DRAFT
Final Environmental Impact Report
Rohr Wohl Specific Plan
STATE CLEARINGHOUSE NO. 2022100138
JULY 2025
Prepared for:
CITY OF CHULA VISTA
276 Fourth Avenue
Chula Vista, California 91910
Contact: Arturo Ortuno
Prepared by:
605 Third Street
Encinitas, California 92024
Contact: Alex Martini
Printed on 30% post-consumer recycled material.
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Table of Contents
SECTION PAGE NO.
Response to Comments ............................................................................................................................................ RTC-1 Errata .............................................................................................................................................................. ERRATA-1 1 Executive Summary.......................................................................................................................................... 1-1
1.1 Project Location and Setting .............................................................................................................. 1-1
1.2 Project Background ............................................................................................................................ 1-1
1.3 Project Description ............................................................................................................................. 1-2
1.3.1 Project Objectives ................................................................................................................. 1-2
1.3.2 Approvals and Amendments ................................................................................................ 1-3
1.4 Areas of Controversy .......................................................................................................................... 1-4
1.5 Project Alternatives ............................................................................................................................ 1-4
1.5.1 No Project/No Build Alternative ........................................................................................... 1-5
1.5.2 Build to Existing Land Use Designations Alternative .......................................................... 1-5
1.5.3 Exclusion of Hotel in Planning Area B-2 Alternative ........................................................... 1-5
1.5.4 Exclusion of All Planning Area B-2 Alternative .................................................................... 1-5
1.6 Summary of Significant Environmental Impacts .............................................................................. 1-5 2 Introduction ...................................................................................................................................................... 2-1
2.1 Project Purpose and Background ...................................................................................................... 2-1
2.2 Hierarchy of Planning Documents ..................................................................................................... 2-1
2.2.1 City of Chula Vista General Plan .......................................................................................... 2-1
2.2.2 Bayfront Local Coastal Program .......................................................................................... 2-2
2.2.3 City of Chula Vista Multiple Species Conservation Program .............................................. 2-2
2.3 Scope of the EIR ................................................................................................................................. 2-2
2.4 Environmental Procedures ................................................................................................................ 2-3
2.4.1 CEQA Compliance ................................................................................................................. 2-3
2.4.2 Notice of Preparation and Scoping ...................................................................................... 2-3
2.4.3 Overview of the EIR Process................................................................................................. 2-3
2.5 Intended Uses of the EIR ................................................................................................................... 2-4
2.6 Organization and Content of the EIR ................................................................................................. 2-4
2.7 Mitigation Monitoring and Reporting Program ................................................................................. 2-6 3 Environmental Setting ..................................................................................................................................... 3-1
3.1 Existing Site Conditions ...................................................................................................................... 3-1
3.1.1 Surrounding Land Uses ........................................................................................................ 3-1
3.1.2 Existing Topography and Soils ............................................................................................. 3-1
3.1.3 Climate .................................................................................................................................. 3-2
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3.1.4 Access .................................................................................................................................... 3-2
3.2 Existing Land Use Designations ........................................................................................................ 3-2
3.2.1 Existing General Plan Designations ..................................................................................... 3-2
3.2.2 Existing Zoning ...................................................................................................................... 3-2
3.2.3 Local Coastal Plan ................................................................................................................ 3-3 4 Project Description ........................................................................................................................................... 4-1
4.1 Location .............................................................................................................................................. 4-1
4.2 Background ......................................................................................................................................... 4-1
4.3 Project Objectives ............................................................................................................................... 4-2
4.4 Project Description ............................................................................................................................. 4-3
4.4.1 Approvals and Amendments ................................................................................................ 4-5
4.4.2 Access and Circulation Network .......................................................................................... 4-5
4.4.3 Public Service and Utilities ................................................................................................... 4-6
4.4.4 Construction Phasing and Conceptual Grading .................................................................. 4-8
4.4.5 Project Design Features ....................................................................................................... 4-8 5 Environmental Impact Analysis ....................................................................................................................... 5-1
5.1 Aesthetics ........................................................................................................................................ 5.1-1
5.1.1 Existing Conditions............................................................................................................. 5.1-1
5.1.2 Thresholds of Significance ................................................................................................ 5.1-7
5.1.3 Impacts ............................................................................................................................... 5.1-7
5.1.4 Level of Significance Prior to Mitigation ......................................................................... 5.1-13
5.1.5 Mitigation Measures ........................................................................................................ 5.1-13
5.1.6 Level of Significance After Mitigation ............................................................................. 5.1-13
5.2 Air Quality ......................................................................................................................................... 5.2-1
5.2.1 Existing Conditions............................................................................................................. 5.2-1
5.2.2 Thresholds of Significance .............................................................................................. 5.2-21
5.2.3 Impacts ............................................................................................................................. 5.2-32
5.2.4 Level of Significance Prior to Mitigation ......................................................................... 5.2-45
5.2.5 Mitigation Measures ........................................................................................................ 5.2-46
5.2.6 Level of Significance After Mitigation ............................................................................. 5.2-48
5.3 Biological Resources ....................................................................................................................... 5.3-1
5.3.1 Existing Conditions............................................................................................................. 5.3-1
5.3.2 Thresholds of Significance .............................................................................................. 5.3-13
5.3.3 Impacts ............................................................................................................................. 5.3-14
5.4 Cultural and Tribal Cultural Resources .......................................................................................... 5.4-1
5.4.1 Existing Conditions............................................................................................................. 5.4-1
5.4.2 Thresholds of Significance .............................................................................................. 5.4-10
5.4.3 Impacts ............................................................................................................................. 5.4-11
5.3.4 Level of Significance prior to Mitigation ......................................................................... 5.3-18
5.3.5 Mitigation Measures ........................................................................................................ 5.3-18
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5.3.6 Level of Significance after Mitigation ............................................................................. 5.3-20
5.4.4 Level of Significance prior to Mitigation ......................................................................... 5.4-13
5.4.5 Mitigation Measures ........................................................................................................ 5.4-13
5.4.6 Level of Significance after Mitigation ............................................................................. 5.4-15
5.5 Energy .............................................................................................................................................. 5.5-1
5.5.1 Existing Conditions............................................................................................................. 5.5-1
5.5.2 Thresholds of Significance ................................................................................................ 5.5-9
5.5.3 Impacts ............................................................................................................................... 5.5-9
5.5.4 Level of Significance Prior to Mitigation ......................................................................... 5.5-13
5.5.5 Mitigation Measures ........................................................................................................ 5.5-13
5.5.6 Level of Significance After Mitigation ............................................................................. 5.5-13
5.6 Geology and Soils ............................................................................................................................ 5.6-1
5.6.1 Existing Conditions............................................................................................................. 5.6-1
5.6.2 Thresholds of Significance ................................................................................................ 5.6-7
5.6.3 Impacts ............................................................................................................................... 5.6-8
5.6.4 Level of Significance prior to Mitigation ......................................................................... 5.6-11
5.6.5 Mitigation Measures ........................................................................................................ 5.6-11
5.6.6 Level of Significance after Mitigation ............................................................................. 5.6-12
5.7 Greenhouse Gas Emissions ............................................................................................................ 5.7-1
5.7.1 Existing Conditions............................................................................................................. 5.7-1
5.7.2 Thresholds of Significance .............................................................................................. 5.7-24
5.7.3 Impacts ............................................................................................................................. 5.7-30
5.7.4 Level of Significance Prior to Mitigation ......................................................................... 5.7-53
5.7.5 Mitigation Measures ........................................................................................................ 5.7-54
5.7.6 Level of Significance After Mitigation ............................................................................. 5.7-54
5.8 Hazards and Hazardous Materials ................................................................................................. 5.8-1
5.8.1 Existing Conditions............................................................................................................. 5.8-1
5.8.2 Thresholds of Significance .............................................................................................. 5.8-16
5.8.3 Impacts ............................................................................................................................. 5.8-16
5.8.4 Level of Significance Prior to Mitigation ......................................................................... 5.8-21
5.8.5 Mitigation Measures ........................................................................................................ 5.8-21
5.8.6 Level of Significance After Mitigation ............................................................................. 5.8-21
5.9 Hydrology and Water Quality ........................................................................................................... 5.9-1
5.9.1 Existing Conditions............................................................................................................. 5.9-1
5.9.2 Thresholds of Significance .............................................................................................. 5.9-11
5.9.3 Impacts ............................................................................................................................. 5.9-11
5.9.4 Level of Significance Prior to Mitigation ......................................................................... 5.9-20
5.9.5 Mitigation Measures ........................................................................................................ 5.9-20
5.9.6 Level of Significance After Mitigation ............................................................................. 5.9-20
5.10 Land Use and Planning ................................................................................................................. 5.10-1
5.10.1 Existing Conditions........................................................................................................... 5.10-1
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5.10.2 Thresholds of Significance .............................................................................................. 5.10-7
5.10.3 Impacts ............................................................................................................................. 5.10-7
5.10.4 Level of Significance prior to Mitigation ...................................................................... 5.10-10
5.10.5 Mitigation Measures ..................................................................................................... 5.10-11
5.10.6 Level of Significance after Mitigation .......................................................................... 5.10-11
5.11 Noise .............................................................................................................................................. 5.11-1
5.11.1 Existing Conditions........................................................................................................... 5.11-1
5.11.2 Thresholds of Significance .............................................................................................. 5.11-8
5.11.3 Impacts ............................................................................................................................. 5.11-9
5.11.4 Level of Significance Prior to Mitigation ...................................................................... 5.11-18
5.11.5 Mitigation Measures ..................................................................................................... 5.11-18
5.11.6 Level of Significance After Mitigation .......................................................................... 5.11-18
5.12 Population and Housing ................................................................................................................ 5.12-1
5.12.1 Existing Conditions........................................................................................................... 5.12-1
5.12.2 Thresholds of Significance .............................................................................................. 5.12-6
5.12.3 Impacts ............................................................................................................................. 5.12-6
5.12.4 Level of Significance prior to Mitigation ......................................................................... 5.12-7
5.12.5 Mitigation Measures ........................................................................................................ 5.12-7
5.12.6 Level of Significance after Mitigation ............................................................................. 5.12-7
5.13 Public Services .............................................................................................................................. 5.13-1
5.13.1 Regulatory Framework..................................................................................................... 5.13-1
5.13.2 Thresholds of Significance .............................................................................................. 5.13-8
5.13.3 Impact Analysis ................................................................................................................ 5.13-8
5.13.4 Level of Significance prior to Mitigation ......................................................................... 5.13-9
5.13.5 Mitigation Measures ..................................................................................................... 5.13-10
5.13.6 Level of Significance after Mitigation .......................................................................... 5.13-10
5.14 Recreation ...................................................................................................................................... 5.14-1
5.14.1 Existing Conditions........................................................................................................... 5.14-1
5.14.2 Thresholds of Significance .............................................................................................. 5.14-6
5.14.3 Impacts ............................................................................................................................. 5.14-7
5.14.4 Level of Significance prior to Mitigation ......................................................................... 5.14-8
5.14.5 Mitigation Measures ........................................................................................................ 5.14-8
5.14.6 Level of Significance after Mitigation ............................................................................. 5.14-8
5.15 Transportation ............................................................................................................................... 5.15-1
5.15.1 Existing Conditions........................................................................................................... 5.15-1
5.15.2 Regulatory Framework..................................................................................................... 5.15-3
5.15.3 Methodology ..................................................................................................................... 5.15-8
5.15.4 Significance Criteria ...................................................................................................... 5.15-14
5.15.5 Impacts .......................................................................................................................... 5.15-14
5.15.6 Level of Significance Prior to Mitigation ...................................................................... 5.15-19
5.15.7 Mitigation Measures ..................................................................................................... 5.15-19
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5.16 Utilities and Service Systems ........................................................................................................ 5.16-1
5.16.1 Existing Conditions........................................................................................................... 5.16-1
5.16.2 Thresholds of Significance .............................................................................................. 5.16-9
5.16.3 Impacts .......................................................................................................................... 5.16-10
5.16.4 Level of Significance Prior to Mitigation ...................................................................... 5.16-15
5.16.5 Mitigation Measures ..................................................................................................... 5.16-15
5.16.6 Level of Significance After Mitigation .......................................................................... 5.16-15 6 Cumulative Impacts ......................................................................................................................................... 6-1
6.1 Introduction......................................................................................................................................... 6-1
6.2 Methodology ....................................................................................................................................... 6-1
6.3 Cumulative Projects ........................................................................................................................... 6-2
6.4 Cumulative Impact Analysis ............................................................................................................... 6-2
6.4.1 Aesthetics .............................................................................................................................. 6-2
6.4.2 Air Quality .............................................................................................................................. 6-3
6.4.3 Biological Resources ............................................................................................................ 6-4
6.4.4 Cultural Resources and Tribal Cultural Resources ............................................................. 6-4
6.4.5 Energy .................................................................................................................................... 6-4
6.4.6 Geology and Soils ................................................................................................................. 6-4
6.4.7 Greenhouse Gas Emissions ................................................................................................. 6-5
6.4.8 Hazards and Hazardous Materials ...................................................................................... 6-5
6.4.9 Hydrology and Water Quality ................................................................................................ 6-6
6.4.10 Land Use and Planning......................................................................................................... 6-6
6.4.11 Noise ...................................................................................................................................... 6-6
6.4.12 Population and Housing ....................................................................................................... 6-7
6.4.13 Public Services ...................................................................................................................... 6-7
6.4.14 Recreation ............................................................................................................................. 6-8
6.4.15 Transportation ....................................................................................................................... 6-8
6.4.16 Utilities and Service Systems ............................................................................................... 6-9 7 Growth Inducement ......................................................................................................................................... 7-1
7.1 Growth Inducement Due to Population Growth ................................................................................ 7-1
7.2 Growth Inducement Due to Economic Growth ................................................................................. 7-2
7.3 Growth Inducement Due to Additional Housing ............................................................................... 7-2
7.4 Growth Inducement Due to Removal of Obstacles .......................................................................... 7-2
7.5 Taxation of Existing Public Facilities and Services ........................................................................... 7-3 8 Significant Irreversible Environmental Changes ........................................................................................... 8-1 9 Effects Found Not to Be Significant ................................................................................................................ 9-1
9.1 Agriculture and Forestry Resources .................................................................................................. 9-1
