal 2), or the Priority 2 threshold standards. However, due to staffing shortages, CVPD does not expect to meet the threshold for the next 1–5 years (City of Chula Vista 2021). Further, beginning on October 22, 2018, CVPD began deploying drones from the rooftop of the CVPD Headquarters to respond to 911 calls and other reports of emergency incidents such as crimes in progress, fires, traffic accidents, and reports of dangerous subjects. This unique concept of operations is called Drone as First Responder (DFR) and it is a transformational method of policing that has demonstrated the ability to increase officer and community safety and reduce overall police response times (City of Chula Vista 2021).
CVPD maintains a mutual aid agreement with the San Diego County Sheriff’s Office. If CVPD encounters an emergency situation that is beyond the extent or control of their resources, under the terms of the mutual aid agreement, the San Diego Sheriff’s Office can provide police enforcement upon request by CVPD. Additionally, the City is a part of the California Disaster and Civil Defense Master Mutual Aid Agreement. This agreement states that all resources and facilities of the state, its various departments a nd agencies, and all its political subdivisions, municipal corporations, and other public agencies be made available to prevent and combat the effect of disasters
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5.13.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to public services are based on Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). According to Appendix G, a significant impact related to public services would occur if the project would:
1. Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
Fire protection.
Police protection.
Schools.
Other public facilities.
5.13.3 Impact Analysis
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
Fire protection
Based on current CVFD fire station distribution, Fire Stations 1, 2, and 3 are most likely to provide the initial response to the project site. However, all stations within CVFD are available to service the project site if necessary.
As depicted in Table 5.13-1, CVFD Station No. 1, located at 447 F Street, is the closest station to the project site.
This station is staffed by 9 firefighters with a Type 1 fire engine, a ladder truck, and a battalion chief vehicle . Fire Stations 2 and 3, which are located at 80 East J Street and 100 Moss Street, respectively, are the next two closest stations that could respond to the site. Station 2 is located 2.8 miles away and is equipped with a Type 1 engine, an OES 420 engine, and an ambulance. Station 3 is located 3.2 miles away and is equipped with a heavy rescue apparatus, ambulance, and a tender/trailer.
The City’s PFDIF addresses a project’s proportional impact on capital facilities, such as structures and equipment, associated with fire protection. The PFDIF does not address the impacts associated with operations and maintenance for those facilities, and it is the City’s policy to use public funds such as property taxes, sales taxes, and fees generated by the proposed project to cover the incremental costs associated with providing fire services.
The project would not substantially increase the demand of fire protection services requir ing the construction of new or expanded fire protection facilities or facilitate the need for additional firefighters and equipment. Prior to demolition of the buildings onsite, they were being serviced by CVFD and once the proposed project is constructed CVFD would continue to provide fire suppression and emergency services to the site. Therefore, with continued service from CVFD, and payment of PFDIF fees, the project would have a less-than-significant impact on fire protection services.
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Police protection
The project would require typical police protection services for a commercial/industrial development. CVPD would provide law enforcement services to the project site. CVPD currently provides police service to the project site from its existing police facility in downtown Chula Vista. Because the project does not include residences, there would not be an increase in population.
The City’s PFDIF, described previously, would help cover the cost of new or expanding public facilities within the City, including police facilities. The proposed project would be subject to payment of the PFDIF fees at the rate in effect at the time building permits are issued. Payment of the PFDIF would be necessary to ensure that the project contributes its fair share of the cost of police facilities and equipment needed to adequately accommodate increasing demand within the City. Similar to fire suppression services, the previous buildings onsite were being serviced by the CVPD and service will continue once the proposed project is built. Therefore, with continued service from CVPD to the project site, and with the payment of PFDIF fees, the project would have a less-than-significant impact on police protection.
Schools
The proposed project would not increase the number of dwelling units or population within the City; therefore, there would not be an increased number of students generated by the project. Schools are funded through the payment of state mandated school fees pursuant to Senate Bill 50/California Government Code Section 65995. CVESD and SUHSD both collect Level I fees for new commercial/industrial developments (CVESD 2020; SUHSD 2022). These fees are required to be paid by future development prior to issuance of building permits.
As stated previously, the project site is located within existing CFDs for CVESD and SUHSD, which impose a special tax on property owners to finance both school districts. Any development of new school facilities resulting from these CFDs would be undertaken by the school dis trict at that time. Pursuant to Education Code Section 17620(a)(1), the governing board can authorize the levy of a fee, charge, dedication, or other requirements against any construction within school district boundaries, and with the school district’s co llection of Statutory and Alternative fees developers can fully mitigate any impacts. Payment of these fees is considered adequate; therefore, the proposed project would have a less-than-significant impact on schools.
Other public facilities
The CVPL Strategic Vision Plan establishes a standard of 500 square feet of adequately equipped and staffed library facilities per 1,000 residents (City of Chula Vista 2014). The proposed project would not result in increased demand for libraries and would not have the potential to require the construction of new or expanded library facilities.
Because the project is considered a commercial development, payment of PFDIF for libraries is not required. The proposed project would result in no impact on libraries.
5.13.4 Level of Significance prior to Mitigation
Impacts associated with fire protection, police protection, schools, and libraries would be less than significant.
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5.13.5 Mitigation Measures
No mitigation measures are required.
5.13.6 Level of Significance after Mitigation
Impacts associated with fire protection, police protection, schools, and libraries would be less than significant.
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5.14 Recreation
This section describes the existing recreational facilities adjacent to the project site and vicinity, identifies associated regulatory requirements, and evaluates potential impacts related to implementation of the Rohr Wohl Specific Plan Project (project or proposed project).
5.14.1 Existing Conditions
5.14.1.1 Regulatory Framework
Federal
No federal regulations or guidelines relating to recreation apply to the proposed project.
State
Quimby Act
The Quimby Act, enacted in 1975, creates a framework that allows cities and counties to provide parks for growing communities. The Quimby Act authorizes jurisdictions to adopt ordinances that require parkland dedication or payment of in -lieu fees as a cond ition of approval of residential subdivisions, The Quimby Act also specifies acceptable uses and expenditures of such funds, such as allowing developers to set aside land, donate conservation easements, or pay direct fees for park improvements.
Proposition 40 Park Bond Act
Proposition 40, also known as the Park Bond Act, allows for the maintenance for preservation of parks of the state’s growing population by borrowing money through general obligation bonds for the development, restoration, and acquisition of state and local parks, recreation areas and historical resource s, and for land, air, and water conservation programs.
Local
City of Chula Vista General Plan
The Public Facilities and Services Element in the City of Chula Vista’s General Plan contains objectives to provide new park and recreation facilities for residents of new development (Objective PFS 15 and PFS 16) (City of Chula Vista 2005). Policy PFS 15.3 promotes the inclusion of park and recreational facilities in or near redevelopment area to serve both new development and to adhere to the existing park and recreation needs. Policy PFS 15.1 pursues the provision of developed parkland for new developmen t project of three acres per one thousand residents. The City’s existing parkland to resident ratio conditions do not meet the standards defined in Chula Vista Municipal Code (CVMC) 17.10.040. However, according to the City’s Parks and Recreation Master Plan, in 2030, the City’s forecasted population would be 340,215 , resulting in the need for 1,237 total acres of developed parkland to meet the threshold (City of Chula Vista 2018). With the projected population and the planned additional 363 acres of new pa rkland, the City would have a parkland ratio of 3.64 acres of parkland per 1,000 residents.
Policy 1.30 within the City’s Parks and Recreation Master Plan also intends to encourage the development of
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bikeways, trails, and paths that provide connections to the community and surrounding communities’ parks and recreational facilities.
The City’s General Plan includes a network of open space and trails that abut other regional open space areas and trails in the area, including: the Bayshore Bikeway; California Riding and Hiking Trail; Sweetwater Valley trail system; the future Otay Valley Regional Park (OVRP) trail system; and the open space preserve in the eastern portion of Otay Ranch. The previously mentioned open spaces and trail networks are regional facilities that connect to the City’s network. The goals of the General Plan are to provide and maintain infrastructure and public services and improve sustainability of the City’s natural resources as established in the Public Facilities and Services and Environmental Elements of the General Plan. The Environmental Element of the General Plan establishes the policy framework for improving sustainability through the responsible stewardship of the City’s natural and cultural resources (Objective E.11), including the preservation of open space and development of connecting trails (City of Chula Vista 2005).
The City is committed to providing an integrated network of open space areas throughout the City to serve residents, as well as to serve as a regional asset and attractor of visitors. The City has significant open space areas with a variety of natural resources. The City has taken a multi-track approach to the conservation and management of its open space resources. Additionally, Growth Management Objective GM 1 and Policy GM 1.11 provide for withholding discretionary approvals and subsequent building permits from projects demonstrated to be out of compliance with applicable park threshold standards (City of Chula Vista 2005).
City of Chula Vista Municipal Code and Growth Management Ordinance CVMC Section 19.80.030, Controlled Development, is intended to ensure that development would not degrade existing public services and facilities below acceptable standards for parks and other public services. Similarly, CVMC Section 19.09, Growth Management, provides policies and programs that tie the pace of development to the provision of public facilities and improvements.
City of Chula Vista Greenbelt Master Plan
The City’s Greenbelt Master Plan provides guidance and continuity for planning open space and constructing and maintaining the Greenbelt Trail (City of Chula Vista 2003a). The Greenbelt Master Plan addresses existing and potential trail locations, trail and staging area development standards, maintenance responsibilities and a system of trails and open space that serve as a unifying element in linking other trails within the central areas of the City.
The future OVRP trail is planned parallel to the Otay River, approximately 1 mile south of the proposed project site (City of Chula Vista 2003b), and is part of the Chula Vista Greenbelt Trail system.
City of Chula Vista Parks and Recreation Master Plan
The City’s Parks and Recreation Master Plan describes a comprehensive parks and recreation system that serves the community at large through the delivery of a variety of park sites containing a variety of recreational experiences.
The master plan contains goals and policies that serve as a blueprint for creating a quality park system. The document establishes goals for the creation of a comprehensive parks and recreation system that meet the needs of the public by effectively distributing park types and associated recreation facilities and programs throughout the City (City of Chula Vista 2018).
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In addition, a third significance criterion from Section 5.13, Public Services, applies to impacts on recreation relating to parks:
Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental i mpacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services: Parks.
5.14.3 Impacts
Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? The proposed project includes development of a variety of open spaces and amenities that would be available to the public as well as employees. These include terraces, roof decks, overlooks, plazas, paseos, greenways, boardwalks, and courtyards.
As discussed previously, the City’s existing parkland to resident ratio conditions do not meet the standards defined in CVMC 17.10.040. However, the proposed project does not include the development of new residences and therefore would not require additional parkland be provided. There are two existing parks less than 0.5 miles from the project site that could be used by employees of the project. The increase in demand for parks or other recreational facilities by employees of the project is anticipated to be minimal, such that there would not be a substantial increase in the physical deterioration of existing park facilities. In addition, per CVMC Section
17.10.120, the proposed project would not be required to pay development fees because there are no proposed residences within the project. Therefore, because the proposed project would not cause substantial physical deterioration of a facility to occur or to be accelerated, the project would have a less-than-significant impact, and mitigation is not required.
Does the project include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment? Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
Parks.
The proposed project would not include any recreational facilities. However, as stated under Threshold 1, the project would provide open spaces and amenities such as terraces, roof decks, overlooks, plazas, paseos, greenways, and courtyards. This would provide the public with walkable and bikeable access to surrounding parks such as Bayside Park and J Street Harbor Park. The project would not induce substantial population growth such that expansion or construction of recreational facilities would be necessa ry because the project does not include new residents requiring recreational facilities . Therefore, the project would not require the construction of new recreational facilities or require the expansion of existing recreational facilities and impacts would be less than significant.
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5.14.4 Level of Significance prior to Mitigation
The project would have less-than-significant impacts associated with recreation.
5.14.5 Mitigation Measures
No mitigation measures are required.
5.14.6 Level of Significance after Mitigation
No mitigation measures would be required. The project would have less-than-significant impacts associated with recreation.
5.15 – TRANSPORTATION
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5.15 Transportation
This section describes the existing transportation setting near the proposed project, identifies associated regulatory requirements, and evaluates potential impacts and identifies mitigation measures related to conflicts with an applicable program, plan, ordinance, or policy addressing the circulation system including transit, roadway, bicycle and pedestrian facilities; conflict or inconsistency with California Environmental Quality Act (CEQA) Guidelines Section 15064.3(b); a substantial increase in hazards due to a geometric design feature; and inadequate emergency access.
The state’s adoption of Senate Bill (SB) 743 and subsequent adoption of CEQA Guidelines section 15064.3 provide that traffic delay under a level of service (LOS) metric is no longer considered a significant environmental impact under CEQA. State law now requires the use of a vehicle miles traveled (VMT) metric for land use development projects, which is intended to promote the state’s goals of reducing greenhouse gas emissions and traffic-related air pollution, while promoting the development of multimodal transportation system, and providing clean, efficient access to destinations. This CEQA transportation impact analysis presents and uses the current VMT metric to best evaluate and disclose project impacts in a manner consistent with current state law and policies.
The proposed project consists of 3 planning areas: the eastern portion of the project site, closest to I-5 (between G Street and H Street), is designated as Planning Area A and is 9.29 acres. The largest planning area is Planning Area B-1, which is 26.13 acres, and Planning Area B-2, which is located south of B-1 and is 9.36 acres (Figure 4-2, Site Plan). A Project Information Form (PIF) has been prepared for Planning Area B-1. It should be noted that the entire Project (Planning Areas A, B-1, and B-2) will be screened out from conducting a detailed CEQA VMT analysis based on satisfying the criteria of the Project being located in a VMT-efficient area. The proposed project’s VMT and other CEQA analysis are provided in this section and the traffic analysis using the LOS metric is provided consistent with City of Chula Vista (City) requirements and for informational purposes in Appendix K. This section relies on VMT to determine significance due to the requirements of SB 743; however, a discussion of LOS is provided for informational purposes.
▪ Appendix K: Rohr/Wohl Specific Plan Planning Area B -1, Planning Areas A & B -2, Local Mobility Analysis, prepared by Mizuta Traffic Consulting Inc., April 2024
5.15.1 Existing Conditions
This section provides a summary of the existing circulation network, bicycle and pedestrian facilities, and transit service near the proposed project.
Existing Street System
E Street is classified as an east-west 4-lane Class I Collector roadway west of Interstate (I) 5, a 4-lane gateway street between I-5 and Broadway, and a 4-lane urban arterial east of Broadway. Sidewalks are provided on both sides of the roadway. On-street parking is prohibited on both sides of the roadway. The posted speed limit is 30 miles per hour (mph).
F Street is classified as an east-west 4-lane Downtown Promenade between I-5 and Broadway and a 2-Downtown Promenade east of Broadway. Sidewalks are provided on both sides of the roadway. On-street parking is prohibited on both sides of the roadway. The posted speed limit is 30 mph.
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G Street is currently functioning as an east -west 2-lane roadway from Marina Parkway to approximately 350 feet west of Bay Boulevard, which widens to a 4-lane roadway to Bay Boulevard. Sidewalks are provided on both sides of the roadway on the 4-lane section. There are no posted speed limits in the area.
H Street is classified as an east-west 4-lane major street between Marina Parkway and Street A and transitions to a 5 -lane major street until the I -5 interchange. However, the roadway is currently not built to its ultimate classification and functions as a 3-lane roadway with two travel lanes in the westbound direction, one travel lane in the eastbound direction, and a center two-way left-turn lane. urban arterial in the immediate vicinity of the Project with two travel lanes provided in each direction. Sidewalks are provided on the north side of the roadway. On-street parking is prohibited on both sides of the roadway. There are no posted speed limits in the area.
J Street is classified as an east-west 4-lane major roadway east of the I-5 interchange. Sidewalks are provided on both sides of the roadway. On-street parking is prohibited on both sides of the roadway. The posted speed limit is 30 mph.
L Street is classified as an east-west 4-lane gateway street between the I-5 interchange and Broadway and a 4-lane Class I Collector roadway east of Broadway. Sidewalks are provided on both sides of the roadway. On-street parking is prohibited on both sides of the roadway. The posted speed limit is 35 mph.
Marina Parkway is classified as a north-south 4-lane major street between the I-5 interchange and H Street. Marina Parkway transitions into J Street east of the I-5 interchange. There are intermittent sidewalks provided on both sides of the roadway. On-street parking is prohibited on both sides of the roadway. The posted speed limit is 35 mph.
Bay Boulevard is classified as a 2-lane Class II Collector from E Street to F Street and transitions to a 2-lane Class III Collector from F Street to J Street. Sidewalks are provided on the west side of the roadway. On -street parking is prohibited on both sides of the roadway. The posted speed limit is 35 mph.
Figure 5.15-1 illustrates the roadway classification per City’s Circulation Plan for Roadways.
Pedestrian Facilities
The roadway segments in the vicinity of the proposed project and located west of I-5 generally have sidewalks on one or both sides of the roadway except for the following locations:
▪ Lagoon Drive: Last 600 feet prior to turning into Marina Parkway ▪ Marina Parkway: Between Lagoon Drive and H Street
▪ G Street: Between Marina Parkway and Bay Boulevard
Pedestrians can walk along the west side of Bay Boulevard and cross the respective cross streets of F Street and H Street within the marked crosswalks. North of F Street, pedestrians would walk along the east side of Bay Boulevard until E Street. All curb ramps at the Bay Boulevard & H Street intersection have detectible warning strips.
The other intersections along Bay Boulevard do not have detectible warning strips.
Figure 5.15-2 illustrates the Pedestrian Route Types per City’s Active Transportation Plan.
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Bicycle Facilities
There is a Class I bicycle path along the south side of H Street between Marina Parkway and Bay Boulevard and connects with the existing Bayshore Bikeway. There is a Class II bicycle lane on both sides of Bay Boulevard between E Street and L Street, both sides of F Street between Marina Parkway and I -5, and both sides of Marina Parkway between F Street and J Street.
Figure 5.15-3 illustrates the Existing and Planned Bike Facilities per City’s Active Transportation Plan.
Transit Facilities
The Metropolitan Transit Service provides transit service to the E Street and H Street trolley stops with Routes 701, 704, 705, 709, and 932. There are no transit stops located west of I-5. Route 701 provides daily service between the H Street Transit Center and Palomar Street Transit Center. Headways are approximately 20 minutes during the weekday peak-hours.
Route 704 provides daily service between the E Street Transit Center and Palomar Street Transit Center. Headways are approximately 30 minutes during the weekday peak-hours.
Route 705 provides service on Monday through Saturday between the E Street Transit Center and Southwestern College. Headways are approximately 30 minutes during the weekday peak-hours.
Route 709 provides daily service between the H Street Transit Center and Eastlake. Headways are approximately 30 minutes during the weekday peak-hours.
Route 932 provides daily service between the 8th Street Transit Center and Iris Avenue Transit Center with stops at the E Street Transit Center. Headways are approximately 20 minutes during the weekday peak-hours.
The nearest transit stops (Routes 701 and 709) to the Project are located at the H Street Transit Center and approximately a 1,000-foot walk to/from the Project.
Figure 5.15-4 illustrates the Transit Facilities within a half-mile of the project site.
Vehicle Miles Traveled
For VMT, the San Diego Association of Governments ( SANDAG) Regional Activity-Based Model outputs produce existing VMT per Capita and VMT per Employee for residents and employees, respectively, that live in the San Diego region. The SANDAG average VMT per employee for the region in the baseline or existing conditions is 18.90. The Project is located in Census Tract 12600, which has an average VMT per employee of 15.91. Census Tract VMT is 16 percent lower than the regional average.
Figure 5.1.5-5 illustrates the project census tract per SANDAG’s VMT screening map.
5.15.2 Regulatory Framework
Federal
No federal regulations or guidelines relating to transportation apply to the proposed project.
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State
Senate Bill 743
On September 27, 2013, Governor Brown signed Senate Bill (SB) 743, which became effective on January 1, 2014.
The purpose of SB 743 is to streamline the review under the CEQA process for several categories of development projects, including the development of infill projects in transit priority areas, and to balance the needs of congestion management with statewide goals related to infill development, promotion of public health through active transportation, and reduction of greenhouse gas emissions. SB 743 adds Chapter 2.7, Modernization of Transportation Analysis for Transit Oriented Infill Projects, to the CEQA Statute (California Public Resources Code, Section 21099). Section 21099(d)(1) provides that aesthetic and parking impacts of a residential, mixed -use residential, or employment center project on an infill s ite within a transit priority area shall not be considered significant impacts on the environment. In addition, SB 743 mandates that alternative metrics for determining impacts relative to transportation shall be developed to replace the use of LOS in CEQA documents.
In the past, environmental review of transportation impacts focused on the delay that vehicles experience at intersections and on roadway segments, which is often measured using LOS. Mitigation for impacts on vehicular delay often involves increasing capacity, such as widening a roadway or increasing the size of an intersection, which in turn encourages more vehicular travel and greater pollutant emissions. Additionally, improvements to increase vehicular capacity can often discourage alternative forms of transportation such as biking and walking. SB 743 directed the Governor’s Office of Planning and Research (OPR) to develop an alternative metric for analyzing transportation impacts in CEQA documents. The alternative shall promote the state’s goals of reducing greenhouse gas emissions and traffic- related air pollution, promoting the development of multimodal transportation system, and providing clean, efficient access to destinations. Under SB 743, it was anticipated that the focus of transportation analysis would shift from vehicle delay to VMT within transit priority areas (i.e., areas well served by transit).
Pursuant to SB 743, OPR released the draft revised CEQA Guidelines in November 2017, recommending the use of VMT for analyzing transportation impacts. Additionally, OPR released updates to the Technical Advisory on Evaluating Transportation Impacts in CEQA (OPR 2018), to provide guidance on VMT analysis. In this Technical Advisory, OPR provides its recommendations to assist lead agencies in screening out projects from VMT analysis and selecting a significance threshold that may be appropriate for their particular jurisdiction. While OPR’s Technical Advisory is not binding on public agencies, CEQA allows lead agencies to “consider thresholds of significance . . . recommended by other public agencies, provided the decision to adopt those thresholds is supported by substantial evidence” (14 CCR 15064.7[c]).
In December 2018, the CEQA Guidelines were updated to add new Section 15064.3, Determining the Significance of Transportation Impacts, which describes specific considerations for evaluating a project’s transportation impacts using the VMT methodology. This new methodology is required to be used for projects beginning on July 1, 2020.
CEQA Guidelines Section 15064.3(b) is divided into four subdivisions as follows:
Land Use Projects. Vehicle miles traveled exceeding an applicable threshold of significance may indicate a significant impact. Generally, projects within one-half mile of either an existing major transit stop or a stop along an existing high quality transit corridor should be presumed to cause a less than significant transportation impact. Projects that decrease vehicle miles traveled in the project area compared to existing conditions should be presumed to have a less than significant transportation impact.
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Transportation Projects. Transportation projects that reduce, or have no impact on, vehicle miles traveled should be presumed to cause a less than significant transportation impact. For roadway capacity projects, agencies have discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements. To the extent that such impacts have already been adequately addressed, such as in a regional transportation plan EIR, a lead agency may tier from that analysis as provided in Section 15152.