9.2 Mineral Resources ............................................................................................................................. 9-1
9.3 Wildfire ................................................................................................................................................ 9-2
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10 Alternatives ..................................................................................................................................................... 10-1
10.1 Introduction....................................................................................................................................... 10-1
10.2 Criteria for Selection and Analysis of Alternatives .......................................................................... 10-1
10.2.1 Feasibility ............................................................................................................................ 10-2
10.2.2 Evaluation of Significant Impacts ...................................................................................... 10-2
10.2.3 Rationale for the Selection of Alternatives ........................................................................ 10-3
10.3 Project Objectives ............................................................................................................................. 10-3
10.4 Alternatives Impact Summary .......................................................................................................... 10-4
10.4.1 No Project/No Build Alternative ......................................................................................... 10-4
10.4.2 Build to Existing Land Use Designations Alternative ...................................................... 10-11
10.4.3 Exclusion of Hotel in Planning Area B-2 Alternative ....................................................... 10-19
10.4.4 Exclusion of All Planning Area B-2 Alternative ................................................................ 10-26
10.5 Environmentally Superior Alternative ............................................................................................ 10-35 11 References ..................................................................................................................................................... 11-1 12 List of Preparers ............................................................................................................................................. 12-1
FIGURES
4-1 Project Location ............................................................................................................................................. 4-13 4-2 Project Site Plan ............................................................................................................................................. 4-15 4-3 Circulation....................................................................................................................................................... 4-17 4-4 Conceptual Grading Plan ............................................................................................................................... 4-47
5.1-1 Existing Conditions: Planning Area A ......................................................................................................... 5.1-15
5.1-2 Existing Conditions: Planning Areas B-2 and B-1 ...................................................................................... 5.1-17
5.1-3 Existing Conditions: Surrounding Area ....................................................................................................... 5.1-19
5.1-4 Existing Conditions: Surrounding Area ....................................................................................................... 5.1-21
5.1-5a View 1: Northbound H Street Looking Northeast Toward Project Site (Existing Conditions) .................. 5.1-23
5.1-5b View 1: Northbound H Street Looking Northeast Toward Project Site (Proposed Conditions) ............... 5.1-25
5.1-6a View 2: Southbound on H Street Bike Path Looking Northwest Toward Project Site and Active Construction (Existing Conditions) .................................................................................................. 5.1-27
5.1-6b View 2: Southbound on H Street Bike Path Looking Northwest Toward Project Site and Active Construction (Proposed Conditions) ............................................................................................... 5.1-29
5.3-1 Local Environmental Setting Map .............................................................................................................. 5.3-55
5.3-2 Biological Resources Map .......................................................................................................................... 5.3-57
5.3-3 Wetland Delineation Map ........................................................................................................................... 5.3-59
5.3-4 Biological Impacts Map............................................................................................................................... 5.3-61
5.3-5 MSCP Preserve BLA Map ............................................................................................................................ 5.3-63
5.8-1 Planning Areas ............................................................................................................................................ 5.8-23
5.8-2 Former Site Uses ......................................................................................................................................... 5.8-25
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5.9-1 Existing Drainage Conditions ...................................................................................................................... 5.9-21
5.9-2 FEMA Flood Zones ...................................................................................................................................... 5.9-23
5.9.3 Proposed Drainage Conditions ................................................................................................................... 5.9-25
5.11-1 Project Site and Noise Measurement Locations .................................................................................... 5.11-19
5.11-2 Predicted Daytime On-site Operations Noise Contours ......................................................................... 5.11-21
5.11-3 Predicted Nighttime On-site Operations Noise Contours....................................................................... 5.11-23
5.13-1 Facility Locations ...................................................................................................................................... 5.13-21
5.15-1 Circulation Plan Roadways ...................................................................................................................... 5.15-21
5.15-2 Pedestrian Route Types ........................................................................................................................... 5.15-23
5.15-3 Existing and Planned Bike Facilities ....................................................................................................... 5.15-25
5.15-4 Transit Facilities within Half-Mile of the Project ..................................................................................... 5.15-27
5.15-5 VMT Screening Map for Project ............................................................................................................... 5.15-29
5.16-1 Existing Water Facilities ........................................................................................................................... 5.16-16
5.16-2 Existing Sewer Infrastructure .................................................................................................................. 5.16-19 6-1 Cumulative Projects ....................................................................................................................................... 6-11 TABLES
1-1 Summary of Significant Environmental Impacts and Mitigation ................................................................... 1-7 4-1 Proposed Land Uses ........................................................................................................................................ 4-3 4-2 Proposed Land Uses for Planning Areas ........................................................................................................ 4-4
5.1-1 Consistency with Aesthetic-Related Policies of the General Plan .............................................................. 5.1-9
5.2-1 Ambient Air Quality Standards ..................................................................................................................... 5.2-2
5.2-2 Local Ambient Air Quality Data ..................................................................................................................... 5.2-4
5.2-3 SDAB Attainment Designation ...................................................................................................................... 5.2-5
5.2-4 SCAQMD Air Quality Significance Thresholds ............................................................................................ 5.2-22
5.2-5 CalEEMod Land Use Development Summary for the Proposed Project .................................................. 5.2-22
5.2-6 CalEEMod Land Use Development Summary for the Existing Site .......................................................... 5.2-23
5.2-7 Project Construction Schedule ................................................................................................................... 5.2-24
5.2-8 Construction Scenario Assumptions .......................................................................................................... 5.2-24
5.2-9 Project Trip Generation ............................................................................................................................... 5.2-27
5.2-10 Existing Project Site Trip Generation.......................................................................................................... 5.2-28
5.2-11 American Meteorological Society/Environmental Protection Agency Regulatory Model Principal Parameters ....................................................................................................................... 5.2-30
5.2-12 Operational Health Risk Assessment American Meteorological Society/ U.S. Environmental Protection Agency Regulatory Model Operational Principal Parameters ................ 5.2-31
5.2-13 San Diego Region vs. City of Chula Vista Population, Housing, and Employment Forecast .................. 5.2-34
5.2-14 Past Performance RHNA 5th Cycle (2013–2020) .................................................................................... 5.2-35
5.2-15 RHNA Allocation for the 6th Cycle (2021–2029) ...................................................................................... 5.2-35
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5.2-16 Employment by Industry in City of Chula Vista .......................................................................................... 5.2-36
5.2-17 Estimated Maximum Daily Construction Criteria Air Pollutant Emissions - Unmitigated ....................... 5.2-38
5.2-18 Estimated Maximum Daily Operational Criteria Air Pollutant Emissions ................................................. 5.2-39
5.2-19 Ambient Carbon Monoxide Concentrations for SCAQMD’s Most Congested Intersection ..................... 5.2-41
5.2-20 Carbon Monoxide Emission Factors Predicted by the EMFAC Model ...................................................... 5.2-42
5.2-21 Construction Health Risk Assessment Results – Unmitigated................................................................. 5.2-43
5.2-22 Operational Health Risk Assessment Results – Unmitigated .................................................................. 5.2-43
5.2-23 Estimated Maximum Daily Construction Criteria Air Pollutant Emissions - Mitigated ........................... 5.2-49
5.2-24 Construction Health Risk Assessment Results - Mitigated ...................................................................... 5.2-50
5.2-25 Operational Health Risk Assessment Results - Mitigated ........................................................................ 5.2-50
5.3-1 Vegetation Communities within the Study Area .......................................................................................... 5.3-7
5.3-2 Potential for City MSCP Subarea Plan Narrow Endemic Species to Occur ................................................ 5.3-9
5.3-3 Vegetation Communities within the Study Area ........................................................................................ 5.3-14
5.4-1 Archaeological Sites Recorded within 1 Mile of the Project Site ............................................................... 5.4-8
5.5-1 Construction Petroleum Demand ............................................................................................................... 5.5-10
5.5-2 Project Annual Operational Electricity Demand Summary ....................................................................... 5.5-11
5.5-3 Total Project-generated Transportation Annual Fuel Demand ................................................................. 5.5-12
5.7-1 Six Top GHG Producer Entities ................................................................................................................... 5.7-21
5.7-2 GHG Emissions Sources in California ........................................................................................................ 5.7-22
5.7-3 Project Potential to Conflict with City of Chula Vista Climate Action Plan ............................................... 5.7-31
5.7-4 Project Potential to Conflict with 2022 Scoping Plan ............................................................................... 5.7-35
5.7-5 Project Potential to Conflict with 2017 Scoping Plan GHG Emission Reduction Strategies ............................................................................................................... 5.7-37
5.7-6 Consistency with Assembly Bill 32 Regulatory Programs ......................................................................... 5.7-41
5.7-7 Project Consistency with SANDAG 2021 Regional Plan ........................................................................... 5.7-43
5.7-8 Project Consistency with the City of Chula Vista General Plan ................................................................. 5.7-47
5.7-9 Estimated Annual Construction Greenhouse Gas Emissions ................................................................... 5.7-51
5.7-10 Estimated Annual Operational Greenhouse Gas Emissions .................................................................... 5.7-52
5.8-1 Database Search Report Findings ............................................................................................................... 5.8-9
5.10-1 General Plan Consistency Table .............................................................................................................. 5.10-12
5.10-2 Local Coastal Program Consistency Analysis ......................................................................................... 5.10-50
5.11-1 Typical Sound Levels in the Environment and Industry ............................................................................ 5.11-2
5.11-2 City of Chula Vista Exterior Property-Line Noise Limits ............................................................................. 5.11-6
5.11-3 Measured Baseline Outdoor Ambient Noise Levels .................................................................................. 5.11-7
5.11-4 Typical Construction Equipment Maximum Noise Levels ......................................................................... 5.11-9
5.11-5 Estimated Distances between Construction Activities and the Nearest Noise-sensitive Receptors ....................................................................................................................... 5.11-10
5.11-6 Predicted Construction Noise Levels per Activity Phase ....................................................................... 5.11-11
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5.12-1 San Diego Region vs. City of Chula Vista Population, Housing, and Employment Forecast .................. 5.12-3
5.12-2 Past Performance RHNA 5th Cycle (2013–2020) .................................................................................... 5.12-4
5.12-3 RHNA Allocation for the 6th Cycle (2021–2029) ...................................................................................... 5.12-5
5.12-4 Employment by Industry in City of Chula Vista .......................................................................................... 5.12-6
5.13-1 Chula Vista Fire Department Locations and Staffing ................................................................................ 5.13-5
5.13-2 Chula Vista School Districts Enrollment History ........................................................................................ 5.13-7
5.14-1 City of Chula Vista Parks and Recreation Resource Categories............................................................... 5.14-3
5.14-2 Summary of Existing Citywide Public Parks and Major Recreation Facilities as of January 2018 ........ 5.14-4
5.14-3 Parks and Recreational Facilities Located within 2 Miles of the Proposed Project Site ........................ 5.14-5
5.15-1 Project Trip Generation ............................................................................................................................ 5.15-12
5.15-2 Project VMT Summary.............................................................................................................................. 5.15-16
APPENDICES
A NOP and Comment Letters
B Specific Plan
C Air Quality and GHG Technical Report
D Biological Resources Report
E Phase I Cultural Resource Survey
F Paleontological Records Search
G1 Geotechnical Investigation Parcel A
G2 Geotechnical Investigation Parcel B
H1 Phase I ESA Parcel A and Land Parcels
H2 Phase I ESA Parcel B
H3 Cleanup and Abatement Order No. R9-2021-0042
I1 Preliminary Drainage Report
I2 Priority Development Project Stormwater Quality Management Plan I3 Updated Drainage Memorandum
J Noise Report
K Local Mobility Analysis
L1 Water Service Analysis
L2 Sewer Service Analysis
L3 Water Supply Assessment
M Mitigation Monitoring and Reporting Program
N Findings
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ACRONYMS AND ABBREVIATIONS
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RESPONSES TO COMMENTS
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RESPONSES TO COMMENTS
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RESPONSES TO COMMENTS
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RESPONSES TO COMMENTS
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RESPONSES TO COMMENTS
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RESPONSES TO COMMENTS
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Response to Comment Letter A1
California Department of Fish and Wildlife
Jessie Lane, Environmental Scientist
October 22 , 2024
A1-1 The comment is an introduction to comments that follow.
A1-2 The comment concerns special-status bats and requests that the DEIR be updated to reflect baseline conditions because mitigation for pallid bat and western mastiff bat are no longer needed since the buildings have already been demolished/renovated. The comment is correct, however, this background was included in the DEIR to ensure that the public has a complete understanding of the project site.
MM-BIO-4 and MM-BIO-5 remain in the Final EIR. No further response is required.
A1-3 The comment suggests that MM-BIO-2 be updated to reflect that the City should coordinate with CDFW if nests are found and that a Scientific Collecting Permit from CDFW would be required for any ne st removal activities. The comment also suggests that MM-BIO-2 be updated to reflect that coordination with USFWS would be required to ensure all protections under the Migratory Bird Treaty Act are adhered to. These two suggestions have been incorporated into MM-BIO-2 in the Final EIR. No further response is required.
A1-4 This comment details an e-mail conversation between CDFW and the City of Chula Vista in which CDFW requested that the DEIR comment period be extended from October 9, 2024 to October 23, 2024. The City agreed and extended the comment period to October 24, 2024. No further response is required.
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Response to Comment Letter A2
Department of Toxic Substances Control
Tamara Purvis, Associate Environmental Planner
October 8 , 2024
A2-1 The comment restates information from the project description of the Draft EIR. The comment does not raise an issue related to the adequacy of the Draft EIR. No further response is required.
A2-2 The comment acknowledges that the City is actively working with the San Diego Regional Water Quality Control Board (SDRWQCB) for remedial actions and concurs that the City should continue working with them to provide the necessary oversight.
The SDRWQCB is the lead agency overseeing environmental investigation and remediation of the Project site under Cleanup and Abatement Order No. R9 -2021-0042 issued on July 12, 2021.
Investigation and remediation activities have been ongoing since the late 1980s. Prior to 2021, these activities were conducted under CAO 98-08 issued April 2, 1998. Information regarding these activities is posted on the State Water Resources Control Board Geotracker website at:
https://geotracker.waterboards.ca.gov/profile report.asp?global id=T10000001489 A2-3 The comment requests per- and poly-fluoroalkyl substances (PFAS) sampling prior to development.
PFAS sampling has already taken place at the Project site. At the request of the SDRWQCB, investigation of the potential presence of PFAS in the uppermost groundwater zones was conducted in 2019 in accordance with U.S. Environmental Protection Agency (USEP A) protocol. Sampling locations were downgradient of manufacturing areas and areas where releases of volatile organic compounds, petroleum hydrocarbons, o r metals were known or suspected to have occurred. Perfluorooctane sulfonic acid (PFOS) and Perfluorooctanoic acid (PFOA) were detected at very low concentrations (less than the USEPA lifetime health advisory of 70 nanograms per liter) and no source of PFA S to the environment was identified. The results of the sampling are documented in the 2020 report titled 2020 Per- and Polyfluoroalkyl Substances (PFAS) Sampling Report – UTC Rohr – North Campus, Chula Vista, which may be found on Geotracker at:
https://documents.geotracker.waterboards.ca.gov/regulators/deliverable documents/4479612052 /PFAS Report Final.pdf .
Based on the 2020 data, annual groundwater monitoring for PFAS has been addressed in Section 2.4.6 “PFAS Sampling” of the April 25, 2024 Site Groundwater and Soil Gas Remedial Alternatives Report and Remedial Action Plan, Rohr, Inc. – a Collins Aerospace Company, North Campus, Chula Vista, California (Groundwater RAP). Parcel B wells where PFAS compounds were previously detected will be sampled and reported as part of the Third Quarter annual groundwater monitoring events. The Groundwater RAP may be found on Geotracker at:
https://documents.geotracker.waterboards.ca.gov/esi/uploads/geo report/9590546846/T100000 01489.PDF.
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. The results of this PFAS investigation are included in the
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report titled Revised Updated Sitewide Conceptual Site Model, UTC Rohr, Inc. – North Campus, which may be found on Geotracker at:
https://documents.geotracker.waterboards.ca.gov/esi/uploads/geo report/9464862287/T100000 01489.PDF No additional sampling for PFAS in soil has been required by the SDRWQCB.
A2-4 The comment concerns soil vapor sampling and contaminated soil and fill materials. Soil vapor sampling has been conducted at the site and vapor intrusion mitigation systems will be installed beneath each building as set forth in the May 17, 2024 Soil and Soil Gas Remedial Alternatives Report and Remedial Action Plan, which may be found on Geotracker at:
https://documents.geotracker.waterboards.ca.gov/esi/uploads/geo report/1560083329/T100000 01489.PDF
The source and historical activities at all locations from which soil and fill materials are proposed for import to the site are evaluated and sampled when necessary following guidance provided in the DTSC Information Advisory Clean Imported Fill Material Fact Sheet. Soil analytical results are compared to USEPA regional screening levels for commercial/industrial site use, as adopted or modified by the DTSC. Documentation of this process is maintained in the project files. The process for evaluating soil is presented in the September 1, 2023 Demolition and Soil Environmental Management Plan, which may be found on Geotracker at:
https://documents.geotracker.waterboards.ca.gov/esi/uploads/geo report/6327364921/T100000 01489.PDF.
A2-5 The comment requests that if additional structures or buildings are to be demolished, then surveys should be conducted to determine the presence of lead-based paints or products, mercury, asbestos-containing materials, and polychlorinated biphenyl caulk. The comment also requests that sampling near current and/or former buildings should be conducted in accordance with DTSC’s PEA Guidance Manual.
If any demolitions are required in the future, required testing would be conducted; however, all former aerospace structures on the site were demolished to facilitate environmental remediation activities being conducted under the oversight of the SDRWQCB. Before demolition, comprehensive building surveys and material testing were performed to evaluate the presence of asbestos-containing material, lead-based paint, and other hazardous materials. Sampling and analytical testing followed regulatory guidance do cuments and regulations. Abatement activities occurred within demarcated, regulated areas, and waste materials were segregated by waste stream for appropriate disposal. Manifests demonstrating disposal of waste classified as hazardous may be accessed at the DTSC Hazardous Waste Tracking System for Generator ID Number CAL000472915.
Substantial subsurface environmental testing and evaluation have been conducted at the Project Site, including areas beneath and around former structures, in alignment with the elements presented in the DTSC PEA Guidance Manual. The SDRWQCB is the lead env ironmental regulatory agency overseeing Site investigation and remediation, with support from the Office of Environmental Health Hazard Assessment (OEHHA), which reviewed and approved the Baseline Human Health Risk Assessment (HHRA). Specific documents addressing DTSC’s PEA Guidance Manual elements include:
Conceptual Site Model, which may be found on Geotracker at:
https://documents.geotracker.waterboards.ca.gov/esi/uploads/geo report/9464862287/T100000 01489.PDF
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Data Gap Investigation Report, which may be found on Geotracker at:
https://documents.geotracker.waterboards.ca.gov/esi/uploads/geo report/1466337978/T100000 01489.PDF
HHRA, which may be found on Geotracker at:
https://documents.geotracker.waterboards.ca.gov/esi/uploads/geo report/7565932869/T100000 01489.PDF
A2-6 The comment provides conclusory remarks. No further response is required.
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Response to Comment Letter A3
Port of San Di ego
Michelle Chan, Program Manager, Development Services
October 4, 2024
A3-1 The comment provides an introduction to the comments that follow and notes that the San Diego Unified Port District (District) had not received formal notification regarding public review for the project. The comment does not raise an issue related to the adequacy of the Draft EIR. No further response is required.
A3-2 The comment identifies the project’s location, expresses unique interest in the development that will occur on the project site, and states that additional comments on the Draft EIR are forthcoming. The comment does not raise an issue related to the adequacy of the Draft EIR. No further response is required. See Response to Comment Letter A6.
A3-3 The comment asserts that the District should be listed as a responsible agency due to its property ownership adjacent to the project site and the potential need for off -site improvements on District - owned property. A responsible agency as defined by CEQA Guidelines Section 21069 “means a public agency, other than the lead agency, which has responsibility for carrying out or approving a project .” There are no approvals required by the District , and there are no off -site improvements required on District-owned property. The project site is under the jurisdiction of the City of Chula Vista. For this reason, the District is not considered a responsible agency. No further response is required.
A3-4 The comment provides conclusory statements and contact information. The comment does not raise an issue related to the adequacy of the Draft EIR. No further response is required.
A3-5 The comment encompasses the District’s NOP comment letter and provides an introduction to the comment letter. The comment does not raise an issue related to the adequacy of the Draft EIR. No further response is required.
A3-6 The comment provides background information on the Chula Vista Bayfront Master Plan (CVBMP) , identifies the proposed project’s location, and summarizes the new zoning designations proposed as part of the project. The comment does not raise an issue related to the adequacy of the Draft EIR. No further response is required.
A3-7 The comment recommends that, given the proximity to the CVBMP , the Draft EIR should include an analysis to evaluate potential conflicts with all scenic-quality-related development policies and design guidelines as stipulated in the CVBMP. The project site is not located within the boundaries of the CVBMP. The project site is subject to the goals and policies of the Chula Vista General Plan, Chula Vista Local Coastal Program (LCP), and the Chula Vista Municipal Code. As stated in Chapter 4, Project Description, Section 4.4.1 Approvals and Amendments, the proposed project would amend the Chula Vista LCP Land Use Plan to reflect the proposed land uses for the project site and would amend the Bayfront Specific Plan to remove the project site entirely. Consistency with the applicable plans has been included in the Draft and Final EIR.
A3-8 The comment states that it’s unclear how different land uses would be assigned to each planning area.
The comment also asks for analysis to ensure the project wouldn’t conflict with the CVBMP policies and
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public access program. Lastly the comment asks for a discussion of how the project will be compatible with development on Parcel H-3.
Regarding how different land uses would be assigned, that would be determined at the time projects are proposed consistent with the Specific Plan. All development proposals within the boundaries of this specific plan shall submit for Design Review Approval, as set forth in the CVMC Section 19.14.582.
Each project shall be evaluated administratively by the City’s Development Services Department for compliance with the terms and intent of this plan, both expressed and implied.” Therefore, projects implemented as part of the specific plan would be required to submit for Design Review Approval and evaluated by the City.
Regarding consistency with the CVBMP, t he project site is not located within the boundaries of the CVBMP. The project site is subject to the goals and policies of the Chula Vista General Plan, Chula Vista Local Coastal Program (LCP), and the Chula Vista Municipal Code. As stated in Chapter 4, P roject Description, Section 4.4.1 Approvals and Amendments, the proposed project would amend the Chula Vista LCP Land Use Plan to reflect the proposed land uses for the project site and would amend the Bayfront Specific Plan to remove the project site entirely. Consistency with the applicable plans has been included in the Draft and Final EIR.
Regarding conflicts with the CDP for the Hotel and Convention Center, the DEIR includes a cumulative impact analysis, Chapter 6, Cumulative Impacts, that includes the hotel and convention center as a cumulative project and an analysis of potential conflicts is included therein.
A3-9 The District expresses appreciation for the opportunity to comment on the Draft EIR and Specific Plan and provides contact information for the commenter. No response is required.
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Response to Comment Letter A4
California Coastal Commission
Melody Lasiter, Coastal Program Analyst
October 15 , 2024
A4-1 The comment provides an introduction to the comments that follow provides a brief summary of the proposed project. The comment does not raise an issue related to the adequacy of the Draft EIR. No further response is required.
A4-2 The comment requests clarification as the project relates to the City’s LUP and the Bayfront Specific Plan. As stated in Chapter 4, Project Description, Section 4.4.1 Approvals and Amendments, the proposed project would amend the Chula Vista LCP Land Use Plan to reflect the proposed land uses for the project site. Section 5.10, Land Use of the Final EIR has been revised to remove the reference regarding the removal of the project site from the Chula Vista LCP. However, as correctly stated in Section 4.4.1, and Section 5.10, the proposed project would amend the Bayfront Specific Plan to remove the project site from the boundaries of the Bayfront Specific Plan.
A4-3 The comment requests the addition of a consistency table with the polices in the City’s LUP. A consistency table with the City’s LUP has been added to Appendix B, Specific Plan.
A4-4 The comment provides conclusory remarks and does not raise an issue related to the adequacy of the Draft EIR. No further response is required.
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Response to Comment Letter A5
Sweetwater Authority
Erik Del Bosque, P.E. , Director of Engineering and Operations December 23 , 2024
A5-1 The comment introduces the comments that follow and provides a summary of the proposed project. The comment does not raise an issue related to the adequacy of the Draft EIR. No further response is required A5-2 The comment suggests that a refined water and fire flow analysis should be conducted in coordination with Authority staff to ensure fire flow demands are met for the project at all times. This comment is noted, and the applicant will work with the Authority to prepare a site -specific water and fire flow analysis as specific developments are proposed.
A5-3 The comment states that the City shall ensure all water improvements are built and operational during the project's initial phase and that all water mains must be sized appropriately and installed within the public Right of Way or Authority easements. All water improvements will be constructed during the initial construction phase and shall be sized appropriately. The project does not propose any offsite water facilities to serve the project.
A5-4 The comment suggests that water facilities within the project site may need to be relocated. All water facilities reside along the perimeter of the project site within Right of Way or an Easement and are not located within areas planned for development.
A5-5 The comment suggests that the developers complete additional hazardous materials analysis on a case-by-case basis to evaluate contaminants of concern. The comment also suggests that the project proponents retain a qualified consultant to recommend proposed pipe materials based on Sweetwater Authority Design Standards and should consider pipe location and the location of hazardous or contaminated materials.
The SDRWQCB is the lead agency overseeing the environmental investigation and remediation of the Project site under Cleanup and Abatement Order No. R9 -2021-0042 issued on July 12, 2021.
Investigation and remediation activities have been ongoing since the late 1980s. Before 2021, these activities were conducted under CAO 98-08 issued April 2, 1998. Information regarding these activities is posted on the State Water Resources Control Board Geotracker website at:
https://geotracker.waterboards.ca.gov/profile report.asp?global id=T10000001489 Thousands of soil samples have been analyzed during site investigation and remediation activities, and chemically impacted soil has been removed to concentrations below risk-based levels approved by the SDRWQCB and the California EPA Office of Environmenta l Health Hazard Assessment. The extent of the cleanup efforts will be documented in an upcoming Soil Remediation Completion Report posted on Geotracker. A Site Management Plan, required by the SDRWQCB, will provide guidance to contractors conducting subsurface work. No additional investigation or data generation is necessary based on the substantial investigation and soil remediation conducted and the guidance provided in a Site Management Plan.
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The type of piping materials used for potential future water mains and underground water supply facilities will be considered relative to the location where they will be installed.
A5-6 The comment provides conclusory remarks and does not raise an issue related to the adequacy of the Draft EIR. No further response is required.
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Response to Comment Letter A6
Port of San Diego
R. Tyson Sohagi, Meyers Nave
March 4, 2025
A6-1 The comment identifies the San Diego Unified Port District s (District) unique interest in the proposed project and future development at the project site. Additionally, the comment refers to the previous comment letter sent from the District, dated October 4 th, 2024, and requests that the District be added as a responsible agency under CEQA and be listed in DEIR Section 1.3 – Project Description under the list of responsible agencies. The comment identifies the District’s anticipation that there may be a need for off-site improvements associated with the Project, i n which case the Project would require discretionary real estate agreement(s) and/or other appropriate permits(s) from the District prior to implementation.
As stated previously in response to the letter dated October 4 th, 2024, a responsible agency as defined by CEQA Guidelines Section 21069 “means a public agency, other than the lead agency, which has responsibility for carrying out or approving a project.” There are no approvals required by the District, and there are no discretionary off-site improvements required on District-owned property.
The project site is under the jurisdiction of the City of Chula Vista. For this reason, the District is not considered a responsible agency. In any event, if District approval is needed for street improvements or installation of subsurface utilities, the City would require coordination with the District. No further response is required.
A6-2 The comment requests the City’s clarification of how the Development Agreement, as amended by the City and Rohr (1999, amended 2011) (collectively, Development Agreement) applies to the proposed project. The comment suggests the purpose of the Development Agreement is to “freeze” designations to implement the consolidation of Rohr facilities from the “South Campus” to the “North Campus” to be thereafter described as the “New Campus.” The City respectfully disagrees with the comment’s characterizations of the Development Agreement. The purpose of any development agreement is, by definition (Government Code §65864 et seq.), vesting (“assurance” of) a right to develop under agreed-upon rules. The right runs with the land and is granted in exchange for benefits to the City. This Development Agreement helps guide development within the entire Bayfront Specific Plan area and thus contemplates a variety of non -industrial uses. As with any agreement, the parties or their successors can amend the Development Agre ement (including the rules being vested) by mutual consent.
An amendment to the Development Agreement was, by oversight, not included in the bullet-point list of entitlements in Section 4.4.1 of the DEIR. That oversight will be corrected in the Final EIR by adding an amendment to the Development Agreement to the bullet-point list. Consistent with the authority of the parties to amend the agreement by mutual consent, the amendment would substitute the Project’s legislative entitlements, such as the amended Bayfront Specific Plan, for the prior rules. This is, for two reasons, not a substantive revision to the DEIR. First, the immediately preceding text in Section 4.4.1 of the DEIR already informed readers that an amendment to the Development Agreement would be approved as part of the Project. Second, revising the Deve lopment Agreement does not reflect an independent Project or physical change to the environment; rather, it amends an additional document to reflect the physical changes (i.e., the Project) already being examined by the DEIR.
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A6-3 The comment requests clarification if any future project(s) would be subject to additional permitting or review requirements in Section 1.4 – Approvals and Amendments of the Draft EIR. Chapter 9-A of the Specific Plan states, “Implementation of the Specific Plan shall conform to Sections 65550 through 65553 of the California Government Code relating to the administration of specific plans and to City of Chula Vista Municipal Code (CVMC) Section 19.07.030. All development proposals within the boundaries of this specific plan shall submit for Design Review Approval, as set forth in the CVMC Section 19.14.582. Each project shall be evaluated administratively by the City’s Development Services Department for compliance with the terms and intent of this plan, both expressed and implied.” Therefore, projects implemented as part of the specific plan would be required to submit for Design Review Approval and evaluated by the City.
A6-4 The comment notes that the Chula Vista resort was demolished in 2022 and therefore should be removed from the DEIR in Section 3.1.1 “Surrounding Land Uses”. The comment additionally requests that the F&G Street Marsh is added to the section, as it is locat ed directly north of the Project site.
These revisions have been made in Errata to the Final EIR.
A6-5 The comment states the definition of the term “project” under CEQA. The comment identifies that Table 4-2 “Proposed Land Uses for Planning Areas” in the DEIR presents land uses in the proposed Planning Areas, acreage and maximum floor ratio for each Planning Areas, square footages of the proposed land uses, and maximum allowable building height for each Planning Areas. The comment suggests that key details, such as proposed site plans, proposed hotel rooms, and construction timelines, are hidden in the DEIR’s technical studies and other sections in the DEIR. The comment requests that these details are included in the Project Description of the DEIR.
As stated in EIR Chapter 4, Project Description, Section 4.4, Project Description, 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. Specific plans are a mechanism to ensure that projects develop in an organized and cohesive manner. Specific plans incorporate a development framework for detailed land use, circulation, infrastructure including drainage, sewer, and water facilities, and u rban design and landscape plans. A comprehensive set of design guidelines and development regulations are included to guide and regulate site planning, landscape, and architectural character within the Specific Plan area ensuring that excellence in design is achieved during project development. The Rohr Wohl Specific Plan establishes the procedures and requirements to approve new development within the Specific Plan area.
Specific details regarding future development in the planning areas were unknown and a Specific Plan was prepared for this reason. Assumptions on site planning, number of hotel rooms, construction timelines, and other specifics were assumed in order to dem onstrate a most impactful scenario. No additional detail has been added to the Project Description.
A6-6 The comment suggests inconsistencies with the site plans included throughout the DEIR and provides examples. The comment states that the site plan for Planning Area B-1 in the Specific Plan, located as Appendix B of the DEIR is inconsistent on pages 16 -17, 48, 50 -51, and page 34. Additionally, the comment states that Appendix K is inconsis tent with the Specific Plan, stating that Figure 1 -2 of Appendix K shows Planning Area B-1 being devoted exclusively to “Office” use, whereas Planning Area B-1 is ide ntified in Appendix K as “Industrial/Business Park w/commercial”. The comment requests that the inconsistencies are eliminated and to clarify which site plans are being proposed.
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rather showcases Chapter 3-C “Key Project Elements” of the Specific Plan. More specifically, Figures 4 through 7 (located on page 16 -17), showcase the four key elements of the Specific Plan which guide land use and design standards for the area. Figures 4 through 7 on page 16-17 of the Specific Plan are titled as follows: Figure 4 - Street Experience ; Figure 5 – Gateways; Figure 6 – Edges; and Figure 7 – Placemaking.
Vista Plan Bicycle and Shuttle Circulation Plan.
Concept. The chapter describes the Specific Plan open space and amenities concepts and provides policies that further include a variety of community areas anticipated in the Specific plan area, along with supporting amenities. Figure 29 through Figure 32 is included on pages 50-51 and are titled as follows: Figure 29 – H Street Frontage Zone; Figure 30 – Main Entrance Zone; Figure 31 – Interior Zone; and Figure 32 – Gateway Zone.
Street Section Key Map is located on page 34.
The Project’s site plan is located on page 4-15 of the DEIR and titled “4-2 Project Site Plan”. The figures identified in the comment are not site plans of Planning Area B -1. Therefore, the site plan is clearly described in the DEIR. The figures identified in the comm ent are not site plans and are specifically described in the Specific Plan. Therefore, the DEIR does not include inconsistencies in this regard. No further comment is required.
Figure 1-2 of Appendix K is titled “Project Site Plan”. This Site Plan identifies “Industrial Building” and includes office spaces within the building.
Table E -1 of Appendix K identifies the land use of Planning Area B -1 as Industrial/Business Park (w/commercial). The site plans are conceptual layouts rather than detailed descriptions of future uses.
Therefore, there are no inconsistencies in this regard. No further response is required.
A6-7 The comment requests that Section 4.4.1 in the DEIR clearly describe the changes to the Development Agreement. See Response to Comment A6 -2. As stated in Response to Comment A6 -2, the Development Agreement would be amended so as to substitute the Project’s entitlements for the prior set of entitlements. It would not change the Project or its physical environmental effects, nor would it
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constitute a new Project. An bullet point was added in the Final EIR to Section 4.4.1 to identify an amendment to the Development Agreement.
A6-8 The comment requests additional information to be included in the DEIR Project Description pertaining to the proposed hotel and restaurant uses in Planning Area B-2, such as location, square footage, and room counts for the future hotel. The comment states that the District is unsure if the proposed Project includes a 254,100 sf 175-room hotel because Table 4-2 of the DEIR identifies a 254,100 sf of hotels, Table E-1, located as Appendix K identifies 175 rooms.
Table 4-2 of the DEIR is titled “Proposed Land Uses for Planning Areas”. In the table, Planning Area B- 2 is designated as Commercial Retail/Commercial Visitor/Commercial Office land uses under the Specific Plan. The table identifies a 254,100 s.f. hotel, and 36,000 s.f. restaurant within this land use.
Table E-1 in Appendix K of the DEIR, is titled “Project Trip Generation”. Table E -1 was created for the Local Mobility Analysis and identifies the Resort hotel as 175 rooms, rather than 254,100 s.f. hotel.
The table utilizes hotel rooms rather than square footage in order to be consistent with conservative standards for trip generation calculations . As stated in the Project Description of the Local Mobility Analysis, included as Appendix K of the DEIR, the programmatic-level analysis would be completed for the uses in Planning Area A and B -2. Due to the uncertainty of the specific uses for Planning Areas A and B-2, the most probable and maximum intensity land uses were assumed for those areas.