Qualitative Analysis. If existing models or methods are not available to estimate the vehicle miles traveled for the particular project being considered, a lead agency may analyze the project’s vehicle miles traveled qualitatively. Such a qualitative analysis would evaluate factors such as the availability of transit, proximity to other destinations, etc. For many projects, a qualitative analysis of construction traffic may be appropriate.
Methodology. A lead agency has discretion to choose the most appropriate methodology to evaluate a project’s vehicle miles traveled, including whether to express the change in absolute terms, per capita, per household or in any other measure. A lead agency may use models to estimate a project’s vehicle miles traveled, and may revise those estimates to reflect professional judgment based on substantial evidence. Any assumptions used to estimate vehicle miles traveled and any revisions to model outputs should be documented and explained in the environmental document prepared for the project.
The Project is a land use development, therefore 15064.3(b)(1) would apply and transportation impacts have been assessed using the VMT metric.
Statewide Transportation Improvement Program and Interregional Transportation Improvement Program
The State Transportation Improvement Program (STIP) run by the California Transportation Commission (CTC) is a five-year investment plan for state transportation money and is updated every two years. Capital highway, local road, transit, and active transportation projects that San Diego region plans to fund may be included in the STIP to receive state funding. The most recent STIP was adopted in March 2022 (SANDAG 2021a) and current proposed 2024 STIP is expected to be adopted in March 2024 by CTC. The San Diego region’s STIP is a subset of projects in the Regional Plan, which guides regional transportation investments for the next 20 years.
The regional spending plan developed by SANDAG accounts for 75% of the STIP. The remaining 25% of the STIP is a statewide spending plan known as the Interregional Transportation Improvement Program (ITIP) (Caltrans 2023).
California Government Code Section 14526 specifies that the purpose of the ITIP is to fund projects that improve interregional movement for people and goods across California on the State Highway System and develop Intercity Passenger Rail corridors of strategic importance. The ITIP is one of many state funding programs that collectively invest in transportation infrastructure, maintenance and operations and is prepared by Caltrans for submittal to the CTC to assist with recommendations for projects in the STIP. Caltrans develops the ITIP to fund projects that connect metro areas and improve mobility across regional boundaries. SANDAG, in cooperation with Caltrans, seeks opportunities to improve interregional connections between San Diego County and Orange County on the I -5 Corridor, Riverside County on the I -15 corridor, Imperial County on the I -8 corridor, and on the critical freight and passenger Los Angeles to San Diego (LOSSAN) rail corridor.
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Caltrans
Caltrans Transportation Impact Study Guide, May 20, 2020, provides that Caltrans’ primary review focus is VMT, replacing LOS as the metric used in CEQA transportation analyses (Caltrans 2020). Caltrans recommends use of OPR’s recommended thresholds and guidance on methods of VMT assessment found in OPR’s Technical Advisory (OPR 2018) for land use projects. In addition to VMT, the 2020 Transportation Impact Study Guide states that it may request a targeted operational and safety analysis to address a specific geometric or operational issue related to the state highway system and connections with the state highway system.
Regional
SANDAG San Diego Forward: The 2021 Regional Plan
The San Diego Association of Governments (SANDAG) San Diego Forward: The 2021 Regional Plan (2021 Regional Plan) was adopted by the SANDAG Board of Directors on December 10, 2021 (SANDAG 2021b). It includes the region’s Regional Transportation Plan (RTP); Sustainable Community Strategy (SCS), as required by SB 375; and Regional Comprehensive Plan. The 2021 Regional Plan provides a long-term blueprint for the San Diego region that seeks to meet r egulatory requirements, address traffic congestion, and create equal access to jobs, education, healthcare, and other community resources. The SCS describes coordinated transportation and land use planning that exceeds the state’s target for reducing per capita GHG emissions set by the California Air Resources Board (CARB).
For the first time, the 2021 Regional Plan incorporates five transformational strategies known as the 5 Big Moves:
Complete Corridors, Transit Leap, Mobility Hubs, Flexible Fleets, and Next Operating System. These interdependent strategies are desig ned to address the greatest transportation and mobility challenges , i.e., safety and traffic congestion, social inequities, and state and federal requirements, to reduce GHG emissions and air pollution.
The 2021 Regional Plan and its draft Environmental Impact Report were released for public and policymaker review in spring 2021 (SANDAG 2021c).
SANDAG also prepared a Regional Transportation Improvement Program (RTIP), a five-year investment plan that identifies projects and programs the San Diego region proposes to fund (SANDAG 2022). The primary purpose of the RTIP is to incrementally implement the latest Regional Plan, which guides regional transportation investments for the next 20 years. Projects funded with federal, state, or TransNet money must be included in an approved RTIP.
For SANDAG projects to be incorporated in the RTIP, projects must first be included in the SANDAG Program Budget approved by the SANDAG Board of Directors. The 2023 RTIP (SANDAG 2022) covers five fiscal years (FY 2023 through FY 2027) and incrementally implements the SANDAG 2021 Regional Plan. SANDAG was accepting public comments on RTIP Amendment No. 9 until January 19, 2024.
Local
City of Chula Vista General Plan
The City of Chula Vista General Plan (General Plan), known as Vision 2020, was adopted by the City on December 13, 2005 (City of Chula Vista 2005). The General Plan and its subsequent amendments form the foundation upon which all land use decisions in the City are based.
The General Plan and its associated Sectional Planning Area (SPA) Plans include goals and policies that guide the City’s growth. The General Plan currently includes many policies that relate to and support the intent of SB 743.The General Plan and SPA Plan policies that are most consistent with the intent of SB 743 are those regarding planned
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improvements, including new roadways and new pedestrian and bicycle facilities, and policies and programs to enhance and encourage bicycle, pedestrian, and transit modes. For example, the evaluation of existing transit services in order to enhance mobility and accessibility within Chula Vista, providing the provision of sidewalks along arterial roadways, providing the provision of shuttle services on some local roads, and the encouragement of the development of high-density mixed land use projects are among the existing Chula Vista policies that align with SB 743 (City of Chula Vista 2020a).
The project site is located in the Bayfront Planning Area and Harbor District subarea of the General Plan (City of Chula Vista 2005). The Land Use and Transportation Element establishes the land use categories, roadway classifications, and generalized land use patterns for City development and focuses on themes that (1) support strong community character and image, (2) support strong and safe neighborhoods, and (3) improve mobility.
Chula Vista Bayfront Specific Plan
Chapter 19.81 of the CVMC defines the scope and purpose of the Bayfront Specific Plan. This chapter of the CVMC is intended to implement the Chula Vista General Plan and the Chula Vista Local Coastal Program (LCP) Land Use Plan (LUP) and their goals, objec tives, and policies. Chapter 19.84 of the CVMC provides for the classification of land use and the regulation of development by land use and zoning parcel. The project is zoned as Industrial in the Bayfront Specific Plan. Chapter 19.85 of the CVMC outlines the development criteria for the Bayfront Specific Plan.
Chula Vista Bayfront Local Coastal Program Land Use Plan The Chula Vista Bayfront LCP Amendment Bayfront Specific Plan was adopted in 2012 and amended in 2017. It governs the development of 722 acres of the City’s bayfront. The LCP provides a detailed plan for the orderly growth, development, redevelopment, and conservation of the City jurisdictional parcels located within the Chula Vista Bayfront coastal area. Each coastal city and county’s LCP is required to be pursuant to the California Coastal Act and approved by the California Coastal Commission. This LCP is consistent with the City General Plan and represents a step toward systematic implementation of the General Plan in the bayfront. The LUP provides land use and development policies to ensure that development within the bayfront will be consistent with the provisions of the California Coastal Act. The project site is within the Harbor District subarea, described in the LCP. The LUP outlines objectives and policies as the standard review for coastal development permits (City of Chula Vista 2012).
Chula Vista Municipal Code
Chula Vista Municipal Code (CVMC) Chapter 3.54 establishes a Transportation Development Impact Fee to fund transportation improvements and facilities within the Eastern Territories of the City and requires payment prior to the issuance of building permits for development. Section 3.54.030 lists the transportation facilities to be financed by the fees collected and includes a total of 72 roadways within the City. In addition, CVMC Chapter 12.24, Dedications, imposes reasonable requirements upon developers of traffic-generating developments within the City to mitigate potential dangers associated with the (1) lack of sidewalks; (2) moving, high, and stagnant waters during the rainy season; (3) streets of inadequate widths; (4) poor drainage due to the lack of curbs, storm drain facilities and improved alleys; and (5) inadequate street lighting, to the extent reasonably possible.
City of Chula Vista Transportation Study Guidelines
The City of Chula Vista adopted their Traffic Study Guidelines (TSG) in June of 2020 to comply with SB 743. The guidelines were revised in January 2022. The TSG provides criteria to evaluate projects for consistency related to
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the City’s transportation goals, policies, and plans, and through procedures established under CEQA. The TSG establishes the content requirements and procedures for preparing a Transportation Study in Chula Vista (City of Chula Vista 202a).
The purpose of the TSG (and a Transportation Study) is to provide applicants, transportation professionals, and City personnel with standard procedures and guidelines to support CEQA review of a project's transportation impacts and a project’s effects on local traffic congestion through a Local Mobility Analysis (LMA).
The project’s VMT analysis per CEQA requirements is provided in this section. The project’s LMA prepared by Mizuta Traffic Consulting, Inc. is included as Appendix K. The approach and methodology for both CEQA and no -CEQA analyses are consistent with the City’s TSG for the purposes of evaluating the project’s potential transportation impacts and effects.
Active Transportation Plan
The City of Chula Vista adopted the Active Transportation Plan (ATP) on May 12, 2020. This plan is an update to the 2010 Pedestrian Master Plan and 2011 Bikeway Master Plan and combines these two documents into one integrated mobility plan focused primarily on non-motorized users and introduces recent micro-mobility trends new to the public roadways in Chula Vista. The ATP focuses enhancing the safety and comfort of existing pedestrian and bicycle facilities as well as increasing connectivity to key attracting land uses such as schools, employment centers, retail districts and recreational areas (City of Chula Vista 202b).
5.15.3 Methodology
In December 2018, the CEQA Guidelines were updated to include a threshold for evaluating traffic impacts using a VMT methodology. This new methodology was required to be used statewide beginning on July 1, 2020.
The City of Chula Vista has an adopted TSG which includes methodology, screening criteria, and analysis procedures for conducting a CEQA VMT analysis for projects located within the City. This section summarizes the methodologies used to perform the VMT analysis.
Vehicle Miles Traveled (CEQA Analysis)
The Updated CEQA Guidelines, Section 15064.3 state that “generally, vehicle miles traveled (VMT) is the most appropriate measure of transportation impacts” and define VMT as “the amount and distance of automobile travel attributable to a project.” “[A]utom obile” refers to on -road passenger vehicles, specifically cars and light trucks.
OPR has clarified in the Technical Advisory on Evaluating Transportation Impacts in CEQA (OPR 2018) (Technical Advisory) and recent informational presentations that heavy -duty truck VMT is not required to be included in the estimation of a project’s VMT. Other relevant considerations may include the effects of the project on transit and non-motorized traveled.
The City has adopted VMT analysis guidelines and thresholds (City of Chula Vista 2020a). For the purposes of the Project analysis, the VMT screening analysis methodology and thresholds identified within the City’s TSG were used.
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VMT Screening and Analysis Approach
The following will be the primary method of the Project’s VMT analysis:
Determine if the project can be screened out from requiring detailed VMT analysis and presumed as less than significant by comparing the project features to screening criteria presented in the City’s TSG.
Determine the VMT/Employee (for employment-based projects) using the VMT Screening Tool published by the City (consistent with SANDAG San Diego Region SB743 VMT Maps).
Compare the screening criteria or project results to the applicable or most appropriate threshold. For the proposed project, the project’s VMT/Employee is compared to the SANDAG regional average to determine if the project would have a potentially signific ant impact. Additionally, project is located within a Transit Accessible Area, however it does not meet the parking requirement specified for this VMT screening criteria.
The City’s TSG state the following criteria can be applied to effectively screen projects from project -level VMT assessment under the presumption that they would result in a less than significant transportation impact . The proposed project’s characteristics are also described for each screening criteria. ▪ Small Residential and Employment Projects : Projects generating 200 or less daily vehicle trips may be presumed to have a less than significant impact absent substantial evidence to the contrary. As shown in Table 5.15.1, the project would generate more than 200 daily trips. Therefore, the proposed project would not meet this screening criteria.
▪ Projects located in a Transit Accessible Area or Buffer (near Transit Priority Areas and near stops along High-Quality Transit Corridors): Within a Transit Buffer Projects located in a transit priority area 1 (TPA) or half-mile walkshed of an existing stop along a high-quality transit corridor2 may be presumed to have a less than significant impact, absent substantial evidence to the contrary. Projects must be entirely within a TPA or have a half -mile walkshed from all points within the project site to qualify for this screening. Projects located in a TPA and a half mile from stops along high -quality transit corridors can help reduce VMT by increasing capacity for transit-supportive residential and/or employment densities in low VMT areas. The increased density that is associated with projects in a TPA can incre ase transit ridership and therefore justify enhanced transit service which would in turn increase the amount of destinations that are accessible by transit and further increase transit ridership and decrease VMT. Additionally, the OPR Technical Advisory states, “generally should presume that certain projects (including residential, retail, and office projects, as well as projects that are a mix of these uses) proposed within ½ mile of an existing major transit stop or an existing stop along a high-quality transit corridor will have a less-than-significant impact on VMT.” This presumption is only appropriate if the project meets the following conditions:
A. Has a Floor Area Ratio (FAR) of more than 0.75: The project’s FAR is for Planning Area A is 3.0, for Planning Area B1 is 1.0 and Planning Area B-2 is 2.0, therefore the project FAR exceeds 0.75.
B. Includes no more than the minimum parking for use by residents, customers, or employees of the project as required by the City of Chula Vista: As shown in the project’s PIF form (Appendix K), the
1 A transit priority area is the area within 0.5 miles of a major transit stop, which is defined as a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bu s routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods. A high quality transit corridor is defined as a corridor with fixed-route bus service, with service intervals no longer than 15 minutes during peak commute periods. Pub. Resources Code Section 21064.3
2 Pub. Resources Code, Section 21155:“For purposes of this section, a high -quality transit corridor means a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours.”
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Planning Area B-1 would include 769 parking spaces and approximately 619 spaces are required per City’s code.
C. Is consistent with relevant City planning documents : The project is proposing amendments and would be governed by the Rohr Wohl Specific Plan; however based on the allowed and proposed land uses, the project is considered to be consistent with the goals and policies of City planning documents. See Table 5.10-1 in Land use and Planning section for a detailed consistency analysis.
D. Does not include a smaller number of units that previously on the project site: The project does not include housing unit and would not replace affordable residential units.
E. Does not replace affordable residential units with moderate- or high-income residential units.
As shown in Figure 5.15-5, VMT Screening Map for Project, the proposed project (A, B1, and B2) is in census tract 12600 which is within a transit buffer or is considered a TPA. The project is located within a 1 ,000- foot walkshed to the H Street Transit Center which is served by routes 701 and 709. As shown under analysis of Threshold a, the proposed project is consistent with relevant City planning documents. Because the proposed project provides more than the minimum parking requirements for Planning Area B-1, and due to unavailability of detailed parking requirements of uses proposed for Planning Area A and B -2, the transit buffer screening criteria is not met at the time of this writing. ▪ Local Serving Retail Projects: Local serving retail projects less than 125,000 square feet 3 and that would serve the local community may be presumed to have a less -than-significant impact absent substantial evidence to the contrary. The proposed project does not have any uses that would be considered local serving retail, therefore, this screening criteria would not apply. ▪ Local Serving Public Facilities and Community Purpose Facilities: Public facilities that serve the surrounding community or public facilities that are passive uses may be presumed to have a less than significant impact absent substantial evidence to the contrary. The proposed project does not include any local serving public facilities or community purpose facilities per City’s land use designation and municipal code, therefore, this screening criteria would not apply.
▪ Redevelopment Projects with Greater VMT: A redevelopment project may be presumed to have a less than significant impact absent substantial evidence to the contrary if the proposed project’s total project VMT is less than the existing land use’s total VMT. The proposed project would redevelop some of the existing uses and an existing use trip generation credit has been applied to estimate the project trip generation. However, due to the nature of the project, a development VMT has not been estimated for the proposed project. ▪ Affordable Housing: Any portion of a project that is composed of deed restricted affordable housing units may be presumed to have a less than significant impact absent substantial evidence to the contrary. The proposed project does not include affordable housing, therefore, this screening criteria would not apply. ▪ Projects located in a VMT -Efficient Area: A VMT-efficient area is any area within the City with an average VMT per Capita or VMT per Employee below the thresholds as compared to the baseline regional average for the census tract it is located within. The project meets this screening criteria. See analysis provided in Section 5.15.5 under Threshold b.
3 City of Chula Vista Transportation Study Guidelines (City of Chula Vista 2020a, p. 19): 125,000 square feet is the maximum size that a commercial development can be while still being considered Neighborhood Shopping Center by SANDAG’s (Not So) Brief Guide of Vehicular Trip Generation Rates for the San Diego Region.
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Projects that do not meet any screening criteria must include a detailed evaluation of the VMT produced by the project.
The significant thresholds and specific VMT metrics used to measure VMT are described by land use type below. ▪ Residential: 15% below regional average VMT per Capita ▪ Employment: 15% below regional average VMT per Employee ▪ Industrial Employment: At or below regional average VMT per Employee ▪ Mixed-Use: Each project component evaluated per the appropriate metric based on land use type (i.e. , residential, employment, and retail)
▪ Regional Retail, Regional Recreational, or Regional Public Facilities: A net increase in total regional VMT using the boundary method
▪ Other Project Types: TSG provides a list with unique land use categories and their appropriate VMT metric or thresholds of significance
The project’s VMT analysis is conducted using City VMT maps which incorporate SANDAG data, and using the VMT per employee metric for the entire site and includes the three planning areas.
Trip Generation
The project’s LMA consists of a combination of a project - and programmatic-level analyses using the project trip generation. The project-level analysis would be completed for the uses in Planning Area B -1. The programmatic- level analysis would be completed for the uses in Planning Areas A and B-2.
Trip generation rates published by the SANDAG Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region (SANDAG 2002) were applied to the existing and proposed uses on site to estimate the traffic generation characteristics of the site. Based on the truck splits from ITE Trip Generation Manual 11 th Edition, passenger cars would account for 83.1% trips of the total trips generated by a warehouse facility and the truck trips would account for approximately 16.9% of the total trips (ITE 2021). Additionally, the Warehouse Truck Fleet Mix from the South Coast Air Quality Management District’s (SCAQMD) Warehouse Truck Trip Study Data Results and Usage (SCAQMD 2014) was used to estimate project -related truck traffic split into two-axle, three-axle, and four -plus axle trucks.
These truck trips generated by the project were then converted to passenger car equivalent (PCE) trips by using recommended PCE factors, and their disproportionate effect on roadway capacity As shown in the table, the Project is forecasted to generate a subtotal of 7,520 daily trips with 903 AM peak-hour trips and 903 PM peak-hour trips for the Project-Level Analyses and a total of 8,168 daily trips with 487 AM peak- hour trips and 767 PM peak-hour trips for the Programmatic Level Analyses. After applying the existing trip credits, the Project-Level Analysis is forecasted to generate a net total of 5,115 daily trips with 446 AM peak-hour trips and 442 PM peak-hour trips. The Programmatic-Level Analysis is forecasted to generate a net total of 6,349 daily trips with 210 AM peak-hour trips and 460 PM peak-hour trips.
Adjusting for PCE, the Project is forecasted to generate a subtotal of 8,501 daily PCE trips with 1,065 AM PCE peak- hour trips and 1,065 PM PCE peak-hour trips for the Project-Level Analyses and a total of 8,581 daily PCE trips with 557 AM PCE peak-hour trips and 837 PM PCE peak-hour trips for the Programmatic Level Analyses. After applying the existing trip credits, the Project-Level Analysis is forecasted to generate a net total of 6,096 daily PCE trips with 608 AM peak-hour trips and 584 PM peak-hour trips. The Programmatic-Level Analysis is forecasted to generate a net total of 6,762 daily PCE trips with 280 AM PCE peak-hour trips and 530 PM PCE peak-hour trips.
The total net trip generation (non-PCE) is approximately 11,464 daily trips, 656 AM peak-hour trips and 882 PM peak-hour trips. Table 5.15.1 summarizes the weekday trip generation rates and calculations.
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5.15.4 Significance Criteria
The significance criteria used to evaluate the project impacts to transportation are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to transportation would occur if the project would:
1. Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.
2. Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b).
3. Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).
4. Result in inadequate emergency access.
5.15.5 Impacts
Would the project conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?
General Plan Consistency
The General Plan land use and transportation element for the city focuses on supporting strong community character and image, supporting strong and safe neighborhoods and improving mobility. The purpose and intent of the proposed project is to provide for compatible uses such as commercial, light industrial uses and business park uses on the underutilized project site, thereby creating new employment opportunities and successfully restoring what was a major job center for the City. The uses such as resort hotel , retail and restaurants would also complement the future development proposed in the Chula Vista Bayfront Master Plan to the south of the proposed project.
A detailed consistency analysis with the Land use and Transportation Element objectives and policies is provided in Table 5.10-1 in Section 5.10, Land Use and Planning.
The project’s LMA (Appendix K) provides potential effects relative to consistency with LOS policies used by the City over each of the study intersections. Pursuant to Public Resources Code Section 21099(b)(2) and CEQA Guidelines Section 15064.3(a), a project’s effect on automobile delay is not considered a significant environmental effect, therefore, no further discussion is required. However, the project would construct improvements or pay for its fair share towards roadway and/or intersection improvements such as signalization or optimizing signal timings to improve mobility around the project site.
As shown in the LMA, the project would be fully responsible for signalizing the Bay Boulevard & G Street and Project Driveway & H Street intersections and retiming the signals at the I-5 Northbound Ramps & E Street, Bay Boulevard & H Street, I-5 Northbound Ramps & H Street, and I-5 Northbound and Southbound Ramps & J Street intersections.
The Project would contribute its fair share towards the construction of a traffic signal or roundabout at the Bay Boulevard & F Street. The Project would contribute its fair share towards the construction of a traffic signal at the J Street and L Street intersections with Bay Boulevard. All proposed improvements would achieve LOS D or better conditions during both peak periods except for the roundabout at Bay Boulevard & F Street. The improvements identified in the LMA are recommendations and the final improvement plan and project funding responsibility will be defined and documented in a separate Rohr/Wohl Specific Plan Transportation Conditions of Approval memo.
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Bike and Pedestrian Facilities
The proposed project would not conflict with existing bike facilities along H Street and Bay Boulevard. According to the City’s ATP, there are three bicycle projects that are shown in the top 10 bicycle projects list near the proposed project. These projects include the following:
▪ H Street between Bay Boulevard and Third Avenue (Rank 1): Construct a multi-use path on both sides of the roadway.
▪ Bay Boulevard between E Street and H Street (Rank 6): Construct a multi-use path. ▪ F Street between Bay Boulevard and Third Avenue (Rank 7): Construct a multi-use path.