Therefore, the Project Description in the DEIR is accurate as is describes the proposed Planning Area B-2 at the programmatic level. Table E-1 identified in Appendix K is not directly related to Table 4-2 of the DEIR and is used for the Local Mobility Analysis.
A6-9 The comment suggests that the DEIR does not clearly describe or analyze the proposed road and intersection improvements discussed in the Local Mobility Analysis (LMA), located as Appendix K of the DEIR. It should be noted that transportation improvements that alleviate traffic congestion are not CEQA considerations; however, the LMA is included as an appendix to the DEIR because City Council has adopted Transportation Study Guidelines that require an analysis of transportation effects as a result of a proposed project. The comment requests that the impacts to the full build-out of the CVBMP and the Gaylord hotel should be clearly described. The comment did not identify a specific potential impact. As described in Table 6-4 of the LMA, the following transportation improvements are proposed to alleviate the project’s effect on traffic congestion:
▪ Retime existing traffic signals at the following locations:
- I-5 northbound ramps/E Street
- I-5 southbound ramps/J Street
- I-5 northbound ramps/J Street
▪ Broadway/J Street
▪ Retime existing traffic signal and restripe the southbound approach at the following location:
- Bay Boulevard/H Street
▪ Contribute on a fair share basis toward traffic signal installation at the following locations:
- Bay Boulevard/J Street (consistent with Chula Vista Bayfront Master Plan EIR Mitigation Measure 4.2-5)
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▪ Contribute a fair share or c onfirm Bay Boulevard/L Street (consistent with Chula Vista Bayfront Master Plan EIR Mitigation Measure 4.2-6) improvement has been fulfilled. ▪ Contribute on a fair share basis toward either traffic signal installation or roundabout construction at the following location:
- Bay Boulevard/F Street (lies outside of the Bayfront Master Plan area) Traffic signal retiming and roadway restriping would involve limited improvements within the existing public right -of-way. Given that the proposed signal installation or roundabout construction improvements are either consistent with the Chula Vista Bayfront Master Plan, or they lie outside of the Master Plan area, future implementation of proposed improvements would have no effect on the buildout of the CVBMP.
A6-10 The comment notes that all legislative amendments, including the Specific Plan, require certification from the Coastal Commission before they can become effective. Therefore, the comment requests that Section 4.4.1 – Approvals and Amendments should be revised to state “when adopted by and certified by Coastal Commission, the Specific Plan would become the zoning for all use within the Specific Plan Area”. The requested edit was not made in the Final EIR. The City would be the entity issuing CDPs for projects in the future and there w ould be no certification or additional act by Coastal Commission.
Notice of non-/appealable developments that do not require a public hearing involving permitted uses shall be provided in the manner prescribed in CVMC 19.83.005. Text has been added to Chapter 9-A of the Specific Plan to clarify the need for future projects to undergo Design Review Approval and obtain a CDP from the City.
A6-11 The comment requests clarification in both the EIR and the Specific Plan, regarding why Coastal Development Permits (CDPs) are required for planning area B-1 but not Planning Area A and B-2. CDPs, which would be issued by the City pursuant to CVMC Section 19.83.001 et seq, would be required for Planning Area A and B -2, but not until a project is proposed. In addition to a CDP, a ll development proposals within the boundaries of the specific plan shall submit for Design Review Approval, as set forth in the CVMC Section 19.14.582. Each project shall be evaluated administratively by the City’s Development Services Department for compliance with the terms and intent of this plan, both expressed and implied.” Therefore, projects implemented as part of the specific plan would be required to submit for Design Review Approval and Obtain a CDP.
Text has been added to Chapter 9-A of the Specific Plan to clarify the need for future projects to undergo Design Review Approval and obtain a CDP from the City.
A6-12 The comment requests clarification on whether the CDP procedures outlined in the Chula Vista Municipal Code Section 19.83.001 et seq are applicable to all development within the Plan’s borders.
See Response to Comment A6-11.
A6-13 The comment requests clarification in the EIR if Planning Area A and Planning Area B-2 will be required to submit for Design Review Approval. Additionally, the comment requests that all of the proposed projects undergo Design Review and that the City add design guidelines to the draft Specific Plan and require a more robust design review process to ensure that the Project has compatible setbacks with adjacent development. See Response to Comment A6-11. In addition, design guidelines are included in the Chapter 8 of the Specific Plan.
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A6-14 The comment recommends, given that the Gaylord Pacific Resort Hotel and Convention Center is in full compliance with the building height, setback and lot coverage requirements as set forth in the Chula Vista Bayfront Development Policies, the Gaylord Pacif ic Resort Hotel and Convention Center will not be blocking the San Diego Bay View from the Project site entirely. The comment suggests that the aesthetics analysis revise the following statement and other associated aesthetics analysis accordingly to consider the impacts of the proposed Project on the views mentioned above: "views to the San Diego Bay are not available from the project site due to Gaylord Pacific Resort Hotel and Convention Center." Based on the visual assessment conducted as part of the Draft EIR, the details regarding views of San Diego Bay from the project site remain unchanged. Although only approximately 0.3 miles to the west, public views to San Diego Bay are not available from the project site; or from nearby mobile vantage points including Bay Boulevard or H Street (see Figure 5.1-1 that shows views of the project site from an adjacent segment of H Street). Also and as demonstrated in the captured westerly view from H Street presented on Figure 5.1-1, views to the San Diego Bay are not available across the Project site due to the presence of the 22-story Gaylord Pacific Resort Hotel and Convention Center (and parking structure) that are located to the south of the Project site and effectively block elements located further south (including the San Diego Bay) from view.
In addition, Table 3 , Development Standards, in the Specific Plan identifies minimum setbacks and heights for future buildings, including a setback of 15 to 20 feet along H Street and a maximum height along H Street of 60 feet.
A6-15 Referring to Table 5.1.-1 Consistency with Aesthetic Related Policies of the General Plan in the DEIR, the comment requests clarification under what circumstances future development would be subject to the City of Chula Vista's design review process. Addit ionally, the comment requests that the design standers from the Chula Vista Bayfront Design Guidelines for Parel H-23 to the list of the surrounding area to review for compatibility. See Response to Comment A6 -11. In addition, d esign standards stipulated in the Chula Vista Bayfront Design Guidelines for Parcel H-23 have not been included in the FEIR. The DEIR demonstrates compliance with policies applicable to the Project site only. There is no development proposed on Parcel H -23 and it would be speculative to assume otherwise (CEQA Guidelines Section 15145, Speculation).
A6-16 The comment requests a key map to indicate the various vantage points of the Visual Simulation photos in Section 5.1 Aesthetics. The requested key map has been prepared and is presented in the FEIR as Figure 5.1-5, Key Views.
A6-17 The comment requests clarification if the Visual simulations provided are based on the draft Specific Plan standards and if they are depicted accurately reflecting the maximum build-out as allowed per the draft Specific Plan. The visual simulations depict a conceptual site plan/layout of permitted uses presenting building mass and heights/scale consistent with the development standards established in the draft specific plan. All proposed development depicted in the visual simul ations is consistent with Table 3, Development Standards Table, of the draft Specific Plan and depict allowable maximum buildout.
A6-18 The comment suggests that the DEIR's biological impact analysis is inadequate under CEQA because it does not analyze the Project’s impacts to the F&G Street Marsh which is approximately 250 feet from the project site. Based on measurements from Google Earth, the F&G Street Marsh is located approximately 310 feet from the nearest property line of the project site. Local Coastal Plan Policy EM.1.E.2 recommends buffer widths of 100 feet from wetlands and the project site is greater than 100 feet from
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the wetlands. In addition, there is an active intervening industrial use between the project site and the F&G Street Marsh which would further reduce potential impacts from occurring due to the proposed project. Also see Response to Comment A6-24 regarding noise impacts at the F&G Street Marsh.
A6-19 The comment requests that a mitigation measure be added to lower noise levels during construction to ensure no impacts occur to hotel guests. As demonstrated in Section 5.11, Noise, the hotel land use adjacent to the project site was taken into consideration when analyzing construction related noise impacts from the project. As presented in Table 5.11-6, the highest estimated construction noise levels are predicted to stay at or below 76 dBA Leq over an 8-hour period at the nearest existing noise-sensitive land use (the hotel under construction approximately 130 feet to the west of the project site) when grading activities take place near the project site boundary. Further, it should be noted that there are no residential uses or sensitive receptors adjacent to the site. As a result, 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. Despite the construction noise analysis above showing that the impact to noise- sensitive receptors would be less than significant, Chapter 4, Project Description provides list of best practices (PDF-Construction Noise) for limiting construction noise that would be implemented by the contractor. No further response is required.
A6-20 The comment states that all construction equipment should be low emission or electric to protect the downwind Environmental Justice communities’ health. As discussed in Section 5.2 Air Quality of the Draft EIR, the project incorporates the use of electric and low emission construction equipment as Mitigation Measure (MM) AQ-3, and MM AQ-4, respectively. The use of electric construction equipment is dependent on the availability of electric hookups. MM AQ -3 requires the project applicant or successor in interest to provide temporary electrical hookups so that equipment such as saws, drills, and compressors are electric-powered versus diesel-powered. In addition, MM AQ-3 prohibits the use of diesel-fueled generators for on-site construction equipment unless the electrical infrastructure is not yet available. Additionally, MM AQ -4 requires the use of Tier 4 equipment for offroad equipment with engines rated at 75 horsepower or greater. Tier 4 equipment achieves up to 90% reduction in particulate matter (PM) and 50-90% reduction in emissions of oxides of nitrogen (NOx) compared to Tier 1 standards (EPA 2016).
A6-21 The comment requests that a mitigation measure be added requiring extensive and proven stormwater controls to be constructed to eliminate any upstream discharges to the Bay, including turbidity or chemicals from the forme r industrial site. The site has undergone extensive remediation and no
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chemicals in soil from the former industrial operations, if any, will not be exposed for surficial discharge into the storm drain system. On -going groundwater remediation will result in the degradation of chemicals in groundwater, and the project design includes engineering controls to prevent groundwater discharge into the Bay via the storm drain system.
The site has undergone extensive remediation and chemicals in soil from the former industrial operations, if any, will not be exposed for surficial discharge into the storm drain system. Groundwater remediation will result in the degradation of chemicals in groundwater. The proposed project is providing engineered controls to prevent groundwater from entering the new storm drain system which could discharge to the Bay. The project will also provide engineered controls to inhibit the pipe bedding material within the storm drain trench from acting as a conduit to transmit groundwater along the trench path These controls inhibit the migration of groundwater via the trenches for storm drain and sewer which are installed below the water table. Specifically, these pipes will be gasketed with water-tight joints. Also, every 300’ will be placed a shallow concrete cut-off wall embedded beyond the trench limits to prevent groundwater from traversing along the trench limits or use of a slurry backfill around the pipe in lieu of a rock and gravel backfill. These measures are required as part of the Groundwater Remedial Action Plan that the Water Board has implemented. No additional mitigation measures are necessary.
A6-22 The comment states that the project should include vehicle charging infrastructure for 75 -100% of visitors due to future state requirements eliminating the sale of gas fueled vehicles. While California is phasing out gas fueled vehicles, requiring 75 -100% of parking spaces to include electric vehicle (EV) chargers is not necessary because the transition to all zero-emission vehicles is gradual, with a target set for 2035, which means there will still be a mix of gas fueled and EVs on the road for some time; and not all parking spaces will be used by EVs at all times. Usage patterns and demand for charging stations can vary, so a lower percentage of chargers might be sufficient to meet the needs of EV drivers.
The project will include EV infrastructure in compliance with Title 24 CALGreen standards. CALGreen includes detailed requirements for non -residential buildings, ensuring that new constructions are equipped to support EV infrastructure. This includes provisions for EV capable spaces, EV ready spaces, and the installation of Level 2 EV supply equipment . By requiring EV capable and EV ready spaces, CALGreen ensures that buildings are prepared for future increases in EV adoption.
A6-23 The comment requests a mitigation measure be added to require nighttime lighting be limited to the property to protect nesting species in the Bay and F&G Street Marsh and to not disrupt migrating birds passing through San Diego Bay along the Pacific Flyway . During the approximate 5-year construction period, activities, including site preparation, grading, building construction, paving, and architectural coating, would generally occur during daylight hour. However, during winter months and assuming construction contractors elect to work beyond sunset and till 7:00 p.m., the use of mobile lighting may be required. During potential future use of lighting during construction, the frequency of nighttime lighting use would be limited, the duration of use would typically be brief, and the location of lighting would be limited to areas of active construction (i.e., illumination of the entirety of the project site and/or individual planning areas would not occur). In addition, lighting would typically be directed downward and shielded so as to not result in unnecessary skyglow or substantial light trespass onto neighboring properties constituting a public nuisance (City of Chula Vista Municipal Code Section 17.28.020) . Further and consistent with the City’s Multiple Species Conservation Program Subarea Plan Agency Management Issues (City of Chula Vista 2003b), the project would implement best management practices to protect preserve lands and sensitive species from con struction night lighting. In addition, the pro ject site
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encompasses industrial lands within the City’s Bayfront Planning Area, and the nearest residential uses are east of the site and east of I-5. Based on the distance from light sources operating on the project site and the proposed frequency and duration of use, temporary lighting during construction would not result in substantial light or glare such that nighttime views in the area would be substantially affected.
Although specific lighting plans and schedules have not been prepared, the project site is likely to support lighting and potential glare sources typical of commercial, industrial, and business park development. For example, site lighting would likely include entry monument and signage at the project site entrance off H Street; parking lot lighting; illuminated b uilding fascia signage on commercial uses/buildings; exterior-mounted lighting on buildings; and lighting in paseos, greenways, courtyards, common areas, and pedestrian paths. Although buildout of the project site is likely to result in an increase in ligh ting sources on the project site compared to the prior industrial warehouse that was recently demolished, new exterior lighting sources would be directed downward and designed to prevent direct glare onto neighboring uses/properties (see PDF-4 in Chapter 4, Project Description) and on more distant refuge lands north and northwest of the project site (i.e., Planning Area B-1). Exterior lighting sources would also generally be shielded so as to minimize the potential for received glare and uplighting/skyglow, and to ensure consistency with the City’s Multiple Species Conservation Program Subarea Plan Agency Management Issues (Lighting) (City of Chula Vista 2003b). All lighting for project site operations would provide adequate shielding to protect preserve lands and sensitive species from night lighting. In addition, lighting sources associated with future development on the project site would operate in a largely developed area consisting of existing industrial warehouses and business park/technology development/structures, and an under -construction, large-scale hotel and adjacent convention center that will include numerous exterior lighting fixtures/sources to support overall site programming and uses.
A6-24 The comment requests a mitigation be added to require all construction equipment to be electric or have reduce noise to less than 60db to avoid noise impacts to species in the Bay and F&G Street Marsh. Table 5.11-3 in the DEIR demonstrates that baseline outdoor ambient noise levels surrounding the project site are already over 60 dBA Leq. However, as discussed in Section 5.2 Air Quality of the Draft EIR, the project incorporates the use of electric construction equipment as Mitigation Measure (MM) AQ -3. The use of electric construction equipment is dependent on the availability of electric hookups. MM AQ -3 requires the project applicant or successor in interest to provide temporary electrical hookups so that equipment such as saws, drills, and compress ors are electric -powered versus diesel-powered. In addition, MM AQ -3 prohibits the use of diesel -fueled generators for on-site construction equipment unless the electrical infrastructure is not yet available.
To address the potential noise impacts to the F&G Street Marsh attributable to proposed project’s construction activities (particularly at Planning Area B -1, which is the closest planning area), two additional short-term (ST) sound pressure level (SPL) mea surements (15-minutes in duration) were conducted (May 2025) to characterize existing ambient noise levels near the F&G Street Marsh, using the same methodology discussed in Section 5.11.1.2 of the DEIR. The image below shows the location of the ST measurements taken on May 16, 2025. At ST-Marsh-West (M-W), the measured 15-min Leq was
56.8 dBA; at ST-Marsh-South (M-S), the measured 15-min Leq was 54.3 dBA. The main observed noise sources in the area included active construction equipment in the area, distant traffic noise, and industrial noise from a nearby boatyard. Additional information regarding noise sources, measured SPL, and field notes/photos can be found in the attached Dudek “iForms” document (RTC Attachment 1).
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Consistent with Project Design Feature (PDF) Noise Best Practices (NBP) -1 disclosed in Section 4.4.5 of the DEIR, and in a manner comparable to the prediction of proposed project construction noise exposure levels at nearby noise -sensitive receptors as dis closed in Section 5.11.3 of the DEIR, a Microsoft Excel–based noise prediction model emulating and using reference data from the Federal Highway Administration (FHWA) Roadway Construction Noise Model (RCNM) was used to estimate aggregate project construction noise levels at the F&G Street Marsh. PDF-NBP-1 states the following:
▪ The project contractor will, to the extent feasible, schedule construction activities to avoid concurrent operation of several pieces of construction equipment proximate to an offsite noise- sensitive receptor.
Additionally, consistent with the Final EIR for the Chula Vista Bayfront Master Plan, construction noise levels at the F&G Street Marsh were compared against the applicable threshold of 60 dBA Leq (1-hour) for wildlife/sensitive species. Thus, one refinement to the construction noise prediction model utilized to furnish the hourly Leq values provided in Section 5.11.3 of the DEIR is a shortening of the evaluation time period from the work shift duration (up to eight hours) to the applicable one -hour period.
Furthermore, consistent with the PDF -NBP-1 provision stated previously, within such a sample hour, the locations of the multiple pieces of construction equipment in a studied activity group or phase are not conservatively bundled together at an idealized common point at its closest distance to the receptor location. Instead, because of the equipment location uncertainty, the loudest piece of equipment for a construction phase is assumed to operate at the nearest position of the construction site boundary to the nearest noise-sensitive receptor, and the rest of the equipment is assumed to operate from the geographic center of the construction site, which serves as the time -averaged location or geographic acoustical centroid of active construction equipment for the phase under study. The acoustical centroid distance is used in a manner similar to the general assessment technique as described in the FTA guidance for construction noise assessment, when the location of individual equipment for a given construction phase is uncertain over some extent of (or the entirety of) the construction site area. Thus, the granularity of location detail described herein attempts to realistically depict an hour -long “snapshot” of onsite construction activity and thus result in a reasonably accurate prediction of aggregate hourly Leq exposure at the F&G Street Marsh, compared against the applicable threshold of 60 dBA Leq (1-hour) for wildlife/sensitive species.
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Google Earth measurements suggest an approximate nearest horizontal distance of 310 feet from the northwestern property boundary to the F&G Street Marsh. However, considering topographical shielding in the construction noise prediction model, a “diagonal” nearest horizontal distance of 385 feet is measured, assuming project construction activities have a clear, direct line-of-sight to the F&G Street Marsh. Additionally, at an approximate acoustical centroid distance of 900 feet, an active intervening indust rial use between the project site and the F&G Street Marsh is included in the prediction model, as such a structure would block direct line-of-sight between project construction and the F&G Street Marsh.
The resulting aggregate construction noise exposure levels at the F&G Street Marsh are as follows:
58.8 dBA Leq(1hr) during Grading activities, 50.9 dBA Leq(1hr) during Building Construction activities, 59.7 dBA L eq(1hr) during Paving activities, and 32.6 dBA L eq(1hr) during Architectural Coating activities.
Compared to the measured outdoor ambient SPL at ST -M-W and ST-M-S, construction noise levels at the F&G Street Marsh could be higher than existing noise levels by 2.9 to 5.4 dBA. The predicted aggregate construction noise levels do not exceed the applicable threshold of 60 dBA Leq(1hr) for wildlife/sensitive species. Detailed construction noise prediction model worksheets are attached (RTC Attachment 2).
A6-25 The comment requests a mitigation measure be added to require the monitoring date for Osprey nests begin November 1st. There is no suitable osprey nesting habitat or structures on site and MM-BIO-2 of the DEIR addresses any potential impacts on nesting Osprey.
A6-26 The comment states that odors from any brewery use will need to be controlled to avoid smells off the property. As discussed in Section 5.2 Air Quality of the Draft EIR under the section “Regulatory Framework” provides information on applicable regulations related to potential odor sources as a nuisance to the public. Specifically, California Health and Safety Code Section 41700 states that a person shall not discharge from any source whatsoever quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or that endanger the comfort, repose, health, or safety of any of those persons or the public, or that cause, or have a natural tendency to cause, injury or damage to business or property. This section
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also applies to sources of objectionable odors. Additionally, San Diego Air Pollution Control District (SDAPCD) Rule 51 Nuisance probits the discharge from any source, of such quantities of air contaminants or other materials that cause or tend to cause injury, detriment, nuisance, annoyance to people and/or the public, or damage to any business or property , which includes odors. Lastly, the City’s municipal code 19.66.090 states that no emission shall be permitted of odorous gases or other odorous matter in such quantities as to be readily detectable within 500 feet from the establishment or use or at the boundary or boundaries of the 500-fooot zone if closer to the establishment or use, or at any point within an adjacent zone. As discussed in Section 5.2.3, in response to checklist question, “Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?”, the project was described as a commercial use that could include a restaurant that would be a source of food odors that would require the use of modern ventilation and odor control systems. While a brewery was not specifically discussed, it would similarly be subject to existing regulations that would prohibit nuisance odors off the property.
A6-27 The comment requests a mitigation measure be added requiring the project to contribute to the CV circular shuttle to reduce VMT. The Chula Vista Community Shuttle is an on-demand service aimed at enhancing local mobility, particularly for seniors, by providing transportation to essential destinations such as healthcare facilities and grocery stores. While this service contributes to reducing VMT by offering an alternative to individual car trips, its primary funding has been sourced from grants like the Clean Mobility Options Pilot Program and contributions from organizations such as the Community Congregational Development Corporation. It is our understanding that the City does not have a formalized VMT mitigation program that allows developers to contribute directly to initiatives like the Community Shuttle to offset their projects' VMT impacts. Moreover, as the DEIR identified no significant transportation (VMT) impact, there is no need to provide mitigation.
A6-28 The comment states that all buildings should be LEED certified to reduce water and energy usage, reduce VOC and (sic increase) planting of native plants. As discussed in Section 5.5 Energy of the Draft EIR, the project would be built to California Title 24 standards, which incorporates Building Energy Efficiency Standards that are designed to ensure that new and existing buildings in California achieve energy efficiency and preserve outdoor and indoor environmental quality . The project would also be subject to t he California Green Building Standards Code (Part 11 of Title 24), which is commonly referred to as California’s Green Building 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 requirements), water conservation, material conservation, and interior air quality. CALGREEN also specifies VOC limits for adhesives, sealants, paints, and coatings (see CALGreen Section 4.504, Pollutant Control).
Both Title 24 and LEED focus on energy efficiency, water conservation, and indoor environmental quality. Some Title 24 measures align with LEED credits, making it easier for California projects to pursue LEED certification, however LEED often exceeds Title 24 requirements in areas like EV charging infrastructure, public transportation access, and use of environmentally friendly materials.
As discussed in Section 5.2 Air Quality, the project would use low VOC paints, which would reduce VOCs and compliance with CALGreen standards would serve to minimize VOCs. VOCs were determined to be less than significant relative to the City thresholds aft er implementation of MM AQ -2, as such no additional mitigation is required. Additionally, PDF -Building Materials and PDF -Interior Finishes serve to accomplish the same goals as LEED certification relative to sustainability in design. As discussed in
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Section 5.5 Energy of the Draft EIR, the project was determined to result in a less than significant impact relative to energy use and PDF -RC-2 would serve to further reduce energy and water demand from the project. Section 5.9 Hydrology and Water Quality, and Section 5.16 Utilities and Service Systems in the Draft EIR found the expected water demand for the project to be less than significant impacts related to ground water and serving capacity. As such, no mitigation measures are required.
PDF-Landscape W ater would maximize water efficiency and incorporate drought tolerant, native, and/or water efficient plantings. Based on the less than significant impacts for air quality, water supply, and energy use, no additional mitigation measures in the form of LEED certification is required.
However, the project’s compliance with increasingly stringent Title 24 regulations and PDF features serves to achieve many of the same goals as LEED
A6-29 The comment requests a mitigation measure be added to require park space to be included in the development to support employees and guests to enjoy the outdoors. Chapter 6 -A Open Space & Amenities Concept describes the Specific Plan open space and amenities concept and provides policies that further that concept, and states “The Specific Plan envisions a diversity of environments cohesively connected with placemaking that relates directly to the proposed land uses and environmental context of each pla nning area. Each area provides an opportunity to support a range of amenities, such as:
terraces/ steps, roof decks, overlooks, plazas, paseos, greenways, boardwalks, courtyards/ patios, buffers & screening. Furthermore, the comment identified no significant impact that would necessitate these actions as mitigation measures.
A6-30 The comment requests, pertaining to the Project Design Features, to delete the word “should” and replace with “will” in order to avoid impacts to the surrounding sensitive receptors such as the F&G Street Marsh and San Diego Bay. The comment emphasizes concern with impacts to exterior lighting, trash collection, native landscaping, control of pests, and energy usage. The word “should” has been revised in the Final EIR to “will” in PDF- Exterior Lighting, and PDF- Landscape Water. No other revisions were necessary.
A6-31 The comment requests that mitigation measures from the CV Bayfront EIR that directly apply to the project be included to avoid impacts to F&G Street Marsh and San Diego Bay including MM4.8 -6, MM4.4-1, MM4.4 -1B, MM4.4 -1D, MM4.4 -2, MM4.5 -2, MM 4.5 -3, MM 4.6 -6, MM4.7 -2, MM4.7 -3, MM4.7-5, MM4.7-8, MM4.7-9, MM4.8-1, MM4.8-2, MM4.8-3, MM4.8-4, MM4.8-5, MM4.8-6, MM4.8- 23, MM4.16 -1. The proposed project does not tier from, nor is it based on, the CV Bayfront EIR; however, consideration was given to the following:
▪ MM4.4-1, MM4.4-1B, MM4.4-1D and MM4.4-2 are related to Aesthetics/Visual Quality. Design Guidelines are included in the Specific Plan and an analysis of i mpacts associated with the proposed project was included in EIR Section 5.1 Aesthetics, and PDFs were included in Chapter 4, Project Description. There are no significant impacts and no mitigation is necessary. ▪ MM4.5-2 and MM4.5-3 are related to Hydrology/Water Quality. An analysis of impacts associated with the proposed project was included in EIR Section 5.9 Hydrology and Water Quality, and PDFs were included in Chapter 4, Project Description. It should also be noted that the site is currently under active remediation p er direction of the RWQCB. There are no significant impacts and no mitigation is necessary.
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▪ MM4.6-6 is related to Air Quality. An analysis of impacts associated with the proposed project was included in EIR Section 5.2, Air Quality, and PDFs were included in Chapter 4, Project Description.
There are no significant impacts and no mitigation is necessary. ▪ MM4.7-2, MM4.7-3, MM4.7-5, MM 4.7-8, and MM4.7 -9 are related to Noise. An analysis of impacts associated with the proposed project was included in EIR Section 5.11, Noise, and PDFs were included in Chapter 4, Project Description. There are no significant impacts and no mitigation is necessary.
▪ MM4.8-1 is related to nesting raptors. MM -BIO-1 of the DEIR sufficiently addresses impacts on nesting raptors. Impacts would be reduced to less than significant and no additional mitigation is necessary.
▪ MM4.8-2 is related to burrowing owls. There is no suitable nesting habitat on site for burrowing owl and MM-BIO-3 of the DEIR sufficiently addresses impacts on nesting birds. Impacts would be reduced to less than significant and no additional mitigation is necessary. ▪ MM4.8-3 is related to nesting birds. MM -BIO-3 of the DEIR sufficiently addresses impacts on nesting birds. Impacts would be reduced to less than significant and no additional mitigation is necessary.
▪ MM4.8-4 is related to light-footed clapper rail. There is no suitable nesting habitat on site for light- footed clapper rail. There are no significant impacts and no mitigation is necessary. ▪ MM4.8-5 is related to MSCP-covered species. There are no vegetation communities on site and no suitable habitat for any MSCP-covered species on the project site. MM-BIO-6 of the DEIR addresses MSCP Subarea Plan consistency. Impacts would be reduced to less than significant and no additional mitigation is necessary.
▪ MM4.8-6A is related to ambient noise levels. See Response to Comment A6-24 regarding ambient noise levels. There are no significant impacts and no mitigation is necessary. ▪ MM4.8-6B and MM4.8-6C are related to nesting raptors. MM-BIO-1 addresses impacts on nesting raptors. Impacts would be reduced to less than significant and no additional mitigation is necessary.
▪ MM4.8-6D and MM-4.8-23 are related to lighting. An analysis of lighting impacts associated with the proposed project was included in EIR Section 5.1 Aesthetics, and PDFs were included in Chapter 4, Project Description. No additional mitigation is necessary. ▪ MM4.8-6E is related to ambient noise levels. See Response to Comment A6-24 regarding ambient noise levels. There are no significant impacts and no mitigation is necessary.. ▪ MM4.16-1 is related to Energy. An analysis of energy impacts associated with the proposed project was included in EIR Section 5.5 Energy, and PDFs were included in Chapter 4, Project Description.
There are no significant impacts and no mitigation is necessary.
A6-32 The comment restates CEQA Guidelines use of qualitative greenhouse gas (GHG) emissions threshold and specifically references sections 15064.4 and 15183.5 and cites the considerations that should be included in an GHG assessment for determining the significance of impacts. The commenter notes that the DEIR relied solely on a qualitative threshold in analyzing the Project’s GHG impacts by evaluating the potential to conflict with the City’s Climate Action Plan (CAP), California Air Resources Board (CARB) Scoping Plans, A ssembly Bill 32 regulatory programs, San Diego Association of Governments (SANDAG) 2021 Regional Plan, and the City’s General Plan. The commenter notes that the DEIR acknowledged that the City’s CAP is not qualified for tiering per CEQA Guidelines 15183.5.
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The commenter suggests that the DEIR’s conclusion that the Project would result in less than significant GHG impacts is not supported by substantial evidence.
The commenter s tates that Table 5.7 -3 in the DEIR indicates the Project would not conflict with transportation demand management strategies in the City’s CAP because the Project would provide bicycle parking and transit passes in accordance with MM AQ -7 but notes that MM AQ-7 addresses trucks requirements and restrictions.
The commenter also notes that CARB’s 2022 Scoping Plan contemplates vehicle miles traveled (VMT) reductions of at least 15% below the regional average and that MM AQ-8 does not incorporate CARB’s recommended VMT reduction goals. The commenter also notes th at the DEIR states that the Project would not conflict with the City’s CAP Transportation Demand Management (TDM) Policy, but MM AQ-8 does not incorporate relevant performance standards for achieving VMT reductions. The commenter recommends that performance standards be added to MM AQ-8 to achieve VMT reductions.
The Draft EIR, Approach to Determining Significance (page 5.7-26) states the following:
“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 DEIR provides information on how the Scoping Plan lays the framework for actions to reduce California’s GHG emissions and the requirements for CARB and other state agencies to adopt regulations to reduce GHG emissions. Guidelines Section 15064.4(a) allows the the City not to use a quantitative approach for this EIR. 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 Ge neral 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. Further, within each section of the DEIR addressing potential conflict with the applicable plans/regulations the DEIR provides additional context into how the plans/regulations reduce GHG emissions. As shown in Table 5.7-3 through 5.7-8 the Project would not conflict with applicable plans and regulations that have been adopted to reduce GHG emissions. As such, the DEIR provides substantial evidence to support a less than significant finding if the Project does not conflict with those adopted plans and regulations.
Regarding the comment that MM AQ-7 addresses trucks requirements and restrictions, and Table 5.7- 3 references this measure to show no conflict with the City’s Smart Growth and Transportation Strategy as it relates to transportation demand management. Table 5.7-3 will be revised to note MM AQ-8 would require bicycle parking and transit passes.
A specific VMT performance metric was not assigned to MM AQ -8 as it was specifically addressing criteria air pollutant emissions but has the co -benefit of also reducing GHG emissions. Notably, in Section 5.15 Transportation of the DEIR, the Project is shown to be in a VMT-efficient area and already
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meets the 15% below the regional average target. The VMT maps used by the City of Chula Vista are based on data and methodologies from SANDAG but are locally developed and adopted; they are not formally approved or certified by SANDAG. As noted as a disclaimer on the City’s VMT Employee Screening Tool, the data represented on the maps follows OPR guidance and displays VMT efficient areas that are 85% or less of the SANDAG regional average. The data shown on the maps is based on the SANDAG Activity-Based Model #2 (ABM2+) for the base year of the model (2016). As such, the Project has a less than significant VMT impact and no further performance standards are required.
A6-33 The comment requests that a mitigation measure be added requiring reduction of dewatering rates when excavating for utilities in order to prevent contaminated groundwater from migrating towards utility excavations. Such a mitigation measure was reportedly employed in other unspecified previous project documents.
In addition, a footnote in the comment indicates that the link on the City’s EIR website to “Appendix H2 - Phase I ESA Parcel B” points to a Geotechnical Investigation Report, not the Phase I report for Parcel B.
Subsurface utilities for the Project will be installed at elevations above the groundwater surface, except for a segment of the stormwater line that will be installed in the western portion of the Project site.