The Bayshore Bikeway segment between Lagoon Drive and H Street (referenced as Segment 6B in the City’s ATP) is proposed to be located along the abandoned rail line between Planning Area A and B -1/B-2. This extension of the Bayshore Bikeway would be a new multi-use path with proposed cross section of 14-feet width that includes a 5-foot shared use path and a 2 -foot shoulder in each direction. It should be noted that project construction, including subsequent phases of the project, would not conflict with the future construction of the proposed Bayshore Bikeway segment.
As part of the Chula Vista Bayfront Phase 1A Improvements Project, bicycle detectors will be added at the approach to the Bay Boulevard & H Street intersection. There is also a Class II bicycle lane on both sides of Bay Boulevard between G Street H Street.
As part of the Project, sidewalks will be constructed along the Project’s frontage of G and H Street. All Project driveways would be constructed to City standards and include warning detectible strips at the curb returns. The Chula Vista Bayfront Phase 1A Improvements consist of new 24-inch white thermoplastic ladder style crosswalks on the north, south, and west legs of the Bay Boulevard & H Street intersection. At the Marina Parkway & H Street intersection, a new traffic signal will be constructed and will include all new curb returns with warning detectible strips and a 24-inch white thermoplastic ladder style crosswalk on all legs of the intersection. Within the Project site, all internal roadways would have sidewalks on both sides of the roadway. No sidewalk gaps that would exist with the proposed project and pedestrians would have a continuous path from the Project to the H Street Transit Station.
Therefore, the proposed project would not conflict with existing or proposed bike and pedestrian facilities in its vicinity.
Transit Facilities
The H Street Transit Station is located in the 1,000 feet walkshed from the proposed project. There are no planned improvements for additional transit service on the west of I -5. There are no sidewalk gaps in the study area and pedestrians would have a direct connection between the proposed project and the H Street Transit Station via the existing sidewalks.
Therefore, as demonstrated above, consistency with the applicable plans addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities, the project’s impact would be less than significant.
Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)? The following discusses the proposed Project’s VMT analysis and impact determination and its consistency with CEQA Guidelines Section 15064.3(b). The proposed project would be categorized under CEQA Guidelines Section
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An LOS analysis was conducted to evaluate the ability of the project to accommodate the anticipated traffic levels at the driveway access points under Existing, Opening Year, and Horizon Year conditions with and without the proposed project. As described in the LMA (Appendix K), all the driveway approaches along G and H Street are projected to operate at an acceptable LOS and would not substantially increase hazards related to queuing of vehicles entering or exiting the Project site under all conditions analyzed in the LMA. In addition, a signal warrant analysis was conducted for the unsignalized intersections to see if they would trigger the need for a traffic signal (Appendix K).
As shown in the LMA, the project would be fully responsible for signalizing the Bay Boulevard & G Street and Project Driveway & H Street intersections and retiming the signals at the I-5 Northbound Ramps & E Street, Bay Boulevard & H Street, I-5 Northbound Ramps & H Street, and I-5 Northbound and Southbound Ramps & J Street intersections.
The Project would contribute its fair share towards the construction of a traffic signal or roundabout at the Bay Boulevard & F Street. The Project would contribute its fair share towards the construction of a traffic signal at the J Street and L Street intersections with Bay Boulevard. All proposed improvements would achieve LOS D or better conditions during both peak periods except for the roundabout at Bay Boulevard & F Street. The improvements identified in the LMA are recommendations and the final improvement plan and project funding responsibility will be defined and documented in a separate Rohr/Wohl Specific Plan Transportation Conditions of Approval memo.
As mentioned previously, sidewalks will be constructed along the Project’s frontage of G and H Street. All Project driveways would be constructed to City’s Design and Construction Standard Drawings ( City of Chula Vista 2017) and include warning detectible strips at the curb returns. Within the Project site, all internal roadways would have appropriate widths and sidewalks on both sides of the roadway. Therefore, the Project would not increase hazards because of a geometric design feature or incompatible uses and impact would be less than significant.
Would the project result in inadequate emergency access? Regional access to the Project site is provided by I-5 via its interchanges at E Street, J Street and H Street. Local access would be via Bay Boulevard, Marina Parkway, G Street and H Street. Access driveways for Planning Area B- 1 would be located along G Street. Access driveways for Planning Area B -2 would be located along H Street and access driveways for Planning Area A would be located along both G Street and H Street . The proposed project would require construction of internal roadways, as well as impr ovements to existing intersections and project driveways concurrent with development of each Planning Area.
As mentioned in Wildfire discussion in Chapter 9, Effects Not Found to be Significant, the project site is not located within a designated Fire Hazard Severity Zone (CAL FIRE 2022). The City’s fire protection and emergency medical services are provided by the Chula Vista Fire Department (CVFD). The nearest fire station to the site is Fire Station No. 1, located less than 1 mile from the site. The project site is located in the Bayfront area of the City with existing roadways on all sides and no adjacent wildlands or vegetative fuels. Additional, improvements to adjacent roadways and intersections as Planning Areas are developed would ensure adequate traffic operation and emergency access for the future land uses proposed and would be designed based on the City’s codes and regulations.
All internal roadways would be built to meet all minimum fire apparatus access requirements of the CVFD and California Fire Code. Consistent with City’s Engineering Standards, the Project’s roadways would be required to meet all access requirements such as roadway widths, all-weather surface requirements, length of streets, turning requirements, grade restrictions, maintenance requirements, and parking restrictions. Specific fire and life safety requirements would be addressed at the building permit phase w hen architectural plans are submitted for City review and approval. Adequate emergency access and compliance with emergency access and design standards
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would be ensured through this review by the City and responsible emergency service agencies throughout Project implementation. Because the Project’s access points and driveways would be designed in accordance with City standards, the proposed project would be accessible to emergency responders during construction and operation of the Project. During construction, for any work in the public right-of-way or City easement that requires closing any vehicle/bicycle travel lane(s), closing the sidewalk , and/or restricting on-street parking prior to starting any work, temporary traffic control plans will be prepared and implemented per the City’s Department of Engineering & Capital Projects Directives & Procedures.
Therefore, impacts associated with inadequate emergency access would be less than significant.
5.15.6 Level of Significance Prior to Mitigation
Impacts related to transportation would be less than significant.
5.15.7 Mitigation Measures
Impacts related to transportation would be less than significant. No mitigation measures are required.
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5.16 – UTILITIES AND SERVICE SYSTEMS
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5.16 Utilities and Service Systems
This section describes the existing setting related to utilities and service systems that would serve the proposed Rohr Wohl Specific Plan Project (project or proposed project) and evaluates potential impacts to utilities and service systems due to the implementation of the proposed project.
The discussion below is based on the following studies:
▪ Appendix I – Preliminary Drainage Report and Priority Development Project (PDP) Storm Water Quality Management Plan (SWQMP), prepared by Project Design Consultants. ▪ Appendix L1 – Water Report prepared by Dexter Wilson Engineering. ▪ Appendix L2 – Sewer Report prepared by Dexter Wilson Engineering. ▪ Appendix L3 – Water Supply Assessment prepared by Sweetwater Authority
5.16.1 Existing Conditions
5.16.1.1 Regulatory Framework
Federal
Federal Clean Water Act
The Federal Water Pollution Control Act (also known as the Clean Water Act) is the principal federal statute that addresses water resources. The statute employs a variety of regulatory and non-regulatory tools to reduce direct pollutant discharges into waterways, finance municipal wastewater treatment facilities, and manage polluted runoff. The broad goal is to restore and maintain the chemical, physical, and biological integrity of the nation’s waters so that they can support “the protection and propagation of fish, shellfish, and wildlife and recreation in and on the water.” Section 402 of the Clean Water Act authorizes the National Pollutant Discharge Elimination System (NPDES) permit prog ram that covers point sources of pollution discharging to a water body.
The NPDES program also requires operators of construction sites 1 acre or larger to prepare a stormwater pollution prevention plan for construction activities and obtain authorization to discharge stormwater under a NPDES construction stormwater permit.
Federal Safe Drinking Water Act
The Safe Drinking Water Act authorizes the U.S. Environmental Protection Agency (EPA) to set national health-based standards for drinking water to protect against both naturally occurring and human -made contaminants that may be found in drinking water. EPA, states, and water systems work in collaboration to ensure the standards are met.
National Pollutant Discharge Elimination System Permit Program The NPDES permit program was established in the Clean Water Act to regulate municipal and industrial discharges to surface waters of the United States. Discharge from any point source is unlawful unless the discharge is in compliance with an NPDES permit. Federal NPDES permit regulations have been established for broad categories of discharges, including point-source municipal waste discharges and nonpoint -source stormwater runoff. NPDES permits generally identify effluent and receiving water limits on allo wable concentrations and/or mass emissions
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of pollutants contained in the discharge; prohibitions on discharges not specifically allowed under the permit; and provisions that describe required actions by the discharger, including industrial pretreatment, pollution prevention, self-monitoring, and other activities.
Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (40 CCR, Section 268, Subpart D), contains regulations for municipal solid waste landfills and requires states to implement their own permitting programs that include federal landfill criteria. The federal regulat ions address the location, operation, design, and closure of landfills, as well as groundwater monitoring requirements.
Integrated Waste Management Act of 1989 (AB 341)
The Integrated Waste Management Act of 1989 requires each city, county, and regional agency to develop a source reduction and recycling element of an integrated waste management plan that includes source reduction, recycling, and composting components. A m inimum of a 50% diversion rate of all solid waste from landfill disposal or transformation by January 1, 2000 was required and met. The current policy goal of the state is no less than 75% of solid waste generated be source reduced, recycled, or composted by the year 2020.
State
Urban Water Management Planning Act
In 1983, the Legislature enacted the Urban Water Management Planning Act (UWMP Act; California Water Code, Sections 10610 –10656), which requires specified urban water suppliers within the state to prepare an Urban Water Management Plan (UWMP) and update it every 5 years. State and local agencies and the public frequently use UWMPs to determine if agencies are planning adequately to reliably meet water demands in various service areas. As such, UWMPs serve as an important element in documenting water supply availability and reliability for purposes of compliance with state laws, Senate Bills 610 and 221, which link water supply sufficiency to large land- use development project approvals. Urban water suppliers also must prepare UWMPs, pursuant to the UWMP Act, to be eligible for state funding and drought assistance.
The UWMP provides information on water usage, water supply sources, and water reliability planning within a specified water agency service area. It also may provide implementation schedules to meet projected demands over the planning horizon; a description of opportunities for new development of desalinated water; groundwater information (where groundwater is identified as an existing or planned water source); description of water quality over the planning horizon; and identification of water management too ls that maximize local resources and minimize imported water supplies. Additionally, the UWMP evaluates the reliability of water supplies within the specified service area. This includes a water supply reliability assessment, water shortage contingency pla n, and development of a plan in case of an interruption of water supplies.
The Metropolitan Water District (MWD), San Diego County Water Authority (SDCWA), and the Otay Water District (OWD) all play a role in supplying water to the proposed project. All of these agencies have prepared and updated UWMPs in accordance with the UWMP Act.
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Senate Bills 610 and 221
On January 1, 2002, Senate Bill (SB) 610 took effect. SB 610, which was codified in the Water Code beginning with Section 10910, requires the preparation of a water supply assessment for projects within cities and counties that propose to construct 500 or more residential units or the equivalent. SB 610 stipulates that when environmental review of certain development projects is required, the water agency that is to serve the development must complete the water supply assessment to evaluate water supplies that are or will be available during normal, single- dry, and multiple-dry years during a 20-year projection to meet existing and planned future demands, including the demand associated with a proposed project.
SB 221, enacted in 2001 and codified in the Water Code, requires a city, county, or local agency to include a condition to any tentative subdivision map that a sufficient water supply shall be available to serve the subdivision.
The term “sufficient water su pply” is defined as the total water supplies available during normal, single -dry, and multiple-dry years within a 20 -year projection that would meet the proposed subdivision project’s projected water demand, in addition to existing and planned future water uses, including agricultural and industrial uses, within the specified service area. SB 221 further requires any verification of “projected” water supplies to be based on entitlement contracts, capital outlay programs and regulatory permits and approvals.
Sanitary Sewer General Waste Discharge Requirements
On May 2, 2006, the State Water Resources Control Board adopted a General Waste Discharge Requirement (Order No. 2006-0003) for all publicly owned sanitary sewer collection systems in California with more than 1.0 mile of sewer pipe. The order provides a c onsistent statewide approach to reducing sanitary sewer overflows by requiring public sewer system operators to take all feasible steps to control the volume of waste discharges into the system in order to prevent sanitary sewer waste from entering the sto rm sewer system, and to develop a Sewer System Management Plan. The General Waste Discharge Requirement also requires that storm sewer overflows be reported to the State Water Resources Control Board using an online reporting system.
Title 14: Natural Resources – Division 7
Title 14 of the California Code of Regulations regarding Natural Resources sets minimum standards for solid waste handling and disposal, including specific regulations regarding waste tire storage and disposal, hazardous waste disposal facilities, construction and demolition and inert debris transfer/processing, construction and demolition waste and inert debris disposal, transfer/processing operations and facilities, siting and design, operation standards, record keeping, and additional operating requireme nts for facilities. Additional guidance and requirements for compostable materials handling operations and facilities, asbestos handling and disposal, resource conservation programs, farm and ranch solid waste cleanup and abatement, used oil recycling prog ram, electronic waste recovery and recycling, solid waste cleanup among others are also addressed in Title 14.
Title 27: Environmental Protection – Division 2, Solid Waste Title 27 of the California Code of Regulations regarding Environmental Protection and Solid Waste set the criteria for all waste management units, facilities, and disposal sites including regulations of the California Integrated Waste Management Board (CIW MB) and State Water Resources Control Board (SWRCB). Waste classification, siting, construction standards, water quality monitoring and response programs, operating criteria, daily and immediate cover, handling and equipment, controls, gas monitoring and c ontrol, closure and post -closure standards, and financial assurances are all aspects covered in Title 27.
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Assembly Bills 939 and 341: Solid Waste Reduction
The California Integrated Waste Management Act of 1989 ( Assembly Bill [AB] 939) was enacted as a result of a national crisis in landfill capacity, as well as a broad acceptance of a desired approach to solid waste management of reducing, reusing, and recycling. AB 939 mandated local jurisdictions to meet waste diversion goals of 25% by 1995 and 50% by 2020, and established an integrated framework for program implementation, solid waste planning, and solid waste facility and landfill compliance. AB 939 requires cities and counties to prepare, adopt, and submit to the California Department of Resources Recycling and Recovery (CalRecycle) a source reduction and recycling element to demonstrate how the jurisdiction will meet the diversion goals. Other elements i nclude encouraging resource conservation and considering the effects of waste management operations. The diversion goals and program requirements are implemented through a disposal -based reporting system by local jurisdictions under CIWM B regulatory oversight. Since the adoption of AB 939, landfill capacity is no longer considered a statewide crisis. AB 939 has achieved substantial progress in waste diversion, program implementation, solid waste planning, and protection of public health, safety, and the environment from landfills operations and solid waste facilities.
In 2011, AB 341 was passed, making a legislative declaration that it is the policy goal of the state that not less than 75% of solid waste generated be source reduced, recycled, or composted by the year 2020. AB 341 requires that local agencies adopt strat egies that will enable 75% diversion of all solid waste by 2020. This bill requires all commercial businesses and public entities that generate 4 cubic yards or more of waste per week to have a recycling program in place. In addition, multifamily apartment s with five or more units are also required to form a recycling program. At least one of the following actions are required:
▪ Source separate recyclable and/or compostable material from solid waste and either self -haul, subscribe to a recycling program through a waste hauler, and/or otherwise arrange for pick -up of the recyclable and/or compostable materials separately from the solid waste to divert them from disposal. ▪ Subscribe to a service that includes mixed waste processing alone or in combination with other programs, activities, or processes that divert recyclable and/or compostable materials from disposal and yield diversion results comparable to source separation.
▪ Property owners of commercial or multifamily complexes may require tenants to source separate their recyclable materials. Tenants must source separate their recyclable materials if required to by property owners of commercial or multifamily complexes.
California Code of Regulations Title 24, Part 11
In 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code, Part 11 of Title 24, is commonly referred to as CALGreen and establishes minimum mandatory standards as well as voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency, water conservation, material conservation, and interior air quality. The CALGreen standards took effect in January 2011 and instituted ma ndatory minimum environmental performance standards for all new construction of residential and non -residential buildings. CALGreen standards are updated periodically. The latest version (CALGreen 2019) became effective on January 1, 2020. The Mandatory CA LGreen standards pertaining to utilities and service systems include the following (24 CCR Part 11):
▪ Mandatory reduction in indoor water use through compliance with specified flow rates for plumbing fixtures and fittings.
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▪ Mandatory reduction in outdoor water use through compliance with a local water -efficient landscaping ordinance or the California Department of Water Resources’ Model Water Efficient Landscape Ordinance. ▪ Diversion of 65% of construction and demolition waste from landfills. ▪ Mandatory inspections of energy systems to ensure optimal working efficiency ▪ Inclusion of electric vehicle charging stations or designated spaces capable of supporting future charging stations
The CALGreen standards also include voluntary efficiency measures that are provided at two separate tiers and implemented at the discretion of local agencies and applicants. CALGreen’s Tier 1 standards call for a 15% improvement in energy requirements, str icter water conservation, 65% diversion of construction and demolition waste, 10% recycled content in building materials, 20% permeable paving, 20% cement reduction, and cool/solar- reflective roofs. CALGreen’s more rigorous Tier 2 standards call for a 30% improvement in energy requirements, stricter water conservation, 75% diversion of construction and demolition waste, 15% recycled content in building materials, 30% permeable paving, 25% cement reduction, and cool/solar-reflective roofs.
Local
Urban Water Management Plans
The UWMP Act requires that each urban water supplier providing water for municipal purposes, either to more than 3,000 customers, or more than 3,000 AF of water annually, must prepare, adopt, and update a UWMP at least once every 5 years on or before Decem ber 31, in years ending in five and zero. This applies to MWD, SDCWA, and its member agencies, including OWD, that serve unincorporated San Diego County. The intent of an UWMP is to present information on water supply, water usage/demand, recycled water, a nd water use efficiency programs in a respective water district’s service area. The UWMP also serves as a valuable resource for planners and policy makers over a 25-year time frame.
The UWMP process ensures that water supplies are being planned to meet future growth. UWMPs are developed to manage the uncertainties and variability of multiple supply sources and demands over the long term. Water agencies and districts update their demand and supply estimates based on the most recent San Diego Association of Governments (SANDAG) forecast approximately every 5 years to coincide with preparation of their UWMPs. The most current supply and demand projections are contained in the 2020 UWMPs of MWD, SDCWA, and OWD (MWD 2021; SDCWA 20 21; Sweetwater Authority 2021 a). SDCWA member districts rely on the UWMPs and Integrated Resources Plans of MWD (MWD 20 21) and the Regional Water Facilities Master Plan of SDCWA to document supplies available to meet projected demands.
Normal year, single-dry year, and multiple-dry year 2020 UWMP supply and demand assessments for MWD, SDCWA, and Sweetwater Authority are intended to describe the water supply reliability and vulnerability to seasonal or climatic conditions. Normal water years are considered to be years that experience average rainfall for the respective district. Single-dry water years are considered 1-year drought events. Multiple-dry water years refer to a series of below average rainfall for particular areas (i.e., multiple drought year conditions). Projections for multiple- dry years are made in 5-year increments.
In the 2020 UWMPs, MWD, SDCWA, and all SDCWA member agencies, including Sweetwater Authority, that serve unincorporated San Diego County have determined that adequate water supplies would be available to serve existing service areas under normal year, single dry year, and multiple dry year conditions through the year 2045.
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City of Chula Vista General Plan
The Chula Vista General Plan recognizes that, in order to ensure adequate water service, water supplies and facilities need to be maintained and expanded in response to the City’s projected population growth. The General Plan includes objectives and policies in the Public Facilities and Services Element that require development to plan for careful use of natural and man-made resources and services, and maximize opportunities for conservation while minimizing waste (Objective LUT 62); and increase efficiencies in water use through use of alternative technologies (Objective PFS 2). Additionally, the Housing Element includes Objective H 2 to promote efficient use of water through adopted standards and incentive -based policies to conserve limited resources and r educe long-term operational costs of housing. Growth Management Objective GM 1 and Policy GM 1.11 provide for withholding discretionary approvals and subsequent building permits from projects demonstrated to be out of compliance with applicable threshold standards for water service (City of Chula Vista 2005).
In addition, the City of Chula Vista General Plan recognizes that to ensure adequate and reliable sewer service and facilities, services need to be maintained and expanded to accommodate growth in the City’s population. The Chula Vista General Plan include s objectives and policies in the Public Facilities and Services Element that increase efficiencies in wastewater generation and its reuse through use of alternative technologies (Objective PFS 2).
Additionally, Growth Management Objective GM 1 and Policy G M 1.11 provide for withholding discretionary approvals and subsequent building permits from projects that are not in compliance with applicable threshold standards for wastewater service (City of Chula Vista 2005).
In 2005, the City of Chula Vista updated its General Plan and certified the related EIR for the General Plan Update.
In 2013, the City certified a Supplemental EIR (City of Chula Vista 2012), and approved a General Plan Amendment/General Development Plan Amendment (GPA/GDPA). The GPA/GDPA Supplemental EIR (City of Chula Vista 2012) assessed, at the General Plan level, water demands and long -term water supply availability and reliability. The City concluded that a long -term water supply could not be guarante ed; and, therefore, increases in water demand projected in the General Plan and later Amendment would result in a significant unavoidable impact.
The result of the City’s findings is that large -scale proposed development projects within the City must conduct a project-level water supply/demand analysis, accompanied by the required SB 610/SB 221 water supply assessment/verification. Based on this project-level water supply/demand analysis and associated project EIR, the City will then reassess its General Plan-level water supply findings and determinations based on the record before it.
The General Plan forecasts that the future solid waste disposal needs of the City may require the creation of a regional transfer station, where solid waste from individual collection routes would be transferred into large trucks for disposal (City of Chula Vista 2005). As such, the policies are regional in nature and do not specifically address individual developments.
Chula Vista Landscape Water Conservation Ordinance
In response to the new State Water Conservation in Landscaping Act (AB 1881), which required cities and counties to adopt landscape water conservation ordinances by January 1, 2010, the City of Chula adopted the Landscape Water Conservation Ordinance ( Chula Vista Municipal Code [CVMC], Section 20.12) in 2009 and was updated in 2015. This ordinance requires that the majority of new or rehabilitated landscapes be designed using a water budget, to help encourage outdoor water conservation. As a part of the City’s permitting process, some projects will be required to complete either a Landscape Documentation Package or a WaterSmart Checklist. In general, the Landscape Documentation Package will be prepared for larger projects that involve installing or changing an
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existing landscape, while the WaterSmart Checklist is designed for smaller projects. The size of the “landscape area” will determine which of these documents will be required. The landscape area is measured in square feet, and it is an area with outdoor plants, turf and other vegetation that uses water, including any water features either in an area with vegetation or that stand alone (CVMC, Section 20.12).