Depending on the means utilized for the installation of this segment, short-term dewatering (on the order of days) may be conducted. This short -term dewatering will capture contaminated groundwater in a localized area near the trench and will not mobilize contaminated groundwater from across the Project site nor exacerbate the overall footprint of the contaminated groundwater plume. As such, no mitigation measure for the project is required. Groundwater removed from the trench will be appropriately treated and discharged under City of Chula Vista and San Diego Industrial Wastewater Control Program permits to the sewer.
A6-34 The comment requests that, in Section 5.10.1.3 Surrounding Land Uses, to remove “Chula Vista RV Resort” as it was demolished in 2022, and to add “F&G Street Marsh”. These edits have been made in the Errata to the Final EIR.
A6-35 The comment requests that the DEIR include a rationale why the 2002 SANDAG Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region was used instead of trip generation rates in the 2010 SANDAG Trip Generation Rate for Smart Growth. The comment states that applying the 2010 trip rates would increase the trips analyzed in the DEIR by 25 percent. The comment suggests that the DEIR is underestimating impacts to transportation by not using the 2010 Guide trip generation rates for hotels.
The comment additionally requests the DEIR add a transportation analysis for the proposed retail use.
The City’s Transportation Study Guidelines states that the current version of SANDAG’s (Not So) Brief Guide of Vehicle Traffic Generation Rates for the San Diego Region should be used. The 2010 report references in this comment is labeled as a DRAFT document in the footer and it is not represented as an alternative source of traffic generation rates. Instead, as noted on page 2, the “results of the study are intended to provide a richer, more accurate accounting of vehicle trip reduction associated with mixed-use and transit-oriented development (TOD) in smart growth environments, compared to current local and national methods of calculating trip generation. This information is intended to supplement data in the San Diego Traffic Generators Manual , published by SANDAG in 2000, and the accompanying Not-so-Brief-Guide to Trip Generation, published by SANDAG in 2002.” The referenced hotel traffic generation rate of 10 daily trips per room comes from SANDAG’s (Not So) Brief Guide of Vehicle Traffic Generation Rates for the San Diego Region for hotels (with convention
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facilities/restaurant); the SANDAG rate for resort hotels is 8 trips per day per room; there is no conflict between these rates.
Given that no specific hotel project has been proposed at this time, the trip generation rate selected 10 daily trips per room corresponds to the “Hotel with Restaurant and Convention Facilities” land use category in the 2002 SANDAG Guide. This rate was intentionally used toas a conservative estimate to capture the potential for increased trip activity associated with accessory uses such as restaurants or meeting space, which are commonly included in full -service hotels. By using this higher rate, the analysis also inherently accounts for trips to be generated by a future on -site retail or restaurant component, even though such a component is not yet fully defined in the project description.
This conservative approach ensures that any ancillary uses that may accompany the hotel in the futur e would not result in unaccounted-for trip generation or unanticipated impacts on the surrounding roadway network. It also avoids the need to rely on speculative assumptions about the specific mix of hotel-supporting amenities.
A6-36 The comment states that an EIR must consider all phases of a project when evaluating its impact on the environment, including, planning, acquisition, development, and operation. The comment defines “environment” as defined by CEQA. The comment requests tha t an analysis is added of the environmental impacts resulting from the proposed road and intersection improvements and the development projects that would be constructed within the proposed Planning Areas A and B-2. At this time, no specific development projects have been identified for Planning Areas A and B-2. As such, the analysis in the LMA is based on estimated trip generation assumptions for potential future development in these areas. As shown in Table 7-1 of the LMA, the assumed land uses in Planning Areas A and B-2 consist of the following:
▪ 198,000 square feet of industrial business park (with commercial) ▪ A 175-room resort hotel
▪ 36,000 square feet of quality restaurant
As discussed above in the response to comment A6 -9, the proposed transportation improvements would have no effect on land uses within the CVBMP. All of proposed transportation improvements, such as new traffic signals, w ould be constructed on already disturbed (and typically built -on) land.
Furthermore, none are in a location that would create a potential hazard to the public or the environment. After construction, the improvements would improve traffic flow and reduce traffic delays and queues, as compared to the no-project condition. Accordingly, the proposed improvements are not expected to have any adverse effect on traffic hazards, air quality, noise, or GHG. Consequently, none of the work is anticipated to create environmental impacts.
A6-37 The comment acknowledges the Local Mobility Analysis, included as Appendix K of the DEIR. The comment requests that the DEIR describe the scope of the proposed road and intersection improvements including whether the improvements discussed in the Local Mobility Analysis are being considered and if so, to analyze implementation of the analysis. At this time, no specific development projects have been identified for Planning Areas A and B-2. As such, the analysis in the EIR is based on estimated trip ge neration assumptions for potential future development in these areas. These
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estimates were developed in coordination with City staff and are consistent with the City’s adopted land use and transportation planning framework.
Furthermore, in order to provide more flexibility for the development within Planning Areas A and B -2 or the potential to accommodate at least a partial development of Planning Areas A and B-2 before the completion of the Year 2050 roadway network, an Existing Plus Total Project (Planning Areas B-1 Plus Planning Areas A & B-2) were evaluated (Chapter 8 of LMA). Improvements were identified in Table 8-
4. The scope of the proposed improvements is summarized in the response to comment A6 -9 above and discussed in additional detail in the LMA. Construction of any proposed improvements will require approval from the permitting agency and traffic control plans will be implemented to manage traffic during construction. After construction, the improvements would improve traffic flow and reduce traffic delays and queues, as compared to the no-project condition. Accordingly, the proposed improvements are not expected to have any adverse effect on traffic hazards, air quality, noise, or GHG.
A6-38 The comment acknowledges that the DEIR states that the improvements as identified in the Local Mobility Analysis are recommendations only and the final improvement plan and funding responsibility will be defined and documented in a separate Rohr/Wohl Transportation Conditions of Approval memo.
The comment requests coordination with the District to ensure the final improvement plan does not conflict with the traffic mitigation measures and road improvements as identified in the CVMP FEIR.
Prior to finalizing any improvements, the City will coordinate with the District as a matter of standard practice and regulatory compliance to ensure that the final improvement plan does not conflict with the traffic mitigation measures/road improvements as identified in the CVBMP FEIR.
A6-39 The comment acknowledges that the DEIR states that the Planning Area B-1 is analyzed at the project- level and Planning Areas A and B -2 are analyzed at the programmatic level. The comment suggests that the City conduct a project-level CEQA analysis for Planning Areas A and B-2 before the City approves any specific development projects in Planning Area A or B -2. Additionally, the comment requests the District be notified when the CEQA analysis is available.
Future projects implemented as part of Planning Areas A and B-2 will be required to submit for approval and administr ative review process, as described in Chapter 9 -A “Approvals” and Chapter 9 -C “Administration and Review Process”. Future projects implemented as part of the Specific Plan will not undergo additional CEQA analysis , unless proposed plans are substantially different than what was assumed in the EIR and Specific Plan. In such cases, additional analysis would be required per CEQA Guidelines Section 15162. The comment does not address inadequacies with the DEIR. No further comment is required.
A6-40 The commenter states that Mitigation Measure AQ-8 Transportation Demand Management was relied on to reduce the Project’s significant air quality and cancer risk impacts and requests that specific performance standards be included specifically to reduce VMT either 15 percent below the regional average or to no net increase in VMT. The commenter notes that the DEIR Section 5.7 Greenhouse Gas Emissions acknowledged the importance of the 15% VMT reduction goal.
Mitigation Measure AQ -8, Transportation Demand Management was not relied on to reduce the project’s air quality and cancer risk impacts but was rather included as a best practice measure for this type of land use. Regarding MM AQ-8 the Errata for the Final EIR will include a note to clarify that no reductions in emissions are taken from the measure.
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The VMT maps used by the City of Chula Vista are based on data and methodologies from SANDAG but are locally developed and adopted; they are not formally approved or certified by SANDAG. As noted in Section
5.15 Transportation of the DEIR, the Project is shown to be in a VMT-efficient area and already meets the 15% below the regional average target. As such, the Project has a less than significant VMT impact and no further performance standards are required
A6-41 The comment requests a correction to Figure 5.15-5 “VMT Screening Map for Project”, stating “please correct that location of the Project site, which is west of the trolley line.” Figure 5.15-5 has been revised in the Final EIR to reflect the correct location of the project site.
A6-42 The comment suggests that in Section 6.3 Cumulative Projects of the DEIR, several cumulative projects are missing from Table 6-3 (Cumulative Projects). The comment requests the EIR be revised to correctly identify and analyze all cumulative projects. The comment requests that Table 6-1 Cumulative Projects revises “Project 2 – Sun Communities RV Park, Phase II (two), 90 spaces” to “Project 2 – Sun Communities RV Park, Phase I (one), 246 spaces.”
Section 6.3 “Cumulative Projects” of the DEIR identifies a list of cumulative projects that was generated at the time the NOP was prepared for the project, consistent with CEQA Guidelines. Phase I of the Sun Communities RV Park (246 spaces) opened in May 2021, as such, and traffic associated with that project was captured in the existing traffic volumes, which were collected in January 2023 – approximately 1.5 years after the RV Park began operations. Phase II of the Sun Communities RV Park (90 spaces), which was identified in Table 6-3 as one of the cumulative projects, was included based on best available information at the time, although this project may have been withdrawn as of May 2024. Nonetheless, traffic from Phase II was conservatively accounted for in the project’s cumulative analysis. No revisions to the Final EIR were made.
A6-43 The comment requests to add Harbor Park and Sweetwater Park to the cumulative projects list in Table 6-1 Cumulative Projects of the DEIR , as they are located within the cumulative project boundary as shown in Figure 6-1 of the DEIR.
Figure 6-1 of the DEIR is titled “Cumulative Projects”. The figure provides a legend and visual map of the cumulative projects identified in Table 6-1 of the DEIR. The figure does not include a boundary line for cumulative projects. Section 6.3 “Cumulative Projects” of the DEIR identifies a list of cumulative projects that was generated at the time the NOP was prepared for the project, consistent with CEQA Guidelines.
Although Harbor Park and Sweetwater Park were not explicitly listed as cumulative projects, they do not represent a cumulative impact in the context of the traffic analysis. This is because they effectively replace the previously considered Sun Communities RV Park, Phase II, which was removed from the cumulative project list after the Notice of Preparation (NOP) was issued.
Harbor Park and Sweetwater Park are each assumed to be 18 acres in size. City parks, which typically include amenities such as playgrounds and walking paths, generally range from 5 to 40 acres and fall within this category. In contrast, regional parks range from 200 to 500 acres and provide larger-scale facilities.
Based on their size and features, Harbor and Sweetwater Parks are classified as City parks and assigned a trip generation rate of 20 trips per acre. Using guidance from the City of San Diego Trip Generation Manual, it is estimated that 4% of daily trips occur during the AM peak hour and 8% during
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the PM peak hour. This results in an estimated 720 daily trips, with 29 trips during the AM peak hour and 58 during the PM peak hour.
For comparison, the previously analyzed Sun Communities RV Park, Phase II was estimated to generate 450 daily trips, with 36 AM peak-hour trips and 50 PM peak-hour trips.
Although the parks generate a higher number of daily trips, the estimated number of trips during the critical weekday peak periods—the focus of the traffic analysis—remains comparable. Even accounting for a potential overestimate in park trip generation (as portions of the parks may have already existed when traffic counts were collected), the net increase in peak-hour trips is minor. Importantly, this slight increase does not change the previously identified Levels of Service (LOS) at the study area intersections, nor does it introduce any new operational deficiencies.
These two parks were not added to the cumulative list or cumulative figure in the Final EIR.
A6-44 The comment requests to add future Parcel H-23 development to the list of cumulative projects in Table 6-1 Cumulative Projects of the DEIR. The comment states that Parcel H -23 allows for “a hotel with portion of allowed 2,850 rooms in Harbor District, associated conference room, retail, and ancillary uses, along with up to 200,000 square feet of cultural/retail uses and integrated open space, maximum heights are limited to 300 feet for hotel and 65 feet for the cultural/retail uses.” While those are allowed uses on Parcel H -23 there is no development or project proposed on Parcel H -23 and it would be speculative to assume otherwise (CEQA Guidelines Section 15145, Speculation).
A6-45 The comment requests the DEIR include alternatives that were rejected due to infeasibility by the Lead Agency. The DEIR analyzed the No Project Alternative, Build to Existing Land Use Designations Alternative, Exclusion of Hotel in Planning Area B -2 Alternative, and Exclusion of All Planning Area B - 2 Alternative. All alternatives analyzed in the DEIR were conside red feasible under CEQA Guidelines and therefore, the DIER does not include alternatives anticipated to be infeasible.
A6-46 The comment cites Lotus V Dept. of Transportation (2014) 223 Cal. App.4 th 645) regarding project design features that are not part of the project from inception and tied to existing regulatory requirements being considered mitigation measures. The comment notes that the DEIR relied on several PDFs in analyzing the Project’s environmental impacts but does not analyze the impact without the PDFs. The comment cites Mission Bay Alliance v. Office of Cmty. Inv. & Infrastructure (2016) 6 Cal.App.5th 160, 185 and People ex rel. Bonta v Cnty of Lake (2024) 105 Cal.App.5th 1222, 1235) for discussing a project’s impact with and without PDFs included as conditions of approval. The comment also notes that some of the PDFs are not included in the DEIR, proposed Specific Plan, or Notice of Preparation and cites the DEIR’s refere nce to PDF AQ -1 on page 5.2 -37 that states the measure is described in DEIR Chapter 4 Project Description, but is not and requests a description of this measure be added to the DEIR. The commenter also states that these PDFs are relied upon in the impact analysis and the impacts with and without the AQ PDF should be disclosed. The commenter makes a similar request with respect to PDFs GHG-1 and GHG-2 and claims they are relied upon in the energy and GHG impact analysis. The comment noted a similar issue with a reference to PDF -6 in the hazards and hazardous materials impact section and requests a description of this measure be added to the DEIR.
PDF AQ -1 is referenced in the Air Quality and Greenhouse Gas Technical Report and provided as Appendix C of the DEIR, as such it was described in the DEIR. This measure was renamed in Chapter
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4, Project Description of the DEIR to PDF Site Management (SM) -1. Section 5.2 Air Quality will include a clarification to note the correct name of the PDF. In addition, Table 5.2-17 provided the estimated air quality emissions without incorporating PDF SM-1, the footnote at the bottom of the table will be revised to note the measure was not included in the “unmitigated” estimate. Accordingly, the DEIR did present the Project’s emissions without (Table 5.2-17) and with PDFs and mitigation measures (Table 5.2-23).
PDF GHG-1 and PDF GHG-2 are referenced in the Air Quality and Greenhouse Gas Technical Report and provided as Appendix C of the DEIR, as such they were described in the DEIR. These measures were renamed in Chapter 4, Project Description of the DEIR to PDF- Regulation Compliance (RC)-1 and PDF- RC-2, respectively. The Project’s PDF measures related to GHGs RC-1 and RC-2 were not relied upon to reduce GHG emissions.
Regarding energy impact analysis, the commenter erroneously states that GHG PDFs were relied upon to conclude a less than significant impact. As discussed in Section 5.5 Energy of the DEIR, the Project would comply with Title 24 standards and implementation of PDF GHG-2 (renamed PDF-RC-2 in Chapter 4 Project Description of the DEIR) would further ensure that the energy demands would not be inefficient, waste, or otherwise unnecessary. The reference to PDF-RC-2 will be clarified in the errata.
PDF-6 in the hazards and hazardous materials was renamed in the DEIR Chapter 4 Project Description to PDF-Building Materials, as such the measure was described, however the clarification of the name will be provided in the errata. As Section 4.4.5 of the DEIR states, all Project Design Features are part of the Project. To ensure that they will be implemented, the City will in its ordinary course require that development complies with them by imposing them as conditions on entitlements.
A6-47 The comment refers to Chapter 8-C Circulation and Parking of the Draft Rohr/Wohl Specific Plan which is included as Appendix B of the DEIR. The comment states that the draft Specific Plan does not specify the required parking spaces for all the uses in the proposed Specific Plan. The comment requests that Specific Plan clarify parking requirements in order to avoid parking issues in the surrounding areas.
The specific plan does not provide parking regulations. Parking will be regulated by ChulaVista Municipal Code standards. Where the regulations of the specific plan are silent, the comparable regulations of the city zoning ordinance, and all adopted ordinances, regulations, standards, and guidelines of the City of Chula Vista shall prevail, as deemed appropriate by the Planning Director. See Section 4-B.