City of Chula Vista Wastewater Master Plan
The City of Chula Vista Wastewater Collection System Master Plan (City of Chula Vista 2014) provides a comprehensive review and evaluation of the City of Chula Vista’s wastewater collection, conveyance, and treatment capacity requirements under the existin g (2012) and ultimate (2050) conditions. Based on findings of the evaluation, the City’s Wastewater Collection System Master Plan recommends facility improvements and financing alternatives to ensure that aging infrastructure remains serviceable and to allow for the continued build out of the General Plan. Currently, wastewater generation within the City of Chula Vista is collected by City -owned facilities and conveyed to connections to the City of San Diego’s Metropolitan Wastewater Department (METRO) conveyance and treatment facilities for treatment and disposal. As of 2014, the City’s capacity at METRO is 20.864 million gallons per day (mgd). Future City flow projections based on current growth projections indicate that this capacity may be exceeded withi n the next 10 -15 years. As such, the wastewater generation analysis presented in the Wastewater Master Plan is intended to be used by the City to establish a basis for acquiring future METRO treatment capacity to allow for implementation of the Chula Vista General Plan, as adopted in 2005 and amended in 2012.
Chula Vista Municipal Code
Chula Vista Municipal Code, Section 19.09.040G, requires “that sewage flows and volumes shall not exceed City engineering standards as set forth in the subdivision manual.” In addition, the City must annually provide Metro with a 12 - to 18 -month developmen t forecast and request confirmation that the projection is within the City’s purchased capacity rights and an evaluation of Metro’s ability to accommodate the forecast and continuing growth.
Construction and Demolition Debris Recycling Ordinance
Effective July 1, 2008, construction and demolition projects are required to divert their debris from landfill disposal in the City of Chula Vista; 100% of inert materials (i.e., concrete, rock, landscape debris) and a minimum of 50% of all other materials (i.e., Cabinets, carpet, drywall, etc.) shall be recycled and or reused from certain ‘covered’ projects.
Covered projects are those with an approved Waste Management Report and submitted performance deposit. The Construction and Demolition Debris Recyclin g Ordinance (CVMC Section 8.25.095) is designed as a means of achieving compliance with California Green Building Standards Code (Title 24, Part II, Sections 4.408 and 5.408).
City of Chula Vista Recycling and Solid Waste Planning Manual The State of California has mandated that at least 75% of the solid waste generated be diverted from landfills. Therefore, each applicant of a development, subdivision, or major construction project (including new public facilities) is required to allocate adequate space and provide facilities to house the equipment necessary for recycling and trash services to be provided to all future residents. Such space allocation a nd facilities are to be illustrated within preliminary plans submitted to the city (i.e., Design Review process). Recycling and Solid Waste Plans are subject to approval by the City Manager or designee (City of Chula Vista 2022).
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5.16.1.2 Existing Setting
Water Service/Infrastructure
The Sweetwater Authority would provide water service to the proposed project area. As stated in the UWMP, local sources have met approximately 45 percent of the water needs within the Authority’s service area, while the 55 percent balance has been met with imported water purchased from SDCWA. As a member agency of SDCWA, the Authority is entitled to directly purchase water from SDCWA on a wholesale basis. The percentage of local to imported water can vary greatly year to year due to local rainfall amounts.
The Sweetwater Authority owns and operates two storage reservoirs known as Sweetwater Reservoir and Loveland Reservoir, which are used to divert and retain water from the Sweetwater River. During wet years when Sweetwater and Loveland Reservoirs are at or near full capacity, they are capable of providing up to a two -year supply to the Sweetwater Authority’s customers. The Sweetwater Authority does not produce or distribute recycled water, nor does it collect or treat wastewater. Additionally, the Sweetwater Authority does not currently have plans to implement new water supply projects within its service area.
Figure 5.16-1 shows the existing water supply infrastructure in the vicinity of the project site. The Sweetwater Authority’s public water system includes a 12 -inch water line in Bay Boulevard along the east side of the project site, a 12-inch water line in G Street along the north side of the site, and a 16 -inch water line in H Street on the south side of the site. These existing water lines are within the Sweetwater Authority 255 Pressure Zone system and are connected to the 18 million gallon Bonita Valley Reservoir located east of I-805 and south of Bonita Road.
Wastewater Service/Infrastructure
Sewer service to the project site would be provided by the City of Chula Vista. Figure 5.16 -2 shows the existing sewer facilities in the vicinity of the project site. The City of Chula Vista public sewer system includes an 18 -inch sewer line within Planning Area A, a 12-inch sewer line in G Street along the north side of the site, a 10-inch force main in G Street, and a 10-inch sewer line in Marina Parkway on the west side of the site. The on-site private sewer lines, laterals, and connection locations are in design development for the project.
These existing sewer lines are within the City of Chula Vista sewer system and are connected to the existing 78-inch San Diego Metro Interceptor Sewer line within Bay Boulevard. The existing sewer lines connect into the City of Chula Vista’s CV-3 meter which monitors flows going into the Metro line.
Stormwater
With respect to Planning Areas B -1 and B-2, approximately 0.3 acres of off -site run-on occurs as sheetflow in the northeast portion of the site. Planning Area B is roughly split into northern and southern portions with respect to stormwater flow. The north half of the site and is conveyed to a 36 inch storm drain on the north side of G Street, which in turn feeds into a 54-inch reinforced concrete pipe (RCP) and then into an existing slough northwest of the site. The slough is connected to San Diego Bay. Thethe southern half of the site will continue to discharge to existing outfall connections is conveyed to the southwest corner and into an existing 60inch storm drain beneath H Street, which in turn feeds into a 72-inch and 84-inch RCP under H Street, followed by outlets directly into San Diego Bay at the Chula Vista Marina (Figure 5.9-1, Existing Drainage Conditions) (Appendix I).
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Solid Waste
Republic Services provides solid waste pick up and disposal throughout the City of Chula Vista and would also service the project site. Solid waste is disposed of at either the Otay Landfill and Compost Facility located at 1700 Maxwell Road, City of Chula Vista, or the Sycamore Landfill 8514 Mast Boulevard, City of Santee. The Otay Landfill has a remaining capacity of 21,194,008 cubic yards and a max capacity of 61,154,000 cubic yards. The Otay Landfill has a cease operation date of 2030 (CalRecycle 2024a). The Sycamore Landfill has a remaining capacity of 113,972,637 cubic yards and a max capacity of 147,908,000 cubic yards. The Sycamore Landfill has a cease operation date of 2042 (CalRecycle 2024b).
Electricity, Natural Gas, and Telecommunication Facilities Electricity would be provided to the site by San Diego Gas and Electric Company (SDG&E). SDG&E provides electric services to 3.7 million customers through 1.49 million electric meters located in a 4,100-square-mile service area that includes San Diego Coun ty and southern Orange County (SDG&E 2024). According to the California Energy Commission, demand forecasts anticipate that approximately 22.7 billion kWh of electricity will be used in SDG&E’s service area in 2024 (CEC 2023). SDG&E also provides natural g as utility service to both residential and non - residential customers.
Regarding telecommunication facilities, existing infrastructure is available surrounding the project site that can provide telephone, cable TV, and internet service. These services would be available from a variety of providers.
There’s an existing SDG&E easement that extends through Planning Area B -1 and SDG&E overhead pole lines adjacent to G Street. S DG&E also has two unused easements in the northeast corner of Planning Area B -1 and a 150-foot-wide easement along the east portion of Planning Area B-1 and B-2 which contains an overhead pole line and two underground high-voltage conduit banks.
5.16.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to utilities and service systems is based on the recommendations provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact would occur if the project would:
Require or result in the relocation or construction of new or expanded water, wastewater treatment, or storm water drainage, electric power, natural gas, or telecommunications facilities or expansion of existing facilities, the construction or relocation of which could cause significant environmental effects.
Have insufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years.
Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.
Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.
Not comply with federal, state, and local management and reduction statutes and regulations related to solid waste.
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5.16.3 Impacts
Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment, or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? Water Service/Infrastructure
As stated in Appendix L1, the estimated water demand for the proposed project is 84,718 gallons per day ( gpd) average. Prior to demolition of the buildings in Planning Area B-1 and B-2 in 2023 (site was actively being used until 2020), water demand was estimated to be 70,417 gpd average. Thus, the increase in water demand is approximately 14,301 gpd average or 16.0 acre -feet/year. Prior to the renovations in Planning Area A, the water demand was estimated to be 32,370 gpd 1 and now that the renovations are complete , the water demand is estimated to be 20,902 gpd2. Therefore, Planning Area A would have a reduced water demand of 11,468 gpd compared to previous industrial uses.
With an existing 12-inch water line in G Street along the north side of the project site, and an existing 16-inch water line in H Street at the south side of the site, there is sufficient water flow and pressure to develop the project site.
This is further supported by hydrant flow tests prepared by Sweetwater Authority. Two tests were conducted, one on the 12-inch water line in G Street and one on the 16-inch water line in H Street.
The hydrant flow test in G Street shows that a flow of 4,947 gallons per minute (gpm) can be supplied in the 12-inch water line with greater than 60 pounds per square inch (psi) residual pressure. The H Street hydrant flow test shows an analysis for 5,000 gpm flow with similar pressure results. This substantiates that a fire hydrant flow requirement of 5,000 gpm is achievable on the project site with appropriate fire system looping.
However, the City of Chula Vista Fire Department allows only a 25% reduction in the required fire flow for fire sprinklered buildings. Since some of the proposed buildings in Planning Area B-1 may be over 100,000 square feet, consideration may need to be given to the type of construction for these buildings so that the required fire flow does not exceed the ability of the existing water system.
With the ability to modify the type of construction of the larger buildings or configure an on-site fire protection system that will make use of both existing water lines in G Street and H Street, there is no need for off -site water pipeline improvements to provide water service to the project site. Impacts would be less than significant.
Wastewater Service/Infrastructure
As stated in Appendix L2, estimated sewage generation for the project site was determined based on the city of Chula Vista Wastewater Master Plan and the proposed land uses in B -1 and B-2. Estimated average dry weather flow sewage generation was determined to be 58,781 gpd. The estimated peak dry weather flow for the project is 82,293 gpd. The ratio of peak wet weather flow to peak dry weather flow is 1.85, resulting in an estimated pea k wet weather flow of 152,242 gpd. Prior to the renovations in Planning Area A, the sewage generation flow was
1 Previous industrial warehouse in Planning Area A was 282,004 square feet; estimated water demand was 5,000 gpd/acre, for a total of 32,370 gpd total.
2 Newly renovated warehouse (Business Park Flex) in Planning Area A is 202,336 sq uare feet (85% industrial and 15% office); estimated water demand is 4,500 gpd/acre, for a total of 20,902 gpd total.
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estimated to be 4,609 gpd3 and now that the renovations are complete, the sewer generation flow is estimated to be 3,785 gpd4. Therefore, Planning Area A would have a reduced sewer generation flow of 824 gpd compared to previous industrial uses.
Planning Areas A, B-1 and B-2 will convey their sewage through the existing public sewer lines or proposed on-site private sewer lines to the existing G Street Pump Station. The G Street Pump Station is slated to be upgraded in the near future. Approved plans (Drawing No. 21053-1) are dated December 19, 2022. The proposed project relies on the completion of the G Street Pump Station improvements and therefore the proposed project will not be able to obtain sewer service until the pump station upgrades are completed.
The Chula Vista Bayfront Master Plan – Technical Memorandum No. 2 Proposed Water and Sewer Evaluation, dated December 2016, is the most current document related to the existing flows going into the G Street Pump Station. In the Bayfront Master Plan, Table 4-6 shows that the existing plus proposed flows going to the G Street Pump Station total to an average flow of 0.482 mgd (335 gpm) and a peak wet weather flow of 1.294 mgd (899 gpm). The proposed flows estimated in the Bayfront Master Plan do not include sewage generation from the proposed project.
The existing and proposed flows calculated in the Bayfront Master Plan plus the estimated sewage generation from the proposed project results in an average flow of 0.541 mgd (376 gpm) and a peak wet weather flow of 1.45 mgd (1,007 gpm).
Per the City of Chula Vista Wastewater Master Plan, Section 4.1.2 – Lift Station Design Criteria, the “Lift Stations should be sized for the peak wet weather flow rate plus an additional 20% capacity to account for wear, miscellaneous debris, etc. that may reduce pumping performance.” The peak wet weather flow including the proposed project, plus the 20% pumping capacity safety factor, results in a required pumping capacity of 1,208 gpm for the G Street Pump Station.
The G Street Pump Station upgrades result in an operating pumping capacity of 1,300 gpm which is greater than the calculated required pumping capacity for existing, proposed, and proposed project of 1,208 gpm. Thus, the new G Street Lift Station has sufficient capacity for the build-out of the proposed project. Wastewater infrastructure has the ability to transmit wastewater generated by the proposed project and no new or expanded infrastructure would be required. Impacts would be less than significant.
Stormwater
Based on the PDP SWQMP (Appendix I), the proposed site drainage conveyance network would include trench drains, grate inlets, B-Inlets, ribbon gutters, earthen swales in the westerly dispersion area, and storm drains. The majority of the site drainage would be collected and then directed to modular wetland units for water treatment.
Stormwater runoff would enter the modular wetland units via pipe inflows and curb openings. One 3,130 -square- foot biofiltration basin would be located at the northeast corner of the site (Figure 5.9 -3, Proposed Drainage Conditions). The basin would be lined because the project geotechnical engineer determined the subsurface soils are not suitable for stormwater infiltration. The biofiltration basin would include 18 inches of engi neered sandy loam, growing media on top of a minimum depth of 12 inches of gravel. In addition to these biofiltration layers, a
3 Previous industrial warehouse in Planning Area A was 282,004 sq uare feet; estimated sewer flow was 712 gpd/acre, for a total of 4,609 gpd total.
4 Newly renovated warehouse (Business Park Flex) in Planning Area A is 202,336 sq uare feet (85% industrial and 15% office); estimated sewer flow is 712 gpd/acre for industrial and 1,401 gpd for office, for a total of 3,785 gpd total.
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barrier/filter layer would also be installed beneath the soil media, and above the gravel layer. The filter layer would include a 3-inch layer of washed sand on top of a 3-inch layer of #8 choking stone (Appendix I).
No other biofiltration basins are proposed due to subsurface soil contamination in other areas of the site, as well as shallow groundwater conditions (i.e., locally as shallow as 2 feet). As a result, vegetated modular wetland units would be installed to t reat stormwater runoff across the majority of the site, in combination with two stormwater runoff dispersion areas and a biofiltration planter for stormwater retention. The volume retention requirements would be met on a composite basis rather than on a drainage management area basis. Harvest and re-use would not be feasible for this project. Proposed structural best management practices ( BMPs) would be verified by the City at the completion of construction. PDP BMPs must be maintained into perpetuity. In addition, because the project proposes to treat an equivalent or larger amount of impervious surface due to treating the run -on, the perimeter areas of the site that could not be graded to drain to on -site treatment BMPs are addressed through a proposed treatment swap along the eastern portion of the property, as illustrated in Figure 5.9-3 (Appendix I).
The proposed loading docks would be depressed areas below the building finish floor and would include trench drains to collect stormwater runoff in those areas. Trench drains would also be used on the east side of the site, within the SDG&E easement. The project area east of the SDG&E easement drains is not proposed to be disturbed by the project. Rather, only re-striping is proposed in that area and that portion of the drainage area is considered run-on (Appendix I).
Similar to existing conditions, the site drainage would be roughly split north and south, and will continue to discharge to existing outfall connections with the north side being conveyed to the 36 -inch stub, and then westerly transitioning to the 54-inch RCP, ultimately discharging into an existing slough northwest of the site. The slough is directly connected to San Diego Bay. Stormwater runoff on the so uth side of the site would be conveyed to the H Street 60 -inch storm drain, and then southwesterly to an 84 -inch RCP that outlets directly to San Diego Bay (Appendix I). The new on -site stormwater infrastructure would be adequate to serve the proposed project and impacts would be less than significant.
Electricity, Natural Gas, and Telecommunication Facilitie s Regarding the existing SDG&E easements and facilities, the existing easement that extends through Planning Area B-1 would be quitclaimed during the development process. The overhead pole lines adjacent to G Street would be converted to underground conduits running beneath the sidewalk along the south side of G Street. The two unused easements in the northeast corner of Planning Area B -1 would also be quitclaimed. The 150 -foot-wide easement along the east portion of Planning Area B -1 and B-2, which contains an overhead pole line and two underground high-voltage conduit banks, would remain and the project proposes to use this area as surface parking.
SDG&E would continue to provide electric and natural gas service to the project site as they did prior to demolition of the buildings. Regarding telecommunication facilities, existing infrastructure is available surrounding the project site that can provide telephone, cable TV, and internet service. These services would be available from a variety of providers. No new infrastructure or increase in capacity of existing infrastructure would be required in order to serve the proposed project. Impacts would be less than significant.
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Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? As stated in Appendix L1, the estimated water demand for the proposed project is 84,718 gpd average. Prior to demolition of the buildings in Planning Area B-1 and B-2 in 2023, water demand was estimated to be 70,417 gpd average. Thus, the increase in water demand is approximately 14,301 gpd average or 16.0 acre-feet/year. Prior to the renovations in Planning Area A, the water demand was estimated to be 32,370 gpd 5 and now that the renovations are complete, the water demand is estimated to be 20,902 gpd 6. Therefore, Planning Area A would have a reduced water demand of 11,468 gpd compared to previous industrial uses.
From the Sweetwater Authority’s Water Distribution System 2020 Master Plan, the annual water production for the year 2020 was 16,941 acre-feet (Sweetwater Authority 2021b). Thus, the additional water demand estimated for the proposed project is 0.0 9% of the total water production for the Sweetwater Authority. This additional water supply is expected to be accounted for in the typical increase in normal growth in the Sweetwater Authority service area, as well as in the updated projections which Sweetw ater Authority makes as part of its 5 -year update of its UWMP. As stated in Sweetwater Authority’s UWMP, the projections show that they anticipate having adequate water supplies during normal years, single dry -years, as well as multiple dry -year periods through 2045. If supply limitations arise in multiple dry -year scenarios, they will be addressed through implementation of extraordinary water conservation measures (Sweetwater Authority 2021a).
As indicated in Appendix L3, Water Supply Assessment, prepared by Sweetwater Authority for the proposed project, there will be sufficient water supplies, over a 20 -year planning horizon, to meet the projected demands of the proposed project, in addition to existing and planned future users, including agricultural and manufacturing uses, under normal, single dry-year, and multiple dry-year scenarios.
As previously stated, the additional demand generated by the proposed project is expected to be accounted for in the typical increase in normal growth in the Sweetwater Authority service area. Therefore, sufficient water supplies are available to serve the project and impacts would be less than significant.
Would the project result in a determination by the wastewater treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
San Diego Metropolitan Sewer System
The City of Chula Vista is a participating member of the City of San Diego owned and operated METRO system. The system includes regional sewer interceptors and trunk sewers, lift stations, and treatment and disposal facilities.
Each participating agency of the METRO system has capacity rights that dictate how much they can contribute to the system each day. The most current agreement for capacity rights pertaining to the METRO system is the Amended and Restated Regional Wastewater Disposal Agreement Between the City of San Diego and the Participating Agencies in the Metropolitan Sewerage System, signed July 23, 2021. Per Exhibit B of the agreement, the City of Chula Vista has a capacity of 20.864 mgd average flow in the METRO system.
5 Previous industrial warehouse in Planning Area A was 282,004 square feet; estimated water demand was 5,000 gpd/acre, for a total of 32,370 gpd total.
6 Newly renovated warehouse (Business Park Flex) in Planning Area A is 202,336 sq uare feet (85% industrial and 15% office); estimated water demand is 4,500 gpd/acre, for a total of 20,902 gpd total.
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5.16.4 Level of Significance Prior to Mitigation
Impacts associated with utilities and service systems would be less than significant and no mitigation measures are required.
5.16.5 Mitigation Measures
No mitigation measures are required.
5.16.6 Level of Significance After Mitigation
Impacts associated with utilities and service systems would be less than significant.
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6 Cumulative Impacts
6.1 Introduction
Although the environmental effects of an individual project may not be significant when that project is considered independently, the combined effects of several projects may be significant when considered collectively. Such impacts are referred to as “cumulative impacts.” Section 15355 of the California Environmental Quality Act (CEQA) Guidelines defines cumulative impacts as “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts.” Section 15130 of the CEQA Guidelines provides guidance for analyzing significant cumulative impacts in an environmental impact report (EIR). According to this section of the CEQA Guidelines, the discussion of cumulative impacts “need not provide as great detail as is provided for the effects attributable to the project alone. The discussion should be guided by standards of practicality and reasonableness.” The discussion should also focus only on significant effects resulting from a project’s incremental effects and the effects of other projects. According to Section 15130(a)(1), “an EIR should not discuss impacts which do not result in part from the project evaluated in the EIR.” Cumulative impacts can occur from the interactive effects of a single project. For example, the combination of noise and dust generated during construction activities can be additive and can have a greater impact than either noise or dust alone. However, substantial cumulative impacts more often result from the combined effect of past, present, and future projects located in proximity to the project under review. Therefore, it is important for a cumulative impacts analysis to be viewed over time and in conjunction with other related past, present, and reasonably foreseeable future developments whose impacts might compound or interrelate with those of the project under review.
6.2 Methodology
According to Section 15130(b) of the CEQA Guidelines, cumulative impact analysis may be conducted and presented by either of two methods: (1) a list of past, present, and probable activities producing related or cumulative impacts, or (2) a summary of proj ections contained in an adopted general plan or related planning document, or in a prior environmental document that has been adopted or certified that described or evaluated regional or area-wide conditions contributing to the cumulative impact. Other tha n for air quality, greenhouse gas emissions, noise, and transportation/traffic, the cumulative list approach has been used in the cumulative analysis presented in this chapter, as discussed below. Air quality, greenhouse gas emissions, noise, and transportation/traffic cumulative impacts were evaluated using the summary of projections method because impacts can only be analyzed on a broad, area -wide scope, and in a cumulative context. Table 6 -1 describes the geographic scope of the cumulative impact analyses.
CEQA requires an EIR include an analysis of cumulative impacts. The purpose of this section of the EIR is to explain the methodology for the cumulative analyses and present the potential cumulative effects of the Modera Melrose Mixed-Use Development Project (project or proposed project).
Section 15355 of the CEQA Guidelines defines cumulative impacts as “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts.” Section 15130 of the CEQA Guidelines provides g uidance for analyzing significant cumulative impacts in an EIR. The discussion of cumulative impacts “need not provide as great detail as is provided for the effects attributable to the
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potential conflicts with existing regulations governing scenic quality are not anticipated, and impacts would be less than significant. Cumulative projects No. 1 and No. 3 would be visible from the project site and together with the proposed project the visual character of the bayfront would be different; however, these projects were contemplated as part of the Chula Vista Bayfront Master Plan and visual impacts were addressed in the EIR for the Master Plan.
Cumulative projects No. 4 and 5 are on the projec t site and the buildings have already been demolished. Future development on the project site would be guided by the Design Guidelines established in the Specific Plan and with implementation of existing regulations and the Chula Vista Municipal Code, the proposed project would not result in substantial alteration to the existing or planned character of the area. The project’s contribution to a cumulatively considerable aesthetic impact is negligible.
6.4.2 Air Quality
Air pollution is largely a cumulative impact. The nonattainment status of regional pollutants is a result of past and present development, and the San Diego Air Pollution Control District (SDAPCD) develops and implements plans for future attainment of the National Ambient Air Quality Standards ( NAAQS) and California Ambient Air Quality Standards (CAAQS). Based on these considerations, project -level thresholds of significance for criteria pollutants are relevant in the determination of whether the Project’s individual emissions would have a cumulatively significant impact on air quality. In analyzing cumulative impacts from a project, the analysis must specifically evaluate the project’s contribution to the cumulative increase in pollutants for which the San Diego Air Basin ( SDAB) is designated as nonattainment for the CAAQS and NAAQS. If the project does not exceed thresholds and is determined to have less than significant project-specific impacts, it may still contribute to a significant cumulative impact on air quality if the emissions from the project components, in combination with the emissions from other proposed or reasonably foreseeable future projects, exceed established thresholds. However, the project would only be considered to have a significant cumulative impact if its contribution accounts for a significant proportion of the cumulative total emissions (i.e., it represents a “cumulatively considerable con tribution” to the cumulative air quality impact).
Additionally, for the SDAB, the Regional Air Quality Strategy ( RAQS) serves as the long -term regional air quality planning document for the purpose of assessing cumulative operational emissions within the basin to ensure the SDAB continues to make progress toward NAAQS and CAAQS attainment status. As such, cumulative proje cts located in the San Diego region would have the potential to result in a cumulative impact to air quality if, in combination, they would conflict with or obstruct implementation of the RAQS. Similarly, individual projects that are inconsistent with the regional planning documents on which the RAQS is based would have the potential to result in cumulative impacts if they represent development beyond regional projections.
The SDAB has been designated as a federal nonattainment area for ozone (O3) and a state nonattainment area for O3, coarse particulate matter (PM10), and fine particulate matter (PM2.5). PM10 and PM2.5 emissions associated with construction generally result in near-field impacts. The nonattainment status is the result of cumulative emissions from all sources of these air pollutants and their precursors within the SDAB. The mitigated construction emissions from the proposed project would not exceed the SCAQMD’s volatile organic compound ( VOC) thresholds of significance and impacts would be less than significant. Net operational emissions generated by the project would not result in emissions that exceed si gnificance thresholds for any criteria air pollutant. Long -term operational air quality impacts would be less than significant and impacts would not be cumulatively considerable.
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6.4.3 Biological Resources
As described in Section 5.3, Biological Resources , the project site consists of Tier IV habitats. Tier IV habitats are not considered significant and do not require mitigation. Special-status plant species were not documented within the study area and do not have a moderate or high potential to occur. Howeve r, due to the potential for special - status wildlife species to be present, in addition to nesting birds, mitigation measures MM-BIO1 through MM-BIO-5 would be implemented and would reduce impacts to less than significant.
The cumulative impacts associated with the proposed project include the potential long-term regional effects of the project in combination with other projects and conditions within the area. This includes consideration of potential effects on an ecosystem component or entire ecosystem on a regional scale. The City Multiple Species Conservation Program (MSCP) Subarea Plan is a part of the County of San Diego MSCP, which is a regional effort to counteract significant cumulative biological impacts. All develop ment that is permitted through the city must comply with the MSCP. Because of this regional biological planning, cumulative biological impacts on most species in the region are not significant when developments are pursued in compliance with the plan. Because project avoidance and minimization measures will be pursued in a manner consistent with the City MSCP Subarea Plan, impacts to biological resources would not be cumulatively considerable.
6.4.4 Cultural Resources and Tribal Cultural Resources
As described in Section 5.4, Cultural Resources, the potential for intact cultural deposits to exist within native soils to the depths of proposed ground disturbance is unknown. In the event that unanticipated cultural resources are encountered during project implementation, impacts could be potentially significant, and mitigation measures (MM- CUL-1) would be required. The results of the records search did not identify the presence of any previously recorded archaeological sites within the project site. Cumulative projects No. 1 and No. 3 are already under construction and potential impacts to cultural resources were addressed in the EIR for the Chula Vista Bayfront Master Plan.
Cumulative projects No. 4 and 5 are on the project site and the buildings have already been demolished.
Cumulative project No. 2 is complete and any impacts to cultural resources would have been identified and handled appropriately as part of that project. Lastly, cumulative project No. 6 is an expansion of an existing facility on land that has already been paved or heavily disturbed. Careful treatment of any resources found on site, combined with similar protections elsewhere, would ensure that regional losses do not result in a cumulatively considerable impact on cultural resources.
6.4.5 Energy
Cumulative projects that could exacerbate the project’s impacts include any projects that could result in wasteful, inefficient, or unnecessary use of energy. However, as demonstrated in Section 5.5, Energy, the project would not result in wasteful, inefficient, or unnecessary use of energy during construction or operation. Construction will result in short-term and temporary energy demands. Operation of the Project would not result in a wasteful, inefficient, or unnecessary use of energy or conflict with a n applicable plan. Therefore, the project would have a less -than- significant impact with regards to cumulative energy impacts.
6.4.6 Geology and Soils
As described in Section 5.6, Geology and Soils, impacts associated with landslides, seismic ground shaking, expansive soils and erosion would be less than significant. However, development of the proposed project would
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require excavations for building foundations and utilities, and any excavations into the potentially fossil -bearing strata within the Bay Point and San Diego Formations could result in potentially significant impacts to paleontological resources, and mitigation measure MM-GEO-1 would be required. Impacts would be reduced to less than significant.
Due to the localized nature of geology and soils, cumulative projects would address potential impacts to geology and soils on a project -by-project basis, as potential geologic hazards and soil composition varies by site. Each cumulative project would be required to assess individual and site-specific geologic conditions, which would inform construction and development of each site. All cumulative development would be subject to similar requirements to those imposed and implemented for the proposed project a nd would be required to adhere to applicable regulations, standards, and procedures. As such, the proposed project would not result in impacts that would be cumulatively considerable.
6.4.7 Greenhouse Gas Emissions
As described in Section 5.7, Greenhouse Gas Emissions, the project’s significance is based on its potential to conflict with the applicable plans adopted for the purpose of reducing greenhouse gas (GHG) emissions, including the City’s Climate Action Plan, the 2022 Scoping Plan, the 2017 Scoping Plan, Assembly Bill 32 Regulations, the San Diego Association of Governments’ ( SANDAG’s) Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) and the City’s General Plan. As demonstrated in Section 5.7, the project would not conflict with applicable GHG reduction plans and regulations, accordingly, the impact would be less than significant.
Due to the global nature of the assessment of greenhouse gas emissions and the effects of global climate change, GHG emissions analysis, by its nature, is a cumulative impact analysis. Therefore, the information and analysis provided in Section 5.7, Greenh ouse Gas Emissions, to determine project -level impacts, applies here and the project’s contribution to global climate change would not be cumulatively considerable.
6.4.8 Hazards and Hazardous Materials
As described in Section 5.8 Hazards and Hazardous Materials, construction and operation of the project is not anticipated to create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. In addition, because soil contamination would be remediated to San Diego Regional Water Quality Control Board and San Diego Department of Environmental Health and Quality standards prior to project construction, minor grading and trenching would not encounter contaminated soil that could result in a significant hazard to on -site construction personnel or the environment. Further, with compliance with the Construction General Permit (CGP) and MS4 Permit, project construction would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.
Health and safety impacts are generally site specific and thus handled on a site-by-site basis. All projects identified in Table 6-1 would require the identification of existing hazardous materials on site and would be required to comply with existing regulations related to use, transport, and disposal of hazardous materials. Similarly, all related projects would be required to analyze and properly mitigate any impacts, if impacts are identified. Cumulative projects No. 1 and No. 3 are already under constru ction and the use, transport, and handling of hazardous materials were addressed in the EIR for the Chula Vista Bayfront Master Plan. Cumulative projects No. 4 and 5 are on the project site and the buildings have already been demolished in order to prepare the site for soil remediation. Cumulative
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project No. 2 is complete and any hazardous materials used for operation of the project would be required to comply with local and state laws and regulations. Similarly, cumulative project No. 6 is an expansion of an existing facility and hazardous materials used during construction and future operation would be required to comply with local and state laws and regulations. Overall, the proposed project would not result in a cumulatively considerable impact as it relates to hazards and hazardous materials.
6.4.9 Hydrology and Water Quality
As described in Section 5.9, Hydrology and Water Quality, through implementation of the requirements outlined in the CGP, construction-related impacts to surface water and groundwater would be minimized and impacts would be less than significant. With incorporation of water quality BMPs and project design features, as described above for construction and operation, the project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground w ater quality. The project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin. The proposed storm drain system would be sufficient to satisfy Chula Vista criteria in the post-development condition (Appendix I1) and would not result in erosive scour and associated siltation of San Diego Bay.
In combination with the other cumulative projects in the area, specifically projects No. 1, 2, 3, and 6 , there would be an increase in impervious surfaces which could result in increased surface runoff, alteration of regional drainage patterns, and flooding. However, like the proposed project, each individual project applicant would be required to hydrologically engineer the respective project sites to ensure that post -development surface runoff flows can be accommodated by the regional drainage system. As such, with implementation of storm drain facilities for each related project, if applicable, the proposed project would not result in a cumulative impact to hydrology. Therefore, the proposed project’s contribution to a cumulative hydrology impact would not be cumulatively considerable.
6.4.10 Land Use and Planning
As described in Section 5.10, Land Use and Planning, the proposed project would not result in a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Impacts would be less than significant.
Other projects under review by the City would also be required to comply with the General Plan, any applicable Master Plan, Specific Plan, or Local Coastal Program, and existing zoning. Projects that would not be consistent would require implementation of a General Plan amendment, master plan amendment, and/or zone change and would be required to demonstrate conformance with pertinent goals, policies, and recommendations. Each project would be required to be considered in combination with other foreseeable projects and would be required to demonstrate consistency with an adopted land use plan, land use designation, or policy. Therefore, land use impacts would not be cumulatively considerable.
6.4.11 Noise
As described in Section 5.11, Noise, short-term construction noise is predicted to be well below the Federal Transit Administration guidance of 80 dBA Leq over an 8-hour period, and therefore is less than significant. Traffic related to construction activities would not result in a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards estab lished in the local general plan or noise ordinance, or
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applicable standards of other agencies. Potential impacts at existing off -site noise -sensitive land uses along roadway segments and project-generated changes to future traffic noise would be less than significant.
In combination with the other cumulative projects in the area, specifically projects No. 1, 2, 3, and 6 , there would be an increase in ambient noise in the surrounding area. Cumulative projects No. 4 and 5 have already been completed and the buildings have been demolished, so these projects would not contribute to an increase in noise.
Potential noise impacts have been adequately addressed in previous environmental documents and mitigation has been applied as applicable. The previous buildings on the projec t site contributed to traffic noise and operational noise and introduction of the proposed project would not substantially increase noise beyond what was occurring before the buildings were demolished. Overall, the project’s contribution to a cumulatively considerable noise impact would be negligible.
6.4.12 Population and Housing
As described in Section 5.12, Population and Housing, once operational, the estimated 1,000 jobs that would result from the proposed project would result in some amount of population growth within the City due to new employment opportunities, however, this population growth would not be considered unplanned b ecause the proposed project would restore what was previously a major job center for the City of Chula Vista. No existing residential uses occupy the project site as the site was previously developed wi th industrial buildings, which have since been demolished.
The proposed project does not include the construction of any residential units and would not displace existing housing or people or necessitate the construction of replacement housing elsewhere.
Cumulative projects No.1, Gaylord Hotel (1,600 rooms) and project No. 3, Amara Bay (1,500 multi -family units) would result in an increase in population. However. these projects were adequately analyzed as part of the Bayfront Master Plan EIR and assumed in regional housing and population projections. Since the proposed project would not result in the addition of new housing units or demolish existing units , it would not contribute to a cumulative impact related to housing. Although the project would generat e employment opportunities, which could generate additional population within the City, it would essentially be reestablishing what was a major job center for the City of Chula Vista and the growth would not be unplanned or unforeseen. Overall, the project ’s contribution to a cumulatively considerable population and housing impact would be less than significant.
6.4.13 Public Services
As described in Section 5.13, Public Services, the project would not substantially increase the demand of fire protection services requiring the construction of new or expanded fire protection facilities or facilitate the need for additional firefighters and equipment. The City’s Public Facilities Development Impact Fee (PFDIF) would help cover the cost of new or expanding public facilities within the City, including fire and police facilities. The proposed project would be subject to payment of the PFDIF fees at the rate in effect at the time building permits are issued. Payment of the PFDIF would be necessary to ensure that the project contributes its fair share of the cost of fire police facilities and equipment needed to adequately accommodate increasing demand within the City. In addition, the project site is located within existing Community Facilities Districts ( CFDs) for the Chula Vista Elementary School District and Sweetwater Union High School District , which impose a special tax on property owners to finance both school districts. Any development of new school facilities resulting from these CFDs would be undertaken by the school district at that time. Pursuant to Education Code Section 17620(a)(1), the governing board can authorize the levy of a fee, charge, dedication, or other requirements against any construction within school district boundaries, and
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with the school district’s collection of Statutory and Alternative fees developers can fully mitigate any impacts.
Lastly, because the project is considered a commercial development, payment of PFDIF for libraries is not required.
Cumulative projects No. 4 and 5 involved demolition of buildings on the project site, thus these projects would not contribute to a cumulative impact on public services. Cumulative projects No. 1, 2, 3, and 6 would place additional demand on public services. However, as part of the Chula Vista Bayfront Master Plan EIR, project applicants were required to satisfy adequate levels of service through mechanisms that included payment of a PFDIF, construction of facilities contemplated in the Master Plan, or other equivalent funding agreements. Since the proposed project site was previously served public services prior to demolition of the buildings in Planning Area B-1 and B-2, the site would continue to be served by existing services once the site is redeveloped. The intensity of the proposed project is not substantially greater than what was previously on site and existing public services would be adequate to continue to serve the site. Therefore, the project’s contribution to a cumulatively considerable impact would be less than significant.
6.4.14 Recreation
As described in Section 5.14 Recreation, per Chula Vista Municipal Code Section 17.10.120, the proposed project would not be required to pay development fees because there are no proposed residences within the project.
Therefore, because the proposed project does not include a new residential population and would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. Impacts would be less than significant.
Cumulative projects No. 4 and 5 have already been completed and the buildings have been demolished, so these projects would not contribute to a cumulative impact on recreational facilities. Regarding projects No. 1, 2, 3, and 6, an increase in the use of recreational facilities would potentially occur. However, these projects were part of the Chula Vista Bayfront Master Plan EIR, and their impact on recreational facilities were analyzed and compensated for therein. Mitigation in the Bayfront Master Plan EIR specifically called for hotels and multi-family units to provide an adequate amount of developed parkland in accordance with the City’s Municipal Code (Chapter 17.10), prior to issuance of certificate of occupancy. Therefore, these cumulative projects al ready have mechanisms in place to ensure that recreational facilities are funded or built prior to operation. Since the proposed project would result in less than significant impacts to recreational facilities and cumulative projects have built or compensa ted for recreational facilities, impacts would be less than significant.
6.4.15 Transportation
As described in Section 5.15, Transportation, the proposed project would not conflict with existing or proposed bicycle, pedestrian, or transit facilities in its vicinity. In addition, the proposed project (A, B1 and B2) is located in census tract 12600. The SANDAG average vehicles miles traveled (VMT) per employee is 18.90 and the threshold of 85 percent would be 16.06 VMT per employee or below. The average VMT per employee of this tract is 15.91, which is below the regional average VMT per employee of 18.90, as well as below the VMT per employee threshold (i.e., 85 percent of the regi onal mean) of 16.06. Therefore, it can be concluded that the proposed project is in a VMT efficient area for all employee uses. B ecause the proposed project would meet the VMT screening criteria described above, a more detailed VMT analysis is not required, and can be presumed to result in a less -than- significant VMT impact.
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Industrial employment and employment 1 projects located within a VMT-efficient area may be presumed to have a less than significant impact absent substantial evidence to the contrary. Because the project screens out of a detailed VMT analysis and results in a less -than-significant impact under baseline conditions, the project’s cumulative VMT impact can also be presumed to result in a less than significant VMT impact. Cumulative impacts would be less than significant.
6.4.16 Utilities and Service Systems
As described in Section 5.16, Utilities and Service Systems, the proposed project would have adequate water, wastewater, stormwater, and telecommunication infrastructure. The project would be required to comply with all local and state regulations regardin g solid waste and the surrounding landfills would have capacity to serve the project. Impacts would be less than significant.
All cumulative projects would be required to assess whether adequate infrastructure exists to serve their developments and whether additional or expanded infrastructure would be required to be constructed. and mitigate any potential impacts to water infrastructure caused by the project. A s necessary, a ll projects would be required to construct water infrastructure improvements in order to adequately serve the development, 1 Transportation Study Guidelines Appendix D: Land Use Designations includes the following for employment related uses that pertain to the project:
Industrial employment: Industrial Park (no commercial), Industrial Plant (multiple shifts), Manufacturing/Assembly, Warehousing, Storage.
Commercial employment: Agriculture, Hospital -General/Convalescent/Nursing, Industrial/Business Park (commercial included), Science Research & Development, Hotel (with convention facilities/restaurants), Motel, Resort Hotel, Business Hotel, Military , Standard Commerical Office, Large (High -rise) Commercial Office, Office Park, Single Tenant Office, Corporate Headquarters, Government Offices primarily office with employees, Medical/Dental)
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7 Growth Inducement
Section 15126.2(d) of the California Environmental Quality Act (CEQA) Guidelines mandates that the growth - inducing nature of a proposed project be discussed. This CEQA Guideline states that the growth induc ement analysis is intended to address the potential for the project to “foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment.” Further, the CEQA Appendix G Checklist (Population and Housing) mandates that a CEQA document address a project’s likelihood to induce substantial population growth in an area, either directly (for example, by propo sing new homes or businesses) or indirectly (for example, through extension of roads or other infrastructure).
A project may be distinguished as either facilitating planned growth or inducing unplanned growth. Facilitating growth relates to the establishment of direct employment, population, or housing growth that would occur within a project site. Inducing growth is related to lowering or removing barriers to growth or by creating an amenity or facility that attracts new population/economic activity. For purposes of analysis in this environmental impact report (EIR), a significant growth -inducement impact would occ ur if the proposed Rohr Wohl Specific Plan Project (proposed project or project), and all associated infrastructure improvements, directly or indirectly removes obstacles to growth such that the induced growth would significantly burden existing community services or the environment, or cause a demand for a General Plan Amendment.
This chapter contains a discussion of the growth -inducing factors related to the proposed project . As defined in CEQA Guidelines Section 15162.2(d) , a project is defined as growth inducing when it directly or indirectly:
1. Fosters population growth;
2. Fosters economic growth;
3. Includes the construction of additional housing in the surrounding environment;
4. Removes obstacles to population growth;
5. Taxes existing community service facilities, requiring construction of new facilities that could cause significant environmental effects; and/or
6. Encourages or facilitates other activities that could significantly affect the environment, either individually or cumulatively.
It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.
7.1 Growth Inducement Due to Population Growth
Section 5.12, Population and Housing, notes that the proposed project would have a direct impact on the population growth of the City of Chula Vista (City) by amending the existing zoning of General Industrial (I) zoning to allow for a combination of light industrial, office, commercial, and visitor-oriented uses. The estimated creation of 1,000 jobs would further contribute to the City’s population growth. The project area was already classified as I and identified for development as light industrial, office, commercial, and visitor-oriented uses. To accommodate this, three new zoning designations—PA-1 (Planning Area A), PA-2 (Planning Area B-1), and P-3 (Planning Area B-2)—were created to allow for permitted, conditionally permitted, and prohibited uses within six land use categories. These include 7 – GROWTH INDUCEMENT
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Commercial Retail (CR), Commercial Visitor (CV), Commercial Office (CO), Light Industrial (LI), Regional Technology Park (RTP), and Business Park Flex (BFR).
Because the proposed project would restore a recent previous major job center for the City and aligns with the existing General Plan Industrial (I) designation , it would not be considered unplanned population growth.
Furthermore, the development of a mixed -use regional technology district would create new employment opportunities and thus contribute to population growth within the City. The proposed project would result in on e- time construction employment opportunities and annual operational employment opportunities. Construction opportunities would be temporary and would not result in the permanent relocation of employees. Operational employment opportunities could result in indirect growth inducement from employees that choose to relocate from outside the City.
7.2 Growth Inducement Due to Economic Growth
Increasing the employment population can lead to economic growth by creating a higher demand for regional and local goods and services. The proposed project is designed to encourage clean industrial, commercial, research and development, and office uses, which would provide on-site services and create employment opportunities for residents in the surrounding areas. Business in these sectors would generate new indirect economic output from subsequent expenditures on goods and services to other area businesses. The proposed project would be able to take advantage of its proximity to Interstate 5, the Port of San Diego, and various defense industry assets and contractors to enhance the greater Chula Vista Bayfront area. Because the proposed project would restore a recent previous major job center for the City and aligns with the existing General Plan Industrial (I) designation, it would not be considered unplanned population growth.
7.3 Growth Inducement Due to Additional Housing
As discussed in Section 5.12, the project area is currently designated as General Industrial (I) in the City of Chula Vista General Plan (City of Chula Vista 2005) . The land uses on site would be amended to allow for a flexible combination of light industrial, office, commercial and visitor -oriented uses. No residential units are proposed; therefore, the project would not induce growth due to additional housing.
7.4 Growth Inducement Due to Removal of Obstacles
Improvements to transportation, utilities, and public service infrastructure as part of the proposed project would accommodate the direct growth induced by the proposed project. These improvements would connect to existing infrastructure (including water and sewer) adjacent to the project site and would provide access and utility service solely to the proposed project. The project does not propose larger infrastructure projects that would serve the regional area as a whole.
The proposed project will feature a storm drain system that meets the City’s Standard Urban Stormwater Mitigation Plan requirements for water quality and that can handle peak flows. The system will utilize concrete gutters to collect and transport on-site runoff into storm drains located along the western property line of Planning Areas B-1 and B-2. These private storm drains connect to large -diameter City storm drains located at the southwest and northwest corners of Planning Areas B -1 and B-2. Planning Area A drains through an overland flow system into a ditch along its western property line before entering the City ’s storm drain system along H Street. The drainage 7 – GROWTH INDUCEMENT
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facilities will incorporate low-impact development and water quality features on site, such as swales, bioretention basins, and mechanical treatment, and will be designed to comply with all water quality requirements. The proposed storm drain system is designed to accommodate the proposed project.
The growth -inducing potential of the proposed project would be significant if the infrastructure improvements required to serve the project significantly exceeded the City’s capacity to accommodate growth beyond what is envisioned under the General Plan. However, because the project site is within a developed area along the Bayfront, which currently supports development and is surrounded by complementing land uses, only minor improvements limited to the project site are required to ensure adequate infrastructure is available to serve the proposed project.
Overall, the proposed project would not result in growth inducement due to removal of obstacles.