A6-48 The comment refers to Chapter 8-H Signage of the Draft Rohr/Wohl Specific Plan, which is included as Appendix B of the DEIR. The comment requests clarification of the location of the proposed Gateways sign(s). The comment states that as required pursuant to mitigation measures 4.4-1F in the Chula Vista Bayfront Master Plan Project Final Environmental Impact Report, a Gateway Monument Plan for E, H and J Street was approved by both the Port of San Diego and City of Chula Vista in March 2021.
All signage regulations and guidelines in the RWSP pertain to private signs on private property only and are not intended to replace or obstruct Chula Vista Bayfront signage contemplated in the Gateway Monument Plan for E, H, and J Street. Gateway signage shall be located at major intersections/ entrances to the development and limited to a maximum copy area of 100 square feet and a maximum height of eight feet per Section 8-H (5)
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A6-49 The comment requests that the DEIR include an analysis whether there are any inconsistencies between the Project and the California Coastal Commission’s 2024 Sea Level Rise Policy Guidance.
The comment acknowledges that the Project involves the amendment to the City’s Local Coastal Program (LCP). The comment states that the California Coastal Commission’s Sea Level Rive Policy Guidance advises that a local agency amending its LCP identify, ba sed on best available science and various sea level rise scenarios, physical hazards, and impacts associated with current and future sea level rise impacts. Additionally, the comment states that the agency should develop sea level rise adaptation strategies considering physical hazards and impacts identified. The comment suggests that the proposed DEIR and draft Specific Plan does not address physical hazards or impacts resulting from current and future seal level rise or sea level rise adaptation strategie s. The comment requests that the City revise the proposed Specific Plan to identify an discuss, based on Sea Level Rise Policy Guidance, physical hazards and impacts and associated with current and future sea level rise impacts and sea level rise adaptation strategies.
The California Coastal Commission’s 2024 Sea Level Rise Policy Guidance (Update) document, which identifies itself as guidance rather than regulation, was released after the project’s NOP was circulated, and after the project’s EIR was circulated for public review. However, the project relied upon the Coastal Commission Guidance for “Sea Level Adaptation Strategy for San Diego Bay”. Site design adjustments were made based on this document, and the “Medium-High Risk Scenario” for the year 2050 , which predicted 2.0 feet of sea level rise.
For this reason, the site’s minimum finished floor elevation was raised by approximately 1.9 feet to account for potential sea level rise. This would result in the finished floor elevation of the buildings to be greater than an elevation of 12.5 feet based on the NACD88 vertical datum. This information has been added to the Specific Plan Chapter 2-I, Sea Level Rise.
A6-50 Additionally, the comment requests the District be added as an interested parties list for the Project, including future development. The District has been added to the list of interested parties. No further response is required.
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INTENTIONALLY LEFT BLANK
Attachment 1
Field Noise Measurements
Temp (F) 60
Humidity % (R.H.) 82
Wind Calm
Wind Speed (MPH) 2
Wind Direction West
Sky Overcast
Instrument and Calibrator Information
Instrument Name List (SAC) NL-62
Instrument Name (SAC) NL-62
Instrument Name Lookup Key (SAC) NL-62
Manufacturer Rion
Model NL-62
Serial Number 350815
Calibration Date
Calibrator Name (SAC) Rion NC-74
Calibrator Name (SAC) Rion NC-74
Calibrator Name Lookup Key (SAC) Rion NC-74
Calibrator Manufacturer Rion
Calibrator Model NC-74
Calibrator Serial # 34167529
Pre-Test (dBA SPL) 94
Post-Test (dBA SPL) 94
Windscreen Yes
Weighting? A-WTD
Slow/Fast? Slow
ANSI? Yes
Monitoring
Record # 1
Site ID ST-Marsh-South
Site Location Lat/Long 32.630971, -117.103242
Begin (Time) 09:53:00
End (Time) 10:08:00
Leq 54.3
Lmax 56.3
Lmin 52.4
Other Lx? L90, L50, L10
L90 52.9
L50 54
L10 55.7
Other Lx (Specify Metric) L
Primary Noise Source Industrial
Other Noise Sources (Background) Birds, Distant Aircraft, Distant Traffic Other Noise Sources Additional Description Active construction equipment (excavator, forklift) in area, distant traffic, noise from boatyard Is the same instrument and calibrator being
used as previously noted?
Yes
Begin (Time) 10:12:00
End (Time) 10:27:00
Leq 56.8
Lmax 60.1
Lmin 54.5
Other Lx? L90, L50, L10
L90 55.1
L50 56.4
L10 57.8
Other Lx (Specify Metric) L
Primary Noise Source Industrial
Other Noise Sources (Background) Birds, Distant Aircraft, Distant Industrial, Distant Traffic Other Noise Sources Additional Description Boatyard activity (spraying, engine noise/rumbling), distant equipment back-up horns, traffic Is the same instrument and calibrator being
used as previously noted?
Yes
Are the meteorological conditions the same as
previously noted?
Yes
Description / Photos
Terrain Mixed
Attachment 2
Marsh Construction Modeling
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Errata
The changes reflected in this errata are presented in strike-through and underline revisions to the Rohr Wohl Specific Plan Project EIR The revisions to the EIR reflected in this errata do not affect the adequacy of the previous environmental analysis contained in the EIR.
Chapter 2, Introduction
Section 2.4, Environmental Procedures
Section 2.4.1, CEQA Compliance
The California Public Resources Code (Section 21000 et seq.) requires the preparation and certification of an EIR for any project that a lead agency determines may have a significant effect on the environment. This EIR has been prepared in compliance with all criteria, standards, and procedures of the CEQA Guidelines (14 CCR Section 15000 et seq.).
In the event that future projects , or uses, are proposed on the project site , consistent with the Specific Plan, for which environmen tal impacts m ight exceed the impacts disclosed throughout this EIR, additional CEQA documentation would be required.
Section 2.6, Organization and Content of the EIR
▪ Appendices include various technical studies and correspondence prepared for the project, as listed below and in the table of contents:
- A: NOP and Comment Letters
- B: Specific Plan
- C: Air Quality and GHG Report
- D: Biological Resources Report
- E: Phase I Cultural Resources Survey
- F: Paleontological Resources Records Search
- G1: Geotechnical Investigation Parcel A
- G2: Geotechnical Investigation Parcel B
- H1: Phase 1 ESA Parcel A
- H2: Phase 1 ESA Parcel B
- H3: Cleanup and Abatement Order No. R9-2021-0042
- I1: Preliminary Drainage Report
- I2: Priority Development Project Stormwater Quality Management Plan - I3: Updated Drainage Memorandum
- J: Noise Report
ERRATA
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- K: Local Mobility Analysis
- L1: Water Service Analysis
- L2: Sewer Service Analysis
- L3: Water Supply Assessment
- M: Mitigation Monitoring and Reporting Program
- N: Findings
Chapter 3, Environmental Setting
Section 3.1.1, 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 nterstate 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.
Chapter 4, Project Description
Section 4.4.1, Amendments and Approvals
Approval of the proposed project would require the adoption of a General Plan Amendment and a new Specific Plan; amendment of the Development Agreement by and between the City of Chula Vista, the Redevelopment Agency of the City of Chula Vista, and Rohr, Inc., dated December 30, 1999, as amended; certification of the EIR; adoption of CEQA Findings and Statement of Overriding Considerations; and adoption of a mitigation monitoring and reporting program (MMRP).
The documents to be amended are as follows:
▪ Amendment to the Development Agreement (1999, amended 2011) ▪ Chula Vista General Plan (City of Chula Vista 2005)
▪ Chula Vista Local Coastal Program
- Bayfront Local Coastal Program Land Use Plan (City of Chula Vista 2013) - Bayfront Specific Plan (City of Chula Vista 2018)
▪ Chula Vista Municipal Code Chapter 19
- Section 19.81: Bayfront Specific Plan – Scope and Purpose - Section 19.84: Bayfront Specific Plan – Land Use Zones - Section 19.85: Bayfront Specific Plan – Development Criteria Section 4.4.3.2, Drainage and Stormwater Facilities
On-site runoff is collected and transported by concrete gutters into storm drains located along the western property line of Planning Areas B -1 and B -2. These private storm drains will continue to discharge to existing outfall connections connect to large-diameter City storm drains located at the southwest and northwest corners of Planning ERRATA
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Areas B-1 and B -2. Planning Area A drains as overland flow into an existing ditch along its western property line before entering the City’s public storm drain system along H Street.
Section 4.4.5, Project Design Features
Greenhouse Gas Project Design Features
PDF-RC-1 Operational Mobile Source Emissions Reductions Measures. The project shall implement the following measures.
▪ Legible, durable, weather-proof signs shall be placed at truck access gates, loading docks, and truck parking areas that identify applicable California Air Resources Board (CARB) anti -idling regulations. At a minimum, each sign shall include: (1) instructions for truck drivers to shut off engines when not in use; (2) instructions for drivers of diesel trucks to restrict idling to no more than 5 minutes once the vehicle is stopped, the transmission is set to “neutral” or “park,” and the parking brake is enga ged; and (3) telephone numbers of the building facilities manager and CARB to report violations. Prior to the issuance of an occupancy permit, the City of Chula Vista shall conduct a site inspection to ensure that the signs are in place. ▪ Tenants shall train managers and employees on efficient scheduling and load management to eliminate unnecessary queuing and idling of trucks. Staff in charge of keeping vehicle records shall be trained in diesel technologies and compliance with CARB regulations by attending CARB- approved courses as well as maintaining on-site records demonstrating compliance. ▪ Leasing preference shall be given to prospective tenants with a facility -owned and operated fleet that is alternative/zero-emissions.
▪ Prior to tenant occupancy, the developer or successor(s) in interest shall provide documentation to the City of Chula Vista demonstrating that occupants/tenants of the Project site have been provided documentation on funding opportunities, such as the Carl Moyer Program, that provide incentives for using cleaner-than-required engines and equipment. ▪ The minimum number of automobile electric vehicle (EV) charging stations required by the California Code of Regulations Title 24 shall be provided prior to issuance of a Certificate of Occupancy. In addition, the buildings shall include electrical infrastructure sufficiently sized to accommodate the potential installation of additional automobile EV charging stations in the future. Electrical infrastructure shall be provided such that EV charging s tations can be installed on 20% of the Project’s total autom obile parking spaces. Buildings with over 200 parking spaces shall include an electrical system and other infrastructure sufficiently -sized oversize electrical rooms by 25 percent or by providing a secondary electrical room to accommodate future expansion of electric vehicle charging capability to accommodate the potential expanded installation of EV charging stations in the future. The electrical system and infrastructure must be clearly labeled with noticeable and permanent signage which informs future occupants/owners of the existence of this infrastructure. ▪ Tenants shall be in, and monitor compliance with, all current air quality regulations for on-road trucks including CARB’s Heavy -Duty (Tractor -Trailer) Greenhouse Gas Regulation, Periodic Smoke Inspection Program, and the Statewide Truck and Bus Regulation.
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PDF-RC-2 Operational Energy Source Emissions Reductions Measures. The Project shall implement the following measures.
▪ The project shall be designed such that all buildings with occupied rooms shall have some form of daylighting (e.g. skylights or windows) each building features skylights that cover a minimum of 3% of the total roof area of the Project.
▪ Photovoltaic infrastructure shall be provided on the rooftops of project buildings in accordance with the proposed land use. Industrial/warehouse buildings shall provide a minimum 3% of the total roof area for photovoltaic arrays at building construction. All other proposed land uses shall provide a minimum 1 0% of the total roof area for photovoltaic arrays at building construction. such that a minimum of 25% of the total roof area of the project includes photovoltaic arrays at Project buildout. Project buildings shall include an electrical system and other infrastructure sufficiently sized to accommodate the potential installa tion photovoltaic arrays in the future up to 50% of the total roof area of the project. The electrical system and infrastructure must be clearly labeled with noticeable and permanent signage which informs future occupants/owners of the existence of this infrastructure. ▪ Project building plans shall specify that all fixtures installed in restrooms and employee break areas shall be U.S. Environmental Protection Agency (EPA) Certified WaterSense or equivalent. ▪ Project building plans shall specify that all heating, cooling, lighting, and appliance fixtures installed be Energy Star -rated. Information on energy efficiency, energy -efficient lighting and lighting control systems, energy management, and existing energy incentive programs shall be provided to future tenants of the project.
▪ Prior to the issuance of permits that would allow the installation of landscaping, the City of Chula Vista shall review and approve landscaping plans for the site that require: (1) a plant palette emphasizing drought -tolerant plants; (2) use of water -efficient irrigation techniques; and (3) sufficient shade trees are provided so that at least 30% of the automobile parking areas will be shaded within 15 years after project construction is complete (excluding the truck courts where trees cannot be planted due to interference with truck maneuvering). The City of Chula Vista shall inspect for adherence to these requirements after landscaping installation. ▪ Structures shall be equipped with outdoor electric outlets in the front and rear of the structures to facilitate use of electrical lawn and garden equipment.
General Project Design Features
▪ PDF-Exterior Lighting: Exterior lighting should will be directed and designed to prevent direct glare into adjacent dwelling units and onto neighboring uses/ properties. ▪ PDF- Landscape Water: To maximize water efficiency, new landscape designs should will 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 California-friendly plants, shrubs and trees is also encouraged.
Section 5.1, Aesthetics
Figure 5.1-1, Key Views – Figure 5.1-1 has been added to the Final EIR and is attached to this Errata.
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Section 5.2, Air Quality
Section 5.2.1.2, Regulatory Framework
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, public facilities and services, safety element growth management, 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). The policies for improving air quality in the General Plan are as follows:
Section 5.2.3, Impacts
Construction
Development of the project would generate air pollutant emissions from entrained dust, off-road equipment, vehicle emissions, asphalt pavement application, and architectural coatings. As described previously, fugitive dust would be limited through compliance with SDAPCD Rule 55, which requires the restriction of visible emissions of fugitive dust beyond the property line. This measure is incorporated into the project as PDF -SM AQ-1, and is detailed in Chapter 4, Project Description.
Table 5.2-17
Footnote
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; See Appendix C for complete results. The values shown are the maximum summer or winter daily emissions results from CalEEMod and include PDF-SM-1 fugitive dust mitigation pursuant to PDF AQ-1.); however, PDF-SM-1 was not included in the “unmitigated” estimate.
Section 5.3, Biological Resources
MM-BIO-2 Osprey Nests. Should any osprey nests be established within the project site prior to commencement of construction, nesting structures shall be removed only during the non-breeding season (January 15 to July 31) and subject to monitoring by a qualified biologist during nest removal to ensure there are no direct impacts on osprey who may use the structures as perches during non-breeding season. If nests are found, the City and applicant will coordinate with CDFW and obtain a Scientific Collecting Permit if nest removal activities are required. Coordination with USFWS would also be required in order to ensure all protections under the Migratory Bird Treaty Act are adhered to.
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Section 5.8, Hazards and Hazardous Materials
Section 5.8.1.2, Existing Setting
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).
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.
Section 5.8.3, Impacts
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-Building Materials 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. Where applicable, this practice and its effectiveness in avoiding or minimizing impacts related to hazardous material are described below.
Section 5.9, Hydrology and Water Quality
Section 5.9.3, Impacts
Operations
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 Bay and will continue to discharge to existing outfall connections (Appendix I-2 and I-3).
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:
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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 Bay and 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.
Section 5.10, Land Use and Planning
Section 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 nterstate 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.
Section 5.10.3, Impacts
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 ind ustrial 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.
Table 5.10 -1, General Plan Consistency Table
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.
Section 5.15, Transportation
Figure 5.15-5, VMT Screening Map for the Project – Figure 5.15-5 has been revised in the Final EIR and is attached to this Errata. The revised figure shows the correct location of the project site.
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Section 5.16, Utilities and Service Systems
Section 5.16.1, Existing Conditions
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).
Section 5.16.3, Impacts
Stormwater
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 a n 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.
1, Executive Summary
1.3.2 Approvals and Amendments
Approval of the proposed project would require the adoption of a General Plan Amendment and a new Specific Plan; amendment of the Development Agreement by and between the City of Chula Vista, the Redevelopment Agency of the City of Chula Vista, and Rohr, Inc., dated December 30, 1999, as amended; certification of the EIR; adoption of CEQA Findings and Statement of Overriding Considerations; and adoption of a mitigation monitoring and reporting program (MMRP).