7.5 Taxation of Existing Public Facilities and Services As stated in CEQA Guidelines Section 15126.2(d), “Increases in the population may tax existing community service facilities, requiring construction of new facilities that could cause significant environmental effects.” As described in Section 5.12 of this EIR , the proposed project would not result in a substantial burden to existing community services or facilities, such as police service, fire service, schools, parks, or libraries. The proposed project would be required to pay the City’s Public Facilities Development Impact Fees (PFDIF). The PFDIF would address the project’s proportional impact on capital facilities, such as structures and equipment. It does not address the impact associated with operations and maintenance for those facilities. Public funds such as property taxes, sales taxes, and fees generated by the project would be used to cover the incremental costs associated with providing services.
The project would be required to pay the PFDIF, which would be used exclusively for future facility imp rovements necessary to ensure that the development contributes its fair share of the cost of facilities and equipment determined to be necessary to adequately accommodate new development in the City. Therefore, the proposed project would not indirectly induce growth due to taxation of existing public facilities and services.
7 – GROWTH INDUCEMENT
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8 Significant Irreversible
Environmental Changes
California Environmental Quality Act (CEQA) Guidelines Section 15126.2(c) indicates the following:
[U]ses of non-renewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or non -use thereafter unlikely. Primary impacts and, particularly, secondary impacts (such as hi ghway improvement which provides access to a previously inaccessible area) generally commit future generations to similar uses. Also irreversible damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.
Implementation of the proposed Rohr Wohl Project (project or proposed project) would involve consumption of limited, slowly renewable, and non -renewable resources. This consumption would occur during the construction phase of the project and would continue throughout its operational lifetime. The project would require a commitment of resources that would include (1) building materials, (2) fuel and operational materials/resources, and (3) the transportation of goods and people to and from the project site.
Construction of the project would require the consumption of resources that are not renewable or that may renew so slowly as to be considered non -renewable. These resources would include the following construction supplies:
certain types of lumber and other forest products; aggregate materials used in concrete and asphalt such as sand, gravel, and stone; metals such as steel, copper, and lead ; petrochemical construction materials such as plastics; water; and fossil fuels such as gasoline and oil. While implementation of mitigation measures and project design features would reduce the use of non-renewable resources, fossil fuels would represent the primary energy source associated with construction and ongoing operation of the project, and the existing, finite supplies of these natural resources would be incrementally reduced.
Additionally, the project would involve an unquantifiable, but limited, use of potentially hazardous materials typical for mixed-use development projects, including cleaning solvents and fertilizers and pesticides for landscaping.
These materials would be contained, stored, and used on site in accordance with manufacturers’ instructions and applicable standards and regulations. Compliance with regulations would serve to protect against a significant and irreversible environmental change that could result from the accidental release of hazardous materials.
Furthermore, the project would result in the permanent commitment of land to support the proposed land uses that will redevelop and repurpose land that has been developed and operated for industrial purposes since about 1941.
The project could result in direct and indirect impacts to sensitive species such as migratory birds or bats .
Direct/indirect impacts would be considered potentially significant under CEQA and require implementation of the mitigation measures outlined in Section 5.3, Biological Resources. These mitigation measures would be consistent with the City of Chula Vista Multiple Species Conservation Program Subarea Plan and the Habitat Loss and Incidental Take Ordinance and would reduce impacts to a level below significance.
8 – SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES
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9 Effects Found Not to Be Significant
Section 15128 of the California Environmental Quality Act (CEQA) Guidelines requires that an environmental impact report (EIR) briefly describe potential environmental effects that were determined not to be significant and therefore were not discussed in detail in the EIR. The environmental issues discussed below are not considered significant for the proposed Rohr Wohl Specific Plan Project (project or proposed project), and the reasons for the conclusion of non-significance are discussed below.
9.1 Agriculture and Forestry Resources
Prior to development in 1941, the project site was used for agricultural purposes. However, according to the California Department of Conservation’s California Important Farmland Finder, the project site is not within an important farmland area and is categorized as Urban and Built-Up Land. Urban and Built-Up Land is defined as land occupied by structures with a building density of at least 1 unit to 1.5 acres, or approximately 6 structures to a 10-acre parcel (DOC 2018). The site was previously developed with two main industrial buildings and several outbuildings that were developed and operated for industrial purposes since about 1941. The project site lies within the General Industrial (I) Zoning and Industrial (I) General Plan land use designations and is therefore not zoned for or intended to support agricultural or forestry uses. As such, because the project site is not currently used for agriculture or forestry and has been developed since 1941, no impacts to agriculture and forestry resources would occur.
9.2 Mineral Resources
The Surface Mining and Reclamation Act of 1975 includes requirements and programs to ensure the long-term availability of mineral resources and ensure that the significant adverse environmental impacts of surface mining are adequately mitigated. As mandated by the Surface Mining and Reclamation Act of 1975, aggregate mineral resources within the state are classified by the State Mining and Geology Board through application of the Mineral Resource Zone (MRZ) system. The MRZ s ystem is used to map all mineral commodities within identified jurisdictional boundaries, with priority given to areas where future mineral resource extraction may be prevented or restricted by land use compatibility issues, or where mineral resources may be mined during the 50 -year period following their classification. The MRZ system classifies lands that contain mineral deposits and identifies the presence or absence of substantial sand and gravel deposits and crushed rock source areas (i.e., commodities used as, or in the production of, construction materials). The state geologist classifies MRZs within a region based on the following factors:
▪ MRZ-1: Areas where adequate information indicates that no significant mineral deposits are present, or where it is judged that little likelihood exists for their presence. ▪ MRZ-2: Areas where adequate information indicates that significant mineral deposits are present or where it is judged that a high likelihood for their presence exists. ▪ MRZ-3: Areas containing mineral deposits for which the significance cannot be determined from available data. ▪ MRZ-4: Areas where geologic information does not rule out either the presence or absence of mineral resources.
According to the Updated Mineral Land Classification Map for Portland Cement Concrete -Grade Aggregate in the Western San Diego County Production-Consumption Region, California, a majority of the project site is located within an MRZ-1 zone, meaning there are no significant mineral deposits present, or it is judged that little likelihood exists 9 – EFFECTS FOUND NOT TO BE SIGNIFICANT
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for their presence (DOC 2017). The eastern portion of the site is located in MRZ-3 zone, meaning areas containing mineral deposits for which the significance cannot be determined from available data (DOC 2017).
As discussed in the City of Chula Vista General Plan, Environmental Element, portions of the Otay River Valley are identified as an MRZ-2 area (City of Chula Vista 2005). Additionally, two other MRZ-2 areas are located on and just outside the General Plan area: one in the Sweetwater River Valley east of the Sweetwater Reservoir, and the other along the Jamul/Dulzura Creek east of Lower Otay Lake. However, the project site is located outside the “Regionally Significant” MRZ-2 Aggregate Resource Areas (City of Chula Vista 2005). Additionally, the project would not be used for extractive uses, but rather for a variety of uses including Commercial Retail (CR), Commercial Visitor (CV), Commercial Office (CO), Light Industrial (LI), Regional Technology Park (RTP), and Business Park Flex (BPF). Thus, the City would not permit or plan for mining operations as a future use in this area. Therefore, a less than significant impact to mineral resources would occur.
9.3 Wildfire
Wildfire is a continuous threat in Southern California and is particularly concerning in the wildland–urban interface, the geographic area where urban development either abuts or intermingles with wildland or vegetative fuels.
Because the City receives limited precipitation, the potential for wildland fires represents a significant hazard within certain areas of the City (City of Chula Vista 2005). The project site is an area statutorily designated as a Local Responsibility Area by the City and the California Department of Forestry and Fire Protection (CAL FIRE) and is not located within a designated Fire Hazard Severity Zone (CAL FIRE 2022). The project site is located in the Bayfront area of the City and is surrounded by existing and newly developed sites. There are no adjacent wildlands or vegetative fuels.
The City’s fire protection and emergency medical services are provided by the Chula Vista Fire Department (CVFD).
In conformance with the CVFD Master Plan, the City plans on expanding CVFD staffing and equipment as needed to meet the service standard and to minimize hazards to firefighters and the public. CVFD currently operates nine fire stations. The nearest fire station to the site is Fire Station No. 1, located less than 1 mile from the site.
The project site is an existing industrial site with existing infrastructure. Improvements to infrastructure would be necessary to ensure adequate levels of service for the future land uses proposed and would be designed based on the City’s codes and regulations. The installation and maintenance of associated infrastructure would not exacerbate wildfire risk or result in impacts to the environment. Impacts to wildfire would be less than significant.
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10 Alternatives
10.1 Introduction
Section 15126.6 of the California Environmental Quality Act (CEQA) Guidelines states that the Environmental Impact Report (EIR) shall “describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project and evaluate the comparative merits of the alternatives.” The compara tive merits of the alternatives evaluated, including the No Project Alternative, shall also be discussed.
The range of alternatives evaluated in an EIR is governed by the “rule of reason,” which requires the EIR set forth alternatives adequate to permit a reasoned choice by decisionmakers and limited to alternatives that “would avoid or substantially lessen any of the significant effects of the project.” An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose implementation is remote and speculative (Section 15126.6(a) of the CEQA Guidelines).
Other than the No Project Alternative, the EIR needs to examine only those alternatives that could feasibly obtain most of the basic objectives of the proposed project even if the alternative would impede to some degree the attainment of project objectives.
Factors that may influence feasibility of an alternative also include “site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control, or otherwise have access to the alternative site (or the site is already owned by the proponent)” (CEQA Guidelines, Section 15126.6[f][1]). The ultimate determination as to whether an alternative is feasible or infeasibl e is made by the lead agency’s decision -making body, the Chula Vista City Council (see PRC Section 21081[a] [3].)
This section presents several alternatives to the proposed project, which were considered pursuant to CEQA and evaluated for their ability to meet the basic objectives of the project, while reducing or avoiding the environmental impacts of the project identified in Chapter 5, Environmental Analysis, of the EIR. Those alternatives include: (1) No Project/No Build Alternative (Section 10.4.1); (2) Build to Existing Land Use Designations Alternative (Section
10.4.2); (3) Exclusion of Hotel in Planning Area B -2 Alternative (Section 10.4.3); and (4) Exclusion of all Planning Area B-2 Alternative (Section 10.4.4).
10.2 Criteria for Selection and Analysis of Alternatives The Rohr Wohl Specific Plan Project (project or proposed project) would not result in any significant and unavoidable impacts. The proposed project would result in potentially significant impacts that would be reduced to a level below significant with implementation of mitigation, re lated to the following: air quality, biological resources, cultural resources, and geology and soils (paleontological resources). The proposed project would result in less -than- significant impacts to the following: aesthetics, energy, greenhouse gases, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, population and housing, public services, recreation, traffic and circulation, tribal cultural resources, and utilities and service systems. 10 - ALTERNATIVES
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For each of the alternatives identified, this EIR conducts the following assessment:
▪ Describe the alternative
▪ Determine if the alternative would meet most of the basic project objectives ▪ Assess potential feasibility of the alternative
▪ Determine if the alternative would potentially eliminate or reduce a potentially significant impact of the project
If the alternative meets the above criteria and provides a meaningful CEQA analysis, then the EIR analysis will address the potential impacts of the alternative relative to those potentially significant impacts of the project. An environmentally superior a lternative will then be identified based on the alternative’s ability to reduce environmental impacts.
Based on the identified potentially significant environmental impacts above, the objectives established for the project (refer to Section 10.3, Project Objectives, below), consideration of local plans and zoning designations, and consideration of public input, this EIR evaluates four alternatives to the proposed project:
No Project/No Build Alternative
Build to Existing Land Use Alternative
Exclusion of Hotel in Planning Area B-2
Exclusion of All Planning Area B-2
10.2.1 Feasibility
CEQA Guidelines, Section 15126.6(f)(1), identifies the factors to be taken into account to determine the feasibility of alternatives. The factors include site suitability; economic viability; availability of infrastructure; general plan consistency; other plans or regulatory limitations; jurisdictional boundaries; and whether the applicant can reasonably acquire, control, or otherwise have access to the alternative site. No one of these factors establishes a fixed limit on the scope of reasonable alternatives. An alternative does not need to be considered if its environmental effects cannot be reasonably ascertained and if implementation of such an alternative is remote or speculative.
It has been recognized that, for purposes of CEQA, “feasibility” encompasses “desirability” to the extent that the latter is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors (California Native Plant Society v. City of Santa Cruz [2009] 177 Cal.App.4th 957, 1001). This balancing is harmonized with CEQA’s fundamental recognition that policy considerations may render alternatives impractical or undesirable (California Public Resources Code Section 21081; CEQA Guidelines Section 15126.6[c] and 15364).
10.2.2 Evaluation of Significant Impacts
According to CEQA Guidelines, Section 15126.6(b), the alternatives discussion should focus on those alternatives that, if implemented, could eliminate or reduce any of the significant environmental impacts of the proposed project.
The significant effects of the project impacts are considered to be those that are identified to be potentially significant prior to the incorporation or implementation of any mitigation measures. 10 - ALTERNATIVES
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10.2.3 Rationale for the Selection of Alternatives
As part of an alternatives analysis, CEQA requires an EIR to address a No Project Alternative. The purpose of describing and analyzing a No Project Alternative is to allow decision makers to compare the impacts of approving a proposed project with the impacts of not approving the proposed project.
EIRs should also identify any alternatives that were considered by the Lead Agency but rejected, and briefly explain the reasons why the Lead Agency made such a determination. Among the factors that may be used in an EIR to eliminate alternatives from detailed consideration are (1) failure to meet most of the basic project objectives, ( 2) infeasibility, and/or (3) inability to avoid significant environmental impacts.
In accordance with these requirements and based on comments received during the CEQA Notice of Preparation and scoping process for the proposed project, alternatives to the proposed project were considered and analyzed compared to the proposed project.
10.3 Project Objectives
Following are the objectives of the proposed project:
1. Generate a diverse spectrum of employment opportunities and regain for Chula Vista the approximate 1,000 jobs that existed on the site during Rohr Industries operations.
Foster Chula Vista’s capture of leading businesses and employers in existing and emerging economic sectors that drive the regional economy.
Encourage clean industrial, research and development, and office use designations (e.g., defense, Port - related, e-commerce, technology, hospitality, and medical device/life sciences).
Allow a flexible combination of light industrial, commercial, and visitor -oriented uses to enhance both the existing Collins Aerospace campus and the greater Chula Vista Bayfront area, while taking advantage of its proximity to the I-5 FWY, the Port of San Diego, various defense industry assets and contractors.
Attract significant capital investment to Chula Vista at vacant and underutilized property.
Highlight the proximity to the “E” Street and “H” Street Trolley Stations to encourage transit usage by visitors and workers.
Expand mobility options of today and the future and thoughtfully address Vehicle Miles Traveled (“VMT”).
Leverage ideal location in the bi -national region, with proximity to Mexico, convenient access by air (SAN, CBX) and enhanced border crossing infrastructure under development.
Provide flexibility for land uses and development that evolves as the Chula Vista Bayfront matures over the coming years and decades.
Provide for roadways, infrastructure, and utilities to support on-site land uses as the project evolves.
Facilitate the establishment of design guidelines and development standards consistent with the citywide design guidelines for commercial and industrial uses and Local Coastal Program guidelines.
Develop a plan that is economically feasible and capable of implementation based on reasonably anticipated economic conditions such that no economic burden to the City of Chula Vista would occur. 10 - ALTERNATIVES
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10.4 Alternatives Impact Summary
10.4.1 No Project/No Build Alternative
No construction would occur on site. Planning Areas B-1 and B-2 would remain vacant with newly remediated soil.
Warehouse in Planning Area A would remain in current condition similar to proposed project. All impacts identified as a result of the proposed project would be reduced.
Aesthetics
As described in Section 5.1, Aesthetics, from both the Marina Parkway/H Street intersection and the northerly segment of Marina Parkway, the project site is not within westerly oriented views toward San Diego Bay, and therefore, implementation of the Specific Plan and construction and operation o f potential future commercial, industrial, technology, and business park development in Planning Areas A, B -1, and B -2 would not result in blockage or substantial interruption of existing available views to San Diego Bay from Marina Parkway. The project site is not readily visible from a state scenic highway and proposed development would not remove or substantially alter scenic resources, including trees, rock outcroppings, and historic buildings. The project would not conflict with aesthetics-related policies of the General Plan. Because implementation of the Rohr Wohl Specific Plan and future development on the project site would be consistent with identified aesthetics -related policies of the Chula Vista General Plan, potential conflicts with existing regulations governing scenic quality are not anticipated, and impacts would be less than significant. In addition, exterior lighting installed on the project site to support operations would not adversely affect nighttime views in the area, and the project would not result in substantial glare that would adversely affect daytime views in the area.
Under the No Project/No Build Alternative, nothing would be built in Planning Area B -1 or B-2 and it would remain vacant, graded, and with soil remediated. The existing warehouse in Planning Area A would remain in its current condition. Excluding development in Planning Areas B -1 and B-2 would not complement the surrounding developments currently underway and would not active the waterfront with compatible uses on site. Leaving the project site as vacant graded land with no development would likely increase aesthetics impacts and would negatively contribute to the scenic quality of the area. Impacts would be increased as a result of the No Project/No Build Alternative.
Air Quality
As described in Section 5.2, Air Quality, the proposed project fosters a development pattern that promotes orderly growth by developing on a site with previous industrial uses. As such, the project would not contribute to substantial population and employment growth and associated VMT that was not anticipated for the project site in the existing General Plan. Giving the previous uses that existed on the project site, the anticipated growth in employment and population would be within regional growth forecas ts. Implementation of the proposed project would not conflict with or obstruct the implementation of the Regional Air Quality Strategy ( RAQS) and/or applicable portions of the State Implementation Plan (SIP). Daily construction emissions for the project would exceed the South Coast Air Quality Management District’s (SCAQMD’s) significance thresholds for volatile organic compounds (VOCs), primarily from painting emissions. Therefore, the project would have a potentially significant impact related to emissions of criteria air pollutant emissions during construction and mitigation is required to reduce the impact. Mitigation Measure AQ-1 (MM AQ-1) would require the use of super compliant VOC paint, which is 10 milligrams (mg) of VOC per liter. The net daily operational emissions for the project would not exceed the SCAQMD’s thresholds for any criteria air pollutant. 10 - ALTERNATIVES
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Therefore, the project would result in a less -than-significant impact related to emissions of criteria air pollutant emissions during operation.
The construction health risk assessment ( HRA) determined that diesel particulate matter ( DPM) emissions from construction of the project would result in a Maximum Individual Cancer Risk of 20 in 1 million and a Chronic Hazard Index of 0.011. The Chronic Hazard Index would be below the 1.0 significance threshold; however, the project would exceed the cancer risk threshold of 10 in a million and would be potentially significant without mitigation (MM-AQ- 2 and MM-AQ-4). The operational HRA determined that DPM emissions from operation of the project would result in a Maximum Individual Cancer Risk of 205 in 1 million and a Chronic Hazard Index of 0.055. The Chronic Hazard Index would be below the 1.0 significance threshold; however, the project would exceed the cancer risk threshold of 10 in a million and would be potentially significant without mitigation (MM -AQ-4, MM-AQ-5, and MM -AQ-6). All impacts would be reduced to less than significant with mitigation.
Under the No Project/No Build Alternative, air pollutant emissions associated with construction, including emissions associated with site preparation, site finishing, and architectural coatings, would not occur. This alternative would therefore avoid significant but mitigable emissions related to exposure from construction emissions, because no construction air pollutant emissions would occur. Implementation of this alternative would not introduce any uses that would generate operational air pollutant emiss ions. Although, leaving the site as a graded vacant lot would require daily or weekly dust suppression measures which would result in air quality impacts. However, compared to the proposed project, the No Project/No Build Alternative would reduce air quality impacts because no construction or operation would occur.
Biological Resources
As described in Section 5.3, Biological Resources, The entire project site consists of Tier IV habitats. Tier IV habitats are not considered significant and do not require mitigation. Special -status plant species were not documented within the study area and do not have a moderate or high potential to occur. Two documented special-status wildlife species were found within the study area, American peregrine falcon and osprey. This species has a low potential to nest on site. However, prior to mitigation, imp acts would be potentially significant. MM -BIO-1 would be implemented to reduce impacts to a less -than-significant level. Osprey have a moderate potential for nesting on the site; therefore, impacts would be potentially significant prior to mitigation (MM-BIO-2).
The study area has the potential to support nests that would be protected under the MBTA and/or the California Fish and Game Code Section 3503, under which it is unlawful to “take, possess, or needlessly destroy” avian nests or eggs. Thus, if additional vegetation clearing or grading happens during the breeding season, impacts would be potentially significant and mitigation (MM -BIO-3) would be required. The area is not known to support roosting colonies of special-status bats; therefore, construction is not anticipated to substantially affect either species (pallid bat and western mastiff bat) . Nonetheless, prior to mitigation (MM -BIO-4 and MM -BIO-5) impacts would be potentially significant.
In addition, compliance with regional and local laws, regulations, and policies, would ensure that indirect impacts would be less than significant; the proposed project would result in no impact to riparian habitats or other sensitive natural communities; the project site does not support areas that could be considered jurisdictional by the U.S. Army Corps of Engineers (USACE), Regional Water Quality Control Board ( RWQCB), California Coastal Commission, or California Department of Fish and Wildlife ( CDFW); the project does not propose any new barriers, such as new development or fencing, that would prevent wildlife movement; and the proposed project would abide by all local policies and ordinances protecting biological resources in the City of Chula Vista (City). However, in order to ensure 10 - ALTERNATIVES
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the project’s compliance with the Multiple Species Conservation Program ( MSCP) Subarea Plan, mitigation (MM - BIO-6, MSCP Subarea Plan Consistency and Adjacency) would be required. Prior to mitigation impacts would be potentially significant.
The No Project /No Build Alternative would not require any additional ground-disturbing activities. As such, this alternative would not result in potential direct and/or indirect impacts to nesting birds. This alternative would not require implementation of any mitigation measures , as proposed for the project. Therefore, as no development would occur under this alternative, compared to the proposed project, this alternative would result in reduced impacts to biological resources.
Cultural and Tribal Cultural Resources
As described in Section 5.4, Cultural and Tribal Cultural Resources, the potential for intact cultural deposits to exist within native soils to the depths of proposed ground disturbance is unknown. In the event that unanticipated cultural resources are encountered during project implementation , impacts could be potentially significant, and mitigation measures (MM-CUL-1) would be required. The results of the records search did not identify the presence of any previously recorded archaeological sites within t he project site. However, prior to mitigation impacts would be potentially significant. While the potential to encounter human remains is low, in the event that human remains are uncovered, impacts would also be potentially significant (MM-CUL-1). On May 3, 2024, the City sent notification letters pursuant to Assembly Bill ( AB) 52 and Senate Bill ( SB) 18 to tribes who are traditionally and culturally affiliated with the area of the project. To date, one response from the San Pasqual Tribe was received on May 30, 2024. In response to their request, the City provided the project -specific Cultural Resources Report. The City reached out to the Tribe on July 17, 2024 via e -mail to conduct a formal consultation, and no response has been reciprocated. Consultation with Native American tribes is ongoing. Mitigation would still be required to reduce impacts to less than significant.
The No Project/No Build Alternative would not require any additional ground-disturbing activities. As such, this alternative would not result in potential direct and/or indirect significant impacts to cultural or tribal cultural resources. This alternative would not require implementation of MM-CUL-1 as proposed for the project. Therefore, compared to the proposed project, this alternative would result in reduced impacts to cultural and tribal cultural resources.
Energy
As described in Section 5.5, Energy, construction and operational consumption of electricity, natural gas, and petroleum would not be considered inefficient, wasteful, or otherwise unnecessary and impacts would be less than significant. In addition, the project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
The No Project/No Build Alternative would not require any energy consumption during construction, because nothing would be developed. This Alternative would also not consume any additional energy during operation because the warehouse on Planning Area A would remain in operation as it currently is, and nothing would be built in Planning Areas B-1 or B-2. As a result, less energy would be consumed under this alternative and impacts would be reduced compared to the proposed project.
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Geology and Soils
As described in Section 5.6, Geology and Soils, impacts associated with landslides, seismic ground shaking, expansive soils and erosion would be less than significant. However, development of the proposed project would require excavations for building foundations and utilities, and any excavations into the potentially fossil -bearing strata within the Bay Point and San Diego Formations could result in potentially significant impacts to paleontological resources, and mitigation measure MM-GEO-1 would be required. Impacts would be reduced to less than significant.
Under the No Project/No Build Alternative, the project site would remain in its current state (graded and with soil remediated, and the existing warehouse in Planning Area A would remain as is) . Existing topography and on -site soils would not be disturbed by any development. Paleontological resources would be avoided under this alternative since no additional grading or excavation for building foundations would be required , but conversely those resources would not be found for curation, study, and exhibition. Therefore, when compared to the proposed project, the No Project/no Build Alternative would reduce impacts related to geology and soils.
Greenhouse Gas Emissions
As described in Section 5.7, G reenhouse Gas Emissions, the project’s significance is based on its potential to conflict with the applicable plans adopted for the purpose of reducing greenhouse gas (GHG) emissions, including the City’s climate action plan (CAP), the 2022 Scoping Plan, the 2017 Scoping Plan, AB 32 Regulations, the San Diego Association of Governments’ ( SANDAG’s) Regional Transportation Plan ( RTP)/Sustainable Communities Strategy (SCS) and the City’s General Plan. As demonstrated in Section 5. 7, the project would not conflict with applicable GHG reduction plans and regulations, accordingly, the impact would be less than significant.
Under the No Project/No Build Alternative, the project site would remain in its current state (graded and with soil remediated, and the existing warehouse in Planning Area A would remain as is). Under the No Project/No Build Alternative, GHG emissions asso ciated with construction and operation would not occur. Implementation of this alternative would not introduce any uses that would generate GHG emissions, with the exception of ongoing vehicle trips and operation of the warehouse in Planning Area-A. With no development occurring in Planning Area B-1 or B- 2 GHG emissions under the No Project/No Build Alternative would be reduced compared to the proposed project.
Hazards and Hazardous Materials
As described in Section 5.8, Hazards and Hazardous Materials, construction and operation of the project is not anticipated to create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. In addition, because soil contamination would be remediated to San Diego RWQCB and San Diego Department of Environmental Health and Quality standards prior to project construction, minor grading and trenching would not encounter contaminated soil that could result in a significant hazard to on -site construction personnel or the environment. Further, with compliance with the Construction General Permit and MS4 Permit, project construction would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditio ns involving the release of hazardous materials into the environment. Lastly, the project would not result in potentially hazardous conditions to nearby schools; result in safety hazards or excessive noise for people working or residing near an airport; re sult in interference with an adopted emergency response or evacuation plan; or result in the exposure of people or structures to wildfires. 10 - ALTERNATIVES
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Under the No Project/No Build Alternative, nothing would be built in Planning Area B-1 or B-2 and no potential use or storage of hazardous materials would occur. No hazardous materials associated with construction would be used on site because no construction would occur. Hazardous materials used during the operation of existing warehouse in Planning Area A would include various commercially available hazardous materials and cleaning products. When used in compliance with manufacturer’s recommendations and applicable regulations, these chemicals do not result in a risk to human health or the environment. The routine transport, use, and/or disposal of these substances would be subject to applicable federal, state, and local health and safety laws and regulati ons, which would minimize risks associated with their use. Overall, since less development would occur, impacts would be reduced under this alternative compared to the proposed project.
Hydrology and Water Quality
As described in Section 5.9, Hydrology and Water Quality, through implementation of the requirements outlined in the Construction General Permit (CGP), construction-related impacts to surface water and groundwater would be minimized and impacts would be less than significant. With incorporation of water quality best management practices (BMPs) and project design features, the project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. The project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin. The proposed storm drain system would be sufficient to satisfy Chula Vista criteria in the post-development condition (Appendix I1) and would not result in erosive scour and associated siltation of San Diego Bay. In addition, the project would not increase the rate of surface runoff; would not exceed the capacity of stormwater drainage systems; would not impede or redirect flood flows; is not located in a flood hazard, tsunami, or seiche zone; and would not interfere with implementation of water quality control plans or sustainable groundwater management plans.
Under the No Project/No Build Alternative, the site would remain vacant, graded, and with soil remediated in Planning Areas B-1 and B-2, and the existing industrial building would remain in operation in Planning Area A . No new stormwater infrastructure would be installed and temporary water diversion and sediment capture devices being used while the site is in a graded state would remain in place. Without development on site, no engineered stormwater infrastructure would be created to ensure runoff is not polluted and ensure runoff would not exceed the capacity of existing infrastructure. Potential impacts to hydrology and water quality may be increased under the No Project/No Build Alternative compared to the proposed project.
Land Use
As described in Section 5.10, Land Use and Planning , the proposed project would not result in a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Impacts would be less than significant.
Under the No Project/No Build Alternative, the site would remain vacant, graded, and with soil remediated in Planning Areas B-1 and B-2, and the existing industrial building would remain in operation in Planning Area A. The cumulative projects surrounding the site would continue to be constructed and go into operation while the project site would remain vacant. A vacant site would provide less compatibility with surrounding uses. Infrastructure would not be upgraded (i.e., utility undergrounding, sidewalk improvements, etc.) and no development impact fees would be collected by the City. Overall, leaving the site vacant could result in greater conflicts with land use plans and land use compatibility; thus, land use impacts may be increased under the No Project/No Build Alternative compared to the proposed project.
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Noise
As described in Section 5.11, Noise, short-term construction noise is predicted to be well below the Federal Transit Administration (FTA) guidance of 80 A-weighted decibels (dBA) energy-equivalent sound level (Leq) over an 8-hour period, and therefore is less than significant. Traffic related to construction activities would not result in a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.
Potential impacts at existing off -site noise -sensitive land uses along roadway segments and project -generated changes to future traffic noise would be less than significant. Noise generated by Planning Areas A, B -1, and B-2 are expected to be below the City’s 50 dBA Leq nighttime threshold for multi-family residential land uses. Note that the multi-family residential land use threshold is applied to this analysis due to an absence of City thresholds for hotel land uses. Therefore, impacts associated with stationary opera tions noise would be less than significant.
Lastly, because the predicted vibration level at 70 feet is less than this guidance limit of 0.2 to 0.3 inches per second (ips) peak particle velocity (PPV) and because there are no residential structures adjacen t to the project, the risk of vibration damage to nearby structures is considered less than significant.
Under the No Project/No Build Alternative, the site would remain vacant, graded, and with soil remediated in Planning Areas B-1 and B-2, and the existing industrial building would remain in operation in Planning Area A. There would be no potential increase in noise associated with construction or operation because nothing would be built in Planning Areas B-1 or B-2. Impacts related to noise would be reduced under the No Project/No Build Alternative compared to the proposed project.
Population and Housing
As described in Section 5.12, Population and Housing, once operational, the estimated 1,000 jobs that would result from the proposed project would result in some amount of population growth within the City due to new employment opportunities; however, this population growth would not be considered unplanned because the proposed project would restore what was previously a major job center for the City of Chula Vista. No existing residential uses occupy the project site as the site was previously developed with industrial buildings, which have since been demolished.
The proposed project does not include the construction of any residential units and would not displace existing housing or people or necessitate the construction of replacement housing elsewhere.
Similar to the proposed project, no housing would be developed under the No Project/No Build Alternative and no housing would be displaced. However, no increase or restoration of previous employment opportunities would be provided under this alternative. W hile impacts were determined to be less than significant under the proposed project, due to the lack of employment opportunities, impacts may be slightly reduced under the No Project/No Public Services
As described in Section 5.13, Public Services, the project would not substantially increase the demand of fire protection services requiring the construction of new or expanded fire protection facilities or facilitate the need for additional firefighters and equipment. The City’s Public Facilities Development Impact Fee (PFDIF) would help cover the cost of new or expanding public facilities within the City, including fire and police facilities. The proposed project would be subject to payment of the PFDIF fees at the rate in effect at the time building permits are issued. Payment of the PFDIF would be necessary to ensure that the project contributes its fair share of the cost of fire police facilities and equipment needed to adequately accommodate increasing demand within the City. In addition, the project site is located within existing Community Facilities Districts (CFDs) for Chula Vista Elementary School District (CVESD) 10 - ALTERNATIVES
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and Sweetwater Union High School District (SUHSD), which impose a special tax on property owners to finance both school districts. Any development of new school facilities resulting from these CFDs would be undertaken by the school district at that time. Pursuant to Education Code Section 17620(a)(1), th e governing board can authorize the levy of a fee, charge, dedication, or other requirements against any construction within school district boundaries, and with the school district’s collection of Statutory and Alternative fees developers can fully mitigate any impacts. Lastly, because the project is considered a commercial development, payment of PFDIF for libraries is not required.
Under the No Project/No Build Alternative, the site would remain vacant, graded, and with soil remediated in Planning Areas B-1 and B-2, and the existing industrial building would remain in operation in Planning Area A. There would be no additional demand on police and fire services as no habitable buildings would be developed in Planning Areas B-1 and B-2. Existing demand for services would remain for Planning Area A but no PFDIF would be collected for the undeveloped portions of the site. Impacts would be slightly reduced under the No/Project No Build Alternative when compared to the proposed project.
Recreation
As described in Section 5.14, Recreation, per Chula Vista Municipal Code (CVMC) Section 17.10.120, the proposed project would not be required to pay park development fees because there are no proposed residences within the project. Therefore, because the proposed project does not include a new residential population and would not increase the use of existing neighborhood and regional parks or other recreati onal facilities such that substantial physical deterioration of the facility would occur or be accelerated. Impacts would be less than significant.
Similar to the proposed project, no residences would be constructed as part of the No Project/No Build Alternative.
Therefore, no increase in the use of existing parks or physical deterioration of recreational facilities would occur.
Impacts would be similar when compared to the proposed project.
Transportation
As described in Section 5.15, Transportation, the proposed project would not conflict with existing or proposed bicycle, pedestrian, or transit facilities in its vicinity. In addition, the proposed project (A, B1, and B2) is located in census tract 12600. The SANDAG average VMT per employee is 18.90 and the threshold of 85 percent would be
16.06 VMT per employee or below. The average VMT per employee of this tract is 15.91, which is below the regional average VMT per employee of 18.90 as well as below the VMT per employee threshold (i.e., 85 percent of the reginal mean) of 16.06. Therefore, it can be concluded that the proposed project is in a VMT efficient area for all employee uses. Because the proposed project would meet the VMT screening criteria described above, a more detailed VMT analysis is not required, and can be presumed to result in a less-than-significant VMT impact.
Under the No Project/No Build Alternative, the site would remain vacant, graded, and with soil remediated in Planning Areas B-1 and B-2, and the existing industrial building would remain in operation in Planning Area A. No additional trips would be generated during construction or operation under the No Project /No Build Alternative because nothing would be built in Planning Areas B-1 or B-2. Therefore, when compared to the proposed project, the No Project/No Build Alternative would reduce impacts related to traffic and circulation because no VMT impacts would have the potential to occur.
As shown in the Local Mobility Analysis (LMA), the project would be fully responsible for signalizing the Bay Boulevard and G Street and Project Driveway and H Street intersections and retiming the signals at the I-5 Northbound Ramps 10 - ALTERNATIVES
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and E Street, Bay Boulevard and H Street, I-5 Northbound Ramps and H Street, and I-5 Northbound and Southbound Ramps and J Street intersections. The Project would contribute its fair share towards the construction of a traffic signal or roundabout at the Bay Boulevard and F Street. The Project would contribute its fair share towards the construction of a traffic signal at the J Street and L Street intersections with Bay Boulevard. All proposed improvements would achieve LOS D or better conditions during both peak periods except for the roundabout at Bay Boulevard and F Street. The improvements identified in the LMA are recommendations and the final improvement plan and project funding responsibility will be defined and documented in a separate Rohr/Wohl Specific Plan Transportation Conditions of Approval memo.
The No Project/No Build Alternative would not result in any development or add any trips to the surrounding streets or intersections. No fair share payment would be necessary, and no improvements would be constructed.
Utilities and Service Systems
As described in Section 5.16, Utilities and Service Systems, the proposed project would have adequate water, wastewater, stormwater, and telecommunication infrastructure. The project would be required to comply with all local and state regulations regarding solid waste and the surrounding landfills would have capaci ty to serve the project. Impacts would be less than significant.
Under the No Project/No Build Alternative, the site would remain vacant, graded, and with soil remediated in Planning Areas B-1 and B-2, and the existing industrial building would remain in operation in Planning Area A. No water supply would be needed, no wastewater would be generated, and no solid waste would be disposed of during construction or operation because nothing would be built under this alternative. Although impacts to utilities and service systems were determined to be less than significant, th e No Project/No Build Alternative would have reduced impacts compared to the proposed project.
10.4.2 Build to Existing Land Use Designations Alternative Rather than revising the land use/zoning designations the site would remain zoned General Industrial (I) and remain designated Industrial (I) by the General Plan. Development under this alternative would be required to be consistent with existing permitted uses in the General Industrial zone. Permitted uses in this zone include food service commercial, convenience sales and service commercial, business and communication service commercial, retail business supply commercial , research and development commerci al, general wholesale sales commercial , transportation and warehousing commercial, automotive fee parking commercial, custom industrial, light industrial, general industrial, and essential service civic.
Aesthetics
As described in Section 5.1, Aesthetics, from both the Marina Parkway/H Street intersection and the northerly segment of Marina Parkway, the project site is not within westerly oriented views toward San Diego Bay, and therefore, implementation of the Speci fic Plan and construction and operation of potential future commercial, industrial, technology, and business park development in Planning Areas A, B -1, and B -2 would not result in blockage or substantial interruption of existing available views to San Diego Bay from Marina Parkway. The project site is not readily visible from a state scenic highway and proposed development would not remove or substantially alter scenic resources, including trees, rock outcroppings, and historic buildings. The project would not conflict with aesthetics-related policies of the General Plan. Because implementation of the Rohr Wohl Specific Plan and future development on the project site would be consistent with identified aesthetics -related policies of the Chula Vista 10 - ALTERNATIVES
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General Plan, potential conflicts with existing regulations governing scenic quality are not anticipated, and impacts would be less than significant. In addition, exterior lighting installed on the project site to support operations would not adversely affect nighttime views in the area, and the project would not result in substantial glare that would adversely affect daytime views in the area.
Under the Build to Existing Land Use Designations Alternative, Planning Area B -1 or B-2 would be developed with allowed uses and the existing warehouse in Planning Area A would remain in its current condition and in operation.
As with the proposed project, development in Planning Areas B-1 or B-2 would likely complement the surrounding developments currently underway and would active the waterfront with compatible uses on site, as much as possible. Development under this alternative would also be required t o adhere to the design specifications in the Bayfront Specific Plan. Impacts would likely be similar under the Build to Existing Land Use Designations Alternative when compared to the proposed project.
Air Quality
As described in Section 5.2, Air Quality, the proposed project fosters a development pattern that promotes orderly growth by developing on a site with previous industrial uses. As such, the project would not contribute to substantial population and employment growth and associated VMT that was not anticipated for the project site in the existing General Plan. Giving the previous uses that existed on the project site, the anticipated growth in employment and population would be within regional growth forecas ts. Implementation of the proposed project would not conflict with or obstruct the implementation of the RAQS and/or applicable portions of the SIP. Daily construction emissions for the project would exceed the SCAQMD’s significance thresholds for VOC, primarily from painting emissions .
Therefore, the project would have a potentially significant impact related to emissions of criteria air pollutant emissions during construction and mitigation is required to reduce the impact. Mitigation Measure AQ-1 (MM AQ-1) would require the use of super compliant VOC paint, which is 10 mg of VOC per liter. The net daily operational emissions for the project would not exceed the SCAQMD’s thresholds for any criteria air pollutant. Therefore, the project would result in a less-than-significant impact related to emissions of criteria air pollutant emissions during operation.
The construction HRA determined that DPM emissions from construction of the project would result in a Maximum Individual Cancer Risk of 20 in 1 million and a Chronic Hazard Index of 0.011. The Chronic Hazard Index would be below the 1.0 significance threshold; however, the project would exceed the cancer risk threshold of 10 in a million and would be potentially significant without mitigation (MM-AQ-2 and MM-AQ-4). The operational HRA determined that DPM emissions from operation of the project would result in a Maximum Individual Cancer Risk of 205 in 1 million and a Chronic Hazard Index of 0.055. The Chronic Hazard Index would be below the 1.0 significance threshold; however, the project would exceed the cancer risk threshold of 10 in a million and would be potentially significant without mitigation (MM -AQ-4, MM -AQ-5, and MM -AQ-6). All impacts would be reduced to less than significant with mitigation.
Under the Build to Existing Land Use Designations Alternative, air pollutant emissions associated with construction, including emissions associated with site preparation, site finishing, and architectural coatings, would still occur.
This alternative would likely not avoid significant but mitigable emissions related to exposure from construction emissions, because construction air pollutant emissions would still occur. Similar to the proposed project, implementation of this alternative would introduce uses that would generate operational air pollutant emissions.
Compared to the proposed project, the Build to Existing Land Use Designations Alternative would have similar air quality impacts because construction and operation would still occur ; it is anticipated that similar mitigation measures would be required to reduce such impacts to less than significant. 10 - ALTERNATIVES
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Biological Resources
As described in Section 5.3, Biological Resources, the entire project site consists of Tier IV habitats. Tier IV habitats are not considered significant and do not require mitigation. Special -status plant species were not documented within the study area and do not have a moderate or high potential to occur. Two documented special-status wildlife species were found within the study area, American peregrine falcon and osprey. This species has a low potential to nest on site. However, prior to mitigation, imp acts would be potentially significant. MM -BIO-1 would be implemented to reduce impacts to a less -than-significant level. Osprey have a moderate potential for nesting on the site; therefore, impacts would be potentially significant prior to mitigation (MM-BIO-2).
The study area has the potential to support nests that would be protected under the MBTA and/or the California Fish and Game Code Section 3503, under which it is unlawful to “take, possess, or needlessly destroy” avian nests or eggs. Thus, if additional vegetation clearing or grading happens during the breeding season, impacts would be potentially significant and mitigation (MM -BIO-3) would be required. The area is not known to support roosting colonies of special-status bats; therefore, construction is not anticipated to substantially affect either species (pallid bat and western mastiff bat) . Nonetheless, prior to mitigation (MM -BIO-4 and MM -BIO-5) impacts would be potentially significant.
In addition, compliance with regional and local laws, regulations, and policies, would ensure that indirect impacts would be less than significant; the proposed project would result in no impact to riparian habitats or other sensitive natural communities; the project site does not support areas that could be considered jurisdictional by USACE, RWQCB, the California Coastal Commission, or CDFW; the project does not propose any new barriers, such as new development or fencing, that would prevent wildlife move ment; and the proposed project would abide by all local policies and ordinances protecting biological resources in the City of Chula Vista. However, in order to ensure the project’s compliance with the MSCP Subarea Plan, mitigation (MM -BIO-6, MSCP Subarea Plan Consistency and Adjacency) would be required. Prior to mitigation impacts would be potentially significant.
The Build to Existing Land Use Designations Alternative would require some additional ground-disturbing activities, similar to the proposed project. As such, this alternative could result in potential direct and/or indirect impacts to nesting birds. This a lternative would require implementation of mitigation measures, similar to the proposed project, to reduce potential impacts to sensitive biological resources (pallid bat and western mastiff bat) to less than significant, as well as to ensure compliance wi th MSCP requirements. Therefore, as development would still occur under this alternative, compared to the proposed project, this alternative would result in similar impacts to biological resources.
Cultural and Tribal Cultural Resources
As described in Section 5.4, Cultural and Tribal Cultural Resources, the potential for intact cultural deposits to exist within native soils to the depths of proposed ground disturbance is unknown. In the event that unanticipated cultural resources are encountered during project implementation, impacts could be p otentially significant, and mitigation measures (MM-CUL-1) would be required. The results of the records search did not identify the presence of any previously recorded archaeological sites within the project site. However, prior to mitigation impacts woul d be potentially significant. While the potential to encounter human remains is low, in the event that human remains are uncovered, impacts would also be potentially significant (MM-CUL-1). On May 3, 2024, the City sent notification letters pursuant to AB 52 and SB 18 to tribes who are traditionally and culturally affiliated with the area of the project. To date, one response from the San Pasqual Tribe was received on May 30, 2024. In respons e to their request, the City provided the project-specific Cultural Resources Report. The City reached out to the Tribe on July 10 - ALTERNATIVES
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17, 2024, via e-mail to conduct a formal consultation, and no response has been reciprocated. Consultation with Native American tribes is ongoing. Mitigation would still be required to reduce impacts to less than significant.
Implementation of the Build to Existing Land Use Designations Alternative would require minimal additional ground- disturbing activities would be required, similar to the proposed project . As such, this alternative could result in potential direct and/or indirect significant impacts to cultural or tribal cultural resources. This alternative would require implementation of MM-CUL-1 as proposed for the project to reduce impacts to less than significant .
Therefore, compared to the proposed project, this alternative would result in similar impacts to cultural and tribal cultural resources.
Energy
As described in Section 5.5, Energy, construction and operational consumption of electricity, natural gas, and petroleum would not be considered inefficient, wasteful, or otherwise unnecessary and impacts would be less than significant. In addition, the project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
The Build to Existing Land Use Designations Alternative would require energy consumption during construction of Planning Areas B -1 and B -2. This Alternative would also consume additional energy during operation because development would occur in Planning Areas B -1 and B-2 and the warehouse on Planning Area A would remain in operation as it currently is. As a result, a similar amount of energy would be consumed under this alternative and impacts would be the same compared to the proposed project.
Geology and Soils
As described in Section 5.6, Geology and Soils, impacts associated with landslides, seismic ground shaking, expansive soils and erosion would be less than significant. However, development of the proposed project would require excavations for building foun dations and utilities, and any excavations into the potentially fossil -bearing strata within the Bay Point and San Diego Formations could result in potentially significant impacts to paleontological resources, and mitigation measure MM-GEO-1 would be required. Impacts would be reduced to less than significant.
The Build to Existing Land Use Designations Alternative minimal additional ground -disturbing activities would be required, similar to the proposed project. Paleontological resources would have the potential to be disturbed under this alternative and implementation of MM-GEO-1 would be required. Therefore, when compared to the proposed project, the Build to Existing Land Use Designations Alternative would have similar impacts to the proposed project.
Greenhouse Gas Emissions
As described in Section 5.7, Greenhouse Gas Emissions, the project’s significance is based on its potential to conflict with the applicable plans adopted for the purpose of reducing GHG emissions, including the City’s CAP, the 2022 Scoping Plan, the 2017 S coping Plan, AB 32 Regulations, SANDAG’s RTP/SCS and the City’s General Plan.
As demonstrated in Section 5.7, the project would not conflict with applicable GHG reduction plans and regulations, accordingly, the impact would be less than significant.
Under the Build to Existing Land Use Designations Alternative, GHG emissions associated with construction, including emissions associated with site preparation, site finishing, and architectural coatings, would still occur.
This alternative would still result in GHG emissions related to construction and operation, because development 10 - ALTERNATIVES
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would occur in Planning Areas B -1 and B -2 and Planning Area A would remain in operation. Compared to the proposed project, the Build to Existing Land Use Designations Alternative would have similar GHG impacts because construction and operation would still occur.
Hazards and Hazardous Materials
As described in Section 5.8, Hazards and Hazardous Materials, construction and operation of the project is not anticipated to create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. In addition, because soil contamination would be remediated to San Deigo RWQCB and San Diego Department of Environmental Health and Quality standards prior to project construction, minor grading and trenching would not encounter contaminated soil that c ould result in a significant hazard to on -site construction personnel or the environment. Further, with compliance with the Construction General Permit and MS4 Permit, project construction would not create a significant hazard to the public or the environm ent through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Lastly, the project would not result in potentially hazardous conditions to nearby schools; result in safety hazards or exce ssive noise for people working or residing near an airport; result in interference with an adopted emergency response or evacuation plan; or result in the exposure of people or structures to wildfires.
Under the Build to Existing Land Use Designations Alternative, development would occur in Planning Area B-1 and B-2 and potential use or storage of hazardous materials during construction and operation would occur similar to the proposed project. Further, with compliance with the Construction General Permit and MS4 Permit, construction of this alternative would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. This alternative would occur on the same project site, so the same less-than-significant impacts would result as it relates to soil remediation, proximity to a school, conflicts with an emergency response or evacuation plan, and risk of wildfires. Therefore, impacts would be similar under this alternative compared to the proposed project.
Hydrology and Water Quality
As described in Section 5.9, Hydrology and Water Quality, through implementation of the requirements outlined in the CGP, construction-related impacts to surface water and groundwater would be minimized and impacts would be less than significant. With incorporation of water quality BMPs and project design features, the project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. The project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin. The proposed storm drain system would be sufficient to satisfy Chula Vista criteria in the post-development condition (Appendix I1) and would not result in erosive scour and associated siltation of San Diego Bay. In addition, the project would not increase the rate of surface runoff; would not exceed the capacity of stormwater drainage systems; would not impede or redirect flood flows; is not located in a flood hazard, tsunami, or seiche zone; and would not interfere with implementation of water quality control plans or sustainable groundwater management plans.
Under the Build to Existing Land Use Designations Alternative, development would occur in Planning Areas B-1 and B-2, and the existing industrial building would remain in operation in Planning Area A. New stormwater infrastructure would be installed and temporary water diversion and sediment capture devices would be used during construction.
Similar to the proposed project, engineered stormwater infrastructure would be created to ensure runoff is not polluted and ensure runoff would not exceed the capacity of existing infrastructure. The storm drain system under this alternative would be required to satisfy Chula Vista criteria in the post -development condition and would not 10 - ALTERNATIVES
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result in erosive scour and associated siltation of San Diego Bay. Potential impacts to hydrology and water quality would be similar when compared to the proposed project.
Land Use
As described in Section 5.10, Land Use and Planning, the proposed project would not result in a significant environmental impact due to division of an established community, a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Impacts would be less than significant.
Rather than revising the land use/zoning designations , the site would remain zoned General Industrial (I) and remain designated Industrial (I) by the General Plan under this alternative . Development under this alternative would be required to be consistent with existing permitted uses in the General Industrial zone. Permitted uses in this zone include food service commercial , convenience sales and service commercial , business and communication service commercial , retail business supply commercial , research and development commercial , general wholesale sales commercial , transportation and warehousing commercial , automotive fee parking commercial, custom industrial, light industrial, general industrial, and essential service civic. Thus, land use impacts under the Build to Existing Land Use Designations Alternative would be the same compared to the proposed project.
Noise
As described in Section 5.11, Noise, short-term construction noise is predicted to be well below the FTA guidance of 80 dBA L eq over an 8 -hour period, and therefore is less than significant. Traffic related to construction activities would not result in a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. Potential impacts at existing off-site noise-sensitive land uses along roadway segments and project- generated changes to future traffic noise would be less than significant. Noise generated by Planning Areas A, B-1, and B-2 are expected to be below the City’s 50 dBA L eq nighttime threshold for multi-family residential land uses.
Note that the multi -family residential land use threshold is applied to this analysis due to an absence of City thresholds for hotel land uses. Therefore, impacts associated with stationary operations noise would be less than significant. Lastly, because the predicted vibration level at 70 feet is less than this guidance limit of 0.2 to 0.3 ips PPV and because there are no residential structures adjacent to the project, the risk of vibration damage to nearby structures is considered less than significant.
Under the Build to Existing Land Use Designations Alternative, development would occur in Planning Areas B-1 and B-2, and the existing industrial building would remain in operation in Planning Area A. There would an increase in noise associated with construction and operation, similar to the proposed project, because development would be built and in operation. It is also assumed that predicted vibration level at 70 feet would be less than this guidance limit of 0.2 to 0.3 ips PPV and because there are no residential structures adjacent to the site, the risk of vibration damage to nearby structures under this alternative is considered less than significant. Impacts related to noise would be similar under the Build to Existing Land Use Designations Alternative compared to the proposed project.
Population and Housing
As described in Section 5.12, Population and Housing, once operational, the estimated 1,000 jobs that would result from the proposed project would result in some amount of population growth within the City due to new employment opportunities; however, this population growth would not be considered unplanned because the proposed project would restore what was previously a major job center for the City of Chula Vista. No existing residential uses occupy 10 - ALTERNATIVES
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the project site as the site was previously developed with industrial buildings, which have since been demolished.
The proposed project does not include the construction of any residential units and would not displace existing housing or people or necessitate the construction of replacement housing elsewhere.
Similar to the proposed project, no housing would be developed under the Build to Existing Land Use Designations Alternative and no housing would be displaced. An increase in employment and/or restoration of previous employment opportunities would also be provided under this alternative. Impacts were determined to be less than significant under the proposed project, and impacts would be similar under the Build to Existing Land Use Designations Alternative.
Public Services
As described in Section 5.13, Public Services, the project would not substantially increase the demand of fire protection services requiring the construction of new or expanded fire protection facilities or facilitate the need for additional firefighters a nd equipment. The City’s PFDIF would help cover the cost of new or expanding public facilities within the City, including fire and police facilities. The proposed project would be subject to payment of the PFDIF fees at the rate in effect at the time build ing permits are issued. Payment of the PFDIF would be necessary to ensure that the project contributes its fair share of the cost of fire police facilities and equipment needed to adequately accommodate increasing demand within the City. In addition, the project site is located within existing CFDs for CVESD and SUHSD, which impose a special tax on property owners to finance both school districts. Any development of new school facilities resulting from these CFDs would be undertaken by the school district a t that time. Pursuant to Education Code Section 17620(a)(1), the governing board can authorize the levy of a fee, charge, dedication, or other requirements against any construction within school district boundaries, and with the school district’s collection of Statutory and Alternative fees developers can fully mitigate any impacts. Lastly, because the project is considered a commercial development, payment of PFDIF for libraries is not required.
The Build to Existing Land Use Designations Alternative would develop Planning Areas B-1 and B-2 consistent with existing land use and zoning designations and the industrial building in Planning Area A would remain in operation.
Payment of the City’s PFDIF would still be required under this alternative to help cover the cost of new or expanding public facilities within the City. It is likely that a similar amount of resources would be required to serve development under this alternative as the proposed project and impacts would be the same.
Recreation
As described in Section 5.14, Recreation, per CVMC Section 17.10.120, the proposed project would not be required to pay park development fees because there are no proposed residences within the project. Therefore, because the proposed project does not include a new residential population and would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. Impacts would be less than significant.
The Build to Existing Land Use Designations Alternative would develop Planning Areas B-1 and B-2 consistent with existing land use and zoning designations and the industrial building in Planning Area A would remain in operation.
Residential uses are not currently an allowed use under the existing zoning or General Plan land use, so similar to the proposed project, the Build to Existing Land Use Designations Alternative would not in new population or residences. Therefore, development under this alternative would not be required to pay park development impact fees. Impacts would be similar to the proposed project. 10 - ALTERNATIVES
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Transportation
As described in Section 5.15, Transportation, the proposed project would not conflict with existing or proposed bicycle, pedestrian, or transit facilities in its vicinity. In addition, the proposed project (A, B1 , and B2) is located in census tract 12600. The SANDAG average VMT per employee is 18.90 and the threshold of 85 percent would be
16.06 VMT per employee or below. The average VMT per employee of this tract is 15.91, which is below the regional average VMT per employee of 18.90 as well as below the VMT per employee threshold (i.e., 85 percent of the reginal mean) of 16.06. Therefore, it can be concluded that the proposed project is in a VMT efficient area for all employee uses. Because the proposed project would meet the VMT screening criteria described above, a more detailed VMT analysis is not required, and can be presumed to result in a less-than-significant VMT impact.
The Build to Existing Land Use Designations Alternative would develop Planning Areas B-1 and B-2 consistent with existing land use and zoning designations and the industrial building in Planning Area A would remain in operation.
Additional trips would be generated during construction and operation similar to the proposed project. Similarly, the average VMT per employee of this tract is 15.91, which is below the regional average VMT per employee of 18.90 as well as below the VMT per employee threshold (i.e., 85 percent of the reginal mean) of 16.06. Therefore, it can be concluded that similar to the proposed project, this alternative is in a VMT efficient area for all employee uses.
Because this alternative would meet the VMT screening criteria, a more detailed VMT analysis would not be required, and can be presumed to result in a less -than-significant VMT impact. Thus, when compared to the proposed project, the Build to Existing Land Use Designations Alternative would result in similar impacts related to traffic and circulation.
As shown in the LMA, the project would be fully responsible for signalizing the Bay Boulevard and G Street and Project Driveway and H Street intersections and retiming the signals at the I -5 Northbound Ramps and E Street, Bay Boulevard and H Street, I-5 Northbound Ramps and H Street, and I-5 Northbound and Southbound Ramps and J Street intersections. The Project would contribute its fair share towards the construction of a traffic signal or roundabout at the Bay Boulevard and F Street. The Project would contribute its fair share towards the construction of a traffic signal at the J Street and L Street intersections with Bay Boulevard. All proposed improvements would achieve LOS D or better conditions during both peak periods e xcept for the roundabout at Bay Boulevard and F Street. The improvements identified in the LMA are recommendations and the final improvement plan and project funding responsibility will be defined and documented in a separate Rohr/Wohl Specific Plan Transportation Conditions of Approval memo.
The Build to Existing Land Use Designations Alternative would still add trips to the surrounding streets and intersections, and would still be required to pay fair share fees or construct improvements as determined to be necessary. Impacts would not be reduced under this alternative.
Utilities and Service Systems
As described in Section 5.16, Utilities and Service Systems, the proposed project would have adequate water, wastewater, stormwater, and telecommunication infrastructure. The project would be required to comply with all local and state regulations regarding solid waste and the surrounding landfills would have capacity to serve the project.
Impacts would be less than significant.
The Build to Existing Land Use Designations Alternative would develop Planning Areas B-1 and B-2 consistent with existing land use and zoning designations and the industrial building in Planning Area A would remain in operation.
Additional water supply would be needed, wastewater would be generated, and solid waste would be disposed of during 10 - ALTERNATIVES
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construction or operation under this alternative. Depending on what was developed in Planning Areas B-1 and B-2 it is likely that impacts would be similar regarding utilities and services systems when compared to the proposed project.
10.4.3 Exclusion of Hotel in Planning Area B-2 Alternative The following alternative would allow some of the project’s proposed uses for Planning Area B -2 (such as restaurants, office space, and visitor serving uses) other than a hotel. Exclusion of a potential hotel in Planning Area B-2 would, because of the uniq ue operational characteristics of a hotel, substantially reduce operational impacts associated with air quality, GHG emissions, traffic, and utilities (water supply, wastewater service, and solid waste generation). All of the same approvals and amendments to existing documents as the proposed project would be required under this alternative. The approval of the Rohr Wohl Specific Plan would amend the City’s zoning for the property to allow the development of the proposed project with commercial, industrial, and office uses. This would remain the same under the Exclusion of Hotel in Planning Area B-2 Alternative. Site access, internal circulation, and connection to existing utilities would still occur as detailed in Chapter 4, Project Description.
Aesthetics
As described in Section 5.1, Aesthetics, from both the Marina Parkway/H Street intersection and the northerly segment of Marina Parkway, the project site is not within westerly oriented views toward San Diego Bay, and therefore, implementation of the Speci fic Plan and construction and operation of potential future commercial, industrial, technology, and business park development in Planning Areas A, B -1, and B -2 would not result in blockage or substantial interruption of existing available views to San Diego Bay from Marina Parkway. The project site is not readily visible from a state scenic highway and proposed development would not remove or substantially alter scenic resources, including trees, rock outcroppings, and historic buildings. The project would not conflict with aesthetics-related policies of the General Plan. Because implementation of the Rohr Wohl Specific Plan and future development on the project site would be consistent with identified aesthetics -related policies of the Chula Vista General Plan, potential conflicts with existing regulations governing scenic quality are not anticipated, and impacts would be less than significant. In addition, exterior lighting installed on the project site to support operations would not adversely affect nighttime views in the area, and the project would not result in substantial glare that would adversely affect daytime views in the area.
Under the Exclusion of Hotel in Planning Area B-2 Alternative, Planning Area B-1 and B-2 would still be developed with allowed uses and the existing warehouse in Planning Area A would remain in its current condition and in operation. As with the proposed project, development in Planning Areas B -1 or B -2 would complement the surrounding developments curren tly underway and would active the waterfront with compatible uses on site, although no hotel would be constructed . Development under this alternative would also be required to adhere to the design specifications in the Bayfront Specific Plan. Impacts would likely be similar under the Exclusion of Hotel in Planning Area B-2 Alternative when compared to the proposed project.
Air Quality
As described in Section 5.2, Air Quality, the proposed project fosters a development pattern that promotes orderly growth by developing on a site with previous industrial uses. As such, the project would not contribute to substantial population and employment growth and associated VMT that was not anticipated for the project site in the existing General Plan. Giving the previous uses that existed on the project site, the anticipated growth in employment and population would be within regional growth forecasts. Implementation of the proposed project would not conflict with or obstruct the implementation of the RAQS and/or applicable portions of the SIP. Daily construction emissions 10 - ALTERNATIVES
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for the project would exceed the SCAQMD’s significance thresholds for VOC, primarily from painting emissions .
Therefore, the project would have a potentially significant impact related to emissions of criteria air pollutant emissions during construction and mitigation is required to reduce the impact. Mitigation Measure AQ-1 (MM AQ-1) would require the use of super compliant VOC paint, which is 10 mg of VOC per liter. The net daily operational emissions for the project would not exceed the SCAQMD’s thresholds for any criteria air pollutant. Therefore, the project would result in a less-than-significant impact related to emissions of criteria air pollutant emissions during operation.
The construction HRA determined that DPM emissions from construction of the project would result in a Maximum Individual Cancer Risk of 20 in 1 million and a Chronic Hazard Index of 0.011. The Chronic Hazard Index would be below the 1.0 significance threshold; however, the project would exceed the cancer risk threshold of 10 in a million and would be potentially significant without mitigation (MM-AQ-2 and MM-AQ-4). The operational HRA determined that DPM emissions from operation of the project would result in a Maximum Individual Cancer Risk of 205 in 1 million and a Chronic Hazard Index of 0.055. The Chronic Hazard Index would be below the 1.0 significance threshold; however, the project would exceed the cancer risk threshold of 10 in a million and would be potentially significant without mitigation (MM -AQ-4, MM -AQ-5, and MM -AQ-6). All impacts would be reduced to less than significant with mitigation.
Under the Exclusion of Hotel in Planning Area B-2 Alternative, air pollutant emissions associated with construction, including emissions associated with site preparation, site finishing, and architectural coatings, would still occur.
This alternative would not avoid significant but mitigable emissions related to exp osure from construction emissions, because construction air pollutant emissions would still occur. Emissions from traffic trips would be reduced when compared to the proposed project due to the r eduction in daily trips associated with a hotel.
Implementation of this alternative would still introduce uses that would generate operational air pollutant emissions, but not to the same extent that a hotel would. Compared to the proposed project, the Exclusion of Hotel in Planning Area B -2 Alternative, would have reduced impacts, because a hotel would not be built and a less intensive development, consistent with the Specific Plan, would be built instead.
Biological Resources
As described in Section 5.3, Biological Resources, The entire project site consists of Tier IV habitats. Tier IV habitats are not considered significant and do not require mitigation. Special -status plant species were not documented within the study area and do not have a moderate or high potential to occur. Two documented special-status wildlife species were found within the study area, American peregrine falcon and osprey. This species has a low potential to nest on site. However, prior to mitigation, imp acts would be potentially significant. MM -BIO-1 would be implemented to reduce impacts to a less -than-significant level. Osprey have a moderate potential for nesting on the site; therefore, impacts would be potentially significant prior to mitigation (MM-BIO-2).
The study area has the potential to support nests that would be protected under the MBTA and/or the California Fish and Game Code Section 3503, under which it is unlawful to “take, possess, or needlessly destroy” avian nests or eggs. Thus, if additional vegetation clearing or grading happens during the breeding season, impacts would be potentially significant and mitigation (MM -BIO-3) would be required. The area is not known to support roosting colonies of special-status bats; therefore, construction is not anticipated to substantially affect either species (pallid bat and western mastiff bat) . Nonetheless, prior to mitigation (MM -BIO-4 and MM -BIO-5) impacts would be potentially significant.
In addition, compliance with regional and local laws, regulations, and policies, would ensure that indirect impacts would be less than significant; the proposed project would result in no impact to riparian habitats or other sensitive 10 - ALTERNATIVES
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natural communities; the project site does not support areas that could be considered jurisdictional by USACE, RWQCB, the California Coastal Commission, or CDFW; the project does not propose any new barriers, such as new development or fencing, that would prevent wildlife movement; and the proposed project would abide by all local policies and ordinances protecting biological resources in the City of Chula Vista. However, in order to ensure the project’s compliance with the MSCP Subarea Plan, mitigation (MM -BIO-6, MSCP Subarea Plan Consistency and Adjacency) would be required. Prior to mitigation impacts would be potentially significant.
The Exclusion of Hotel in Planning Area B-2 Alternative would require some additional ground-disturbing activities, similar to the proposed project. As such, this alternative could result in potential direct and/or indirect impacts to nesting birds. This alternative would require implementation of mitigation me asures, similar to the proposed project. Therefore, as development would still occur under this alternative, compared to the proposed project, this alternative would result in similar impacts to biological resources and mitigation would be required.
Cultural and Tribal Cultural Resources
As described in Section 5.4, Cultural and Tribal Cultural Resources, the potential for intact cultural deposits to exist within native soils to the depths of proposed ground disturbance is unknown. In the event that unanticipated cultural resources are encountered during project implementation, impacts could be p otentially significant, and mitigation measures (MM-CUL-1) would be required. The results of the records search did not identify the presence of any previously recorded archaeological sites within t he project site. However, prior to mitigation impacts would be potentially significant. While the potential to encounter human remains is low, in the event that human remains are uncovered, impacts would also be potentially significant (MM-CUL-1). On May 3, 2024, the City sent notification letters pursuant to AB 52 and SB 18 to tribes who are traditionally and culturally affiliated with the area of the project. To date, one response from the San Pasqual Tribe was received on May 30, 2024. In respons e to the ir request, the City provided the project-specific Cultural Resources Report. The City reached out to the Tribe on July 17, 2024, via e-mail to conduct a formal consultation, and no response has been reciprocated. Consultation with Native American tribes is ongoing. Mitigation would still be required to reduce impacts to less than significant.
Under the Exclusion of Hotel in Planning Area B-2 Alternative minimal additional ground-disturbing activities would be required, similar to the proposed project. As such, this alternative could result in potential direct and/or indirect significant impacts to cultural or tribal cultural resources. This alternative wo uld require implementation of MM- CUL-1 as proposed for the project. Therefore, compared to the proposed project, this alternative would result in the same impacts to cultural and tribal cultural resources.
Energy
As described in Section 5.5, Energy, construction and operational consumption of electricity, natural gas, and petroleum would not be considered inefficient, wasteful, or otherwise unnecessary and impacts would be less than significant. In addition, the project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
The Exclusion of Hotel in Planning Area B -2 Alternative would require energy consumption during construction of Planning Areas B -1 and B -2. This Alternative would also consume additional energy during operation because development would occur in Planning Areas B -1 and B-2 and the warehouse on Planning Area A would remain in operation as it currently is. As a result, a similar amount of energy would be consumed under this alternative and impacts would be the same compared to the proposed project. 10 - ALTERNATIVES
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Geology and Soils
As described in Section 5.6, Geology and Soils, impacts associated with landslides, seismic ground shaking, expansive soils and erosion would be less than significant. However, development of the proposed project would require excavations for building foun dations and utilities, and any excavations into the potentially fossil -bearing strata within the Bay Point and San Diego Formations could result in potentially significant impacts to paleontological resources, and mitigation measure MM-GEO-1 would be required. Impacts would be reduced to less than significant.
Under the Exclusion of Hotel in Planning Area B-2 Alternative minimal additional ground-disturbing activities would be required, similar to the proposed project. Paleontological resources would have the potential to be disturbed under this alternative and implementation of MM -GEO-1 would be required. Therefore, when compared to the proposed project, the Exclusion of Hotel in Planning Area B -2 Alternative would have the same impacts to the proposed project.
Greenhouse Gas Emissions
As described in Section 5.7, Greenhouse Gas Emissions, the project’s significance is based on its potential to conflict with the applicable plans adopted for the purpose of reducing GHG emissions, including the City’s CAP, the 2022 Scoping Plan, the 2017 S coping Plan, AB 32 Regulations, SANDAG’s RTP/SCS and the City’s General Plan.
As demonstrated in Section 5.7, the project would not conflict with applicable GHG reduction plans and regulations, accordingly, the impact would be less than significant.
Under the Exclusion of Hotel in Planning Area B -2 Alternative , GHG emissions associated with construction, including emissions associated with site preparation, site finishing, and architectural coatings, would still occur.
GHG emissions related to construction and operation would be similar , because development would occur in Planning Areas B-1 and B-2 and Planning Area A would remain in operation. Emissions from traffic trips would be reduced when compared to the proposed project due to the reduction in d aily trips associated with a hotel.
Implementation of this alternative would still introduce uses that would generate operational and vehicle air pollutant emissions, but not to the same extent that a hotel would. Compared to the proposed project, the Exclusion of Hotel in Planning Area B -2 Alternative, would have reduced impacts, because a hotel would not be built and a less intensive development, consistent with the Specific Plan, would be built instead.