The documents to be amended are as follows:
▪ Amendment to the Development Agreement (1999, amended 2011) ▪ Chula Vista General Plan (City of Chula Vista 2005)
▪ Chula Vista Local Coastal Program
- Bayfront Local Coastal Program Land Use Plan (City of Chula Vista 2013) - Bayfront Specific Plan (City of Chula Vista 2018)
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2-C Relationship to Planning Documents
Relationship to City of Chula Vista General Plan and Zoning The Chula Vista General Plan was adopted in 2005 and recently amended in 2021 to incorporate the city’s updated Housing Element. It includes policies and standards to guide the development of the city. See Section 6 of this plan for a detailed consistency analysis. Specific plans must demonstrate consistency in regulations, guidelines, and programs with the goals and policies set forth in the general plan. 2-H SDG&E Easement and Railroad Right of Way
A 150-foot wide San Diego Gas and Electric easement and a 40 -foot wide SD&AE Railroad right-of-way easement bisects the specific plan area and runs in the north-south direction between PA-A and PA-B1&B2. No structures are allowed in this easement area. Major overhead transmission lines have been undergrounded through the easement area, however, the Specific Plan anticipates this area should be maintained clear for private drives, parking, landscape, and a potential extension of the Bayshore Bikeway. providing an exciting opportunity to connect the property with the existing bicycle facilities on H Street. 2-i Sea Level Rise
The City of Chula Vista’s Climate Adaptation Plan provides a framework to prepare for a changing climate including the effect on sea level rise. Strategy #10 of the plan provides specific actions the city will take to address the potential effect of sea level rise on the community’s infrastructure and built environment.
The Chula Vista Bayfront Local Coastal Program Land Use Plan identifies the site as urban/ developed and outside of environmentally sensitive habitat areas. Consistent with LCP Policy EM.1.E.2, buffers within the Local Coastal Plan area have been designed to accommodate potential areas of future sea level rise inundation and are identified on Exhibit 12a of the plan. The existing plan also provides for an adequate amount of habitat migration within the identified buffer areas based on a projected sea level rise.
The specific plan relies upon California Coastal Commission’s 2024 Sea Level Rise Policy Guidance (Update ) for “Sea Level Adaptation Strategy for San Diego Bay” which assumes an intermediate to high risk scenario for the year 2050 of 0.8 to 1.3 feet of sea level rise.
For this reason, the site’s minimum finished floor elevation is proposed to be raised by approximately 1.9 feet to account for potential sea level rise. This would result in the finished floor elevation of the buildings to be greater than an elevation of 12.5 feet based on the NACD88 vertical datum.
Table 2, Development Standards Table
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Table 3, Development Standards Table
5-A. Circulation Concept
H Street, Bay Boulevard, and G Street are existing streets and provide direct access to the Specific Plan area along the north, south, and east sides of the planning areas. Internal private drives will provide access through and within the planning areas. Truck access will be taken primarily from Bay Boulevard, G Street and internal drives and is discouraged on H Street.
Bay Boulevard
This existing roadway runs parallel to I-5 along the east property line and is designated as a Class II Collector. It will serve as an access road and buffer to I-5. See Figures 15 and 16 for representative cross-sections of Bay Boulevard - provided for reference only.
H Street
This existing roadway is designated as a 4 -lane Arterial. Recent and existing street improvements include new sidewalks, landscape, palm trees, lighting, and a separated bicycle path on the south side of the street. The Specific Plan envisions an expanded sidewalk with landscaped setbacks and additional street trees on the north side of the street. See Figures 17, 18 and 19 for representative cross-sections of H Street - provided for reference only.
Marina Parkway
This existing roadway is no longer a public street and is designated for future use as a utility corridor for the Gaylord Pacific Resort and Convention Center (Gaylord). It will serve to provide a landscaped buffer and screen for service areas of the Specific Plan and Gaylord. This segment will also provide a walking path connection from Gaylord to a potential hotel on PA-B-2.
G Street
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This existing roadway is designated as a private street for a portion within the Specific Plan boundary, while the public street portion serves as access to many public utility corridors and an SDG&E substation. It will function primarily as a service road, providing access to “back of house” areas. Truck access will be limited to this roadway.
See Figures 20 and 21 for representative cross-sections of G Street - provided for reference only.
7-A. Infrastructure
Public Parks
Chula Vista has approximately 90 existing, proposed, and future park and recreation facilities across the city, with the nearest existing facility located at Bayside/Marina Park. The project site is not subject to the Growth Management Oversight Commission parks and recreation threshold as it is located on the west side of I- 805.
8-G. Fencing
Fencing in the Specific Plan should provide for an extension of the community theme or character of development in the Specific Plan. Continuity of building materials and details will provide a cohesive architectural theme throughout highly visible areas of the planning areas. The following security fencing is envisioned along the interior property lines with the adjacent Gaylor-Pacific Resort Hotel. Security Fencing – 6’ High Metal Picket Fence.
9-A. Approvals
Implementation of the Specific Plan shall conform to Sections 65550 through 65553 of the California Government Code relating to the administration of specific plans and to City of Chula Vista Municipal Code (CVMC) Section 19.07.030. All development proposals within the boundaries of this specific plan shall submit to the City of Chula Vista for a Coastal Development Permit and Design Review Approval, as set forth in the CVMC Section 19.14.582. and pursuant to CVMC Section 19.83.001 et seq. Each project shall be evaluated administratively by the City’s Development Services Department for compliance with the terms and intent of this plan, both expressed and implied. 9-C. Administration Review Process
The standards and other requirements of this Specific Plan shall be administered and enforced by the City of Chula Vista Development Services Department and other City departments in the same manner as the provisions of the CVMC.
Unless specified otherwise, where the provisions contained herein differ from those in the CVMC, the provisions of this Specific Plan shall take precedence. Design Review and Planned Sign Programs for implementing development in the
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Specific Plan shall be processed through an administrative review by City of Chula Vista Development Services staff in accordance with CVMC Section 19.07.010 through 19.07.030. Sign concepts, including proposed sign programs, may be reviewed administratively as part of the Design Review for proposed development projects. The Director of Development Services Dirctor, or designee, has the discretion, with the concurrence of the applicant, to act in the place of the Planning Commission for all development proposed under this Specific Plan. 9-D. Specific Plan Amendments
Approval of this Specific Plan signifies acceptance by the City of Chula Vista of a general framework and specific development standards for the Rohr>Wohl Specific Plan. It is anticipated that certain modifications to the Specific Plan text and exhibits may be necessary during the life of the project. Any modifications to the Specific Plan shall occur in accordance with the amendment process described herein and pursuant to CVMC Chapter 19.14. These amendments, should they occur, are divided into two categories. Administrative amendments allow for minor changes to the Specific Plan (as enumerated below) and may be approved by the Director of Development Services (or designee) Zoning Administrator. All other proposed changes (not enumerated below) are considered formal amendments and are required to be reviewed for approval by the Planning Commission and City Council. In all cases, amendments must be found to be consistent with the goals and policies of the Specific Plan.
Administrative Amendments
Upon determination by the Director of Development Services (or designee) Zoning Administrator, certain minor modifications to the Specific Plan do text and graphics may not require formal amendments (i.e. through public hearing) to the Specific Plan as approved. The Zoning Administrator has the authority to approve modifications to the Specific Plan as follows:
7. Landscape, wall material, wall alignment and streetscape design modifications, which substantially conform to the intent of the design guidelines contained in this Specific Plan as determined by the Director of Development Services Planning or his/her designee.
8. Modifications of a similar nature to those listed above, which the Director of Development Services Planning or his/her designee deems minor, which are in keeping with the intent of the Specific Plan Appendix ‘A’ – Land Use Definitions
Government and Civic
Buildings (excludes
Public Safety Facility)
A building or other community facility such as a police sub-station, City Hall, satellite Public Works facility, etc. which provides services to the community or public.
Recreational Equipment
Rentals/Sales (e.g.
bicycles)
A facility where the sale or rental of bikes, skates, surfboards, Segway's and similar recreational equipment. Does not include the sale of vehicles automobiles.
Tattoo Shop This is defined as an establishment which provides tattooing and/or branding of human beings.
Technology
Contract/Consulting
Activities or facilities that involve the production, manufacturing, or consultation of design and development of commercial parts/computers/vehicles/electronic systems by or for the aerospace, defense industry, large national computer/software firms, engineering companies, laboratories, etc.
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Theaters and
Auditoriums
A facility used for entertainment purposes other than sporting events. This facility is primarily indoors and utilized by the general public. This does not include concert or other similar entertainment facilities.
Transit Facilities A center for mass transportation systems which includes buses, taxis, railways, monorail, etc.
Utility Facility and
Infrastructure
A facility utilized for electric, gas, water, steam power, communications system, transportation system which can be publicly, privately, or cooperatively owned. This could include pipelines for potable water, reclaimed water, natural gas, and sewage collection and disposal, and facilities for the transmission of electrical energy for sale, including transmission lines for a public utility company. Also includes telephone, telegraph, cable television, and other communications transmission facilities utilizing direct physical conduits.
Vocational and Trade
Schools
Schools for training students in a variety of specialized programs which includes professional, vocational, and trade career options in culinary, cosmetology, arts and media, accounting and finance, health and dental including nursing, legal, psychology, and technology)
Wholesale Businesses,
Storage, and Distribution
“Wholesale” means the use of a building or buildings primarily for the internal storage of goods of any type, which includes the selling of such goods to other businesses, including retailers, industrial, commercial, institutional, or professional business users, other wholesalers, or acting as agents or brokers and buying merchandise for, or selling merchandise to, such individuals or companies, and specifically excluding sales of goods directly to the ultimate consumer. Generally, sales tax is not collected from businesses purchasing such goods. Typical activities under this use include but are not limited to wholesaling, storage, warehousing services to retailers for goods and food products.
Wind Facility A renewable energy generation facility in which wind is used for the generation of electricity. Or A machine which can convert kinetic energy in wind into a usable form of electrical or mechanical energy intended primarily for on-site consumption but may transfer excess energy into the electrical grid.
Winery/Wine Tasting A place where fruit, such as grapes are processed to produce wine or alcoholic beverages. This also can include the packaging and distribution of the product and tasting. Food service and sales for on and offsite consumption can also occur.
Appendix C, Air Quality and Greenhouse Gas
Technical Report
PDF-GHG-1 Operational Mobile Source Emissions Reductions Measures. The project shall implement the following measures.
▪ Legible, durable, weather-proof signs shall be placed at truck access gates, loading docks, and truck parking areas that identify applicable California Air Resources Board (CARB) anti -idling regulations. At a minimum, each sign shall include: (1) instructions for truck drivers to shut off engines when not in use; (2) instructions for drivers of diesel trucks to restrict idling to no more than 5 minutes once the vehicle is stopped, the transmission is set to “neutral” or “park,” and the parking brake is enga ged; and (3) telephone numbers of the building facilities manager and CARB to report violations. Prior to the issuance of an occupancy permit, the City of Chula Vista shall conduct a site inspection to ensure that the signs are in place.
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▪ Tenants shall train managers and employees on efficient scheduling and load management to eliminate unnecessary queuing and idling of trucks. Staff in charge of keeping vehicle records shall be trained in diesel technologies and compliance with CARB regulations by attending CARB- approved courses as well as maintaining on-site records demonstrating compliance. ▪ Leasing preference shall be given to prospective tenants with a facility -owned and operated fleet that is alternative/zero-emissions.
▪ Prior to tenant occupancy, the developer or successor(s) in interest shall provide documentation to the City of Chula Vista demonstrating that occupants/tenants of the Project site have been provided documentation on funding opportunities, such as the Carl Moyer Program, that provide incentives for using cleaner-than-required engines and equipment. ▪ The minimum number of automobile electric vehicle (EV) charging stations required by the California Code of Regulations Title 24 shall be provided prior to issuance of a Certificate of Occupancy. In addition, the buildings shall include electrical infrastructure sufficiently sized to accommodate the potential installation of additional automobile EV charging stations in the future. Electrical infrastructure shall be provided such that EV charging s tations can be installed on 20% of the Project’s total autom obile parking spaces. Buildings with over 200 parking spaces shall include an electrical system and other infrastructure sufficiently -sized oversize electrical rooms by 25 percent or by providing a secondary electrical room to accommodate future expansion of electric vehicle charging capability to accommodate the potential expanded installation of EV charging stations in the future. The electrical system and infrastructure must be clearly labeled with noticeable and permanent signage which informs future occupants/owners of the existence of this infrastructure. ▪ Tenants shall be in, and monitor compliance with, all current air quality regulations for on-road trucks including CARB’s Heavy -Duty (Tractor -Trailer) Greenhouse Gas Regulation, Periodic Smoke Inspection Program, and the Statewide Truck and Bus Regulation.
PDF-GHG-2 Operational Energy Source Emissions Reductions Measures. The Project shall implement the following measures.
▪ The project shall be designed such that all buildings with occupied rooms shall have some form of daylighting (e.g. skylights or windows) each building features skylights that cover a minimum of 2% 3% of the total roof area of the Project.
▪ Photovoltaic infrastructure shall be provided on the rooftops of project buildings in accordance with the proposed land use. Industrial/warehouse buildings shall provide a minimum 3% of the total roof area for photovoltaic arrays at building construction. All other proposed land uses shall provide a minimum 1 0% of the total roof area for photovoltaic arrays at building construction. such that a minimum of 25% of the total roof area of the project includes photovoltaic arrays at Project buildout. Project buildings shall include an electrical system and other infrastructure sufficiently sized to accommodate the potential installation photovoltaic arrays in the future up to 50% of the total roof area of the project. The electrical system and infrastructure must be clearly labeled with noticeable and permanent signage which informs future occupants/owners of the existence of this infrastructure. ▪ Project building plans shall specify that all fixtures installed in restrooms and employee break areas shall be U.S. Environmental Protection Agency (EPA) Certified WaterSense or equivalent.
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▪ Project building plans shall specify that all heating, cooling, lighting, and appliance fixtures installed be Energy Star -rated. Information on energy efficiency, energy -efficient lighting and lighting control systems, energy management, and existing energy incentive programs shall be provided to future tenants of the project.
▪ Prior to the issuance of permits that would allow the installation of landscaping, the City of Chula Vista shall review and approve landscaping plans for the site that require: (1) a plant palette emphasizing drought -tolerant plants; (2) use of water -efficient irrigation techniques; and (3) sufficient shade trees are provided so that at least 30% of the automobile parking areas will be shaded within 15 years after project construction is complete (excluding the truck courts where trees cannot be planted due to interference with truck maneuvering). The City of Chula Vista shall inspect for adherence to these requirements after landscaping installation. ▪ Structures shall be equipped with outdoor electric outlets in the front and rear of the structures to facilitate use of electrical lawn and garden equipment.
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1 Executive Summary
this chapter provides a summary of the environmental impact report (EIR) for the proposed Rohr Wohl Specific Plan Project (project). This summary (1) addresses the purpose of the Draft EIR; (2) summarizes the proposed project’s location, setting, and existing uses, project description, and objectives; ( 3) identifies required permits and/or discretionary approvals; ( 4) summarizes environmental topics, impacts, mitigation measures, and the level of significance after mitigation in tabular form; ( 5) describes areas of controversy and issues to be resolved; and (6) summarizes reasonable and feasible alternatives to the proposed project.
1.1 Project Location and Setting
The project site is approximately 44.8 acres located in the City of Chula Vista (City), California. The site is in the northwest portion of the City, directly adjacent to the City of San Diego. More specifically, the project site is located west of Interst ate (I) 5, north of H Street, south of G Street, east of Marina Parkway, and 0.5 miles east of the San Diego Bay (Figure 4-1, Project Location). The site Assessor’s Parcel Numbers are 571-330-35, 36, 37, 38, 39, 40, 41, 42, 43, 44, and 45.
The project site is divided into three separate 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, totaling 26.13 acres. Planning Area B-2, which is located south of B-1, totals 9.36 acres.
1.2 Project Background
The subject property consists of developed land occupied by the former Rohr Aircraft Facility. The site was developed with several industrial buildings historically used for manufacturing, warehousing, research and development, and related office uses totaling approximately 1,048,841 square feet. One of the industrial buildings in Planning Area A, known as Building 29 (795 H Street), was used for research and development, tooling, and warehousing and distribution of aftermarket products until February 2021. Renovations of that building commenced in 2021, including removal of approximately 50,000 square feet of interior mezzanine office space.
The renovations to the building in Planning Area A were completed in 2024. Planning Areas B-1 and B-2 were used for manufacturing operations, which ceased in approximately 2020. Ancillary uses continued operation at the site through the middle of 2021 (e.g., warehouse and outdoor storage for Collins Aerospace, decommissioning of plant equipment, shutdown/salvage of utili ties and external site facilities, and employee parking). September 2021 through October 2022 the site was used for parking for Collins Aerospace employees, and October 2022 through March 2023 asbestos abatement of the structures was conducted, steel and c opper were salvaged, and site utilities were disconnected. Demolition of the buildings in Planning Areas B -1 and B -2 (totaling approximately 766,837 square feet) commenced in May 2023 in connection with environmental remediation of the site.
Demolition in Planning Areas B-1 and B-2 are complete and soil remediation is underway as of the preparation of this EIR.
Historically, the project site was used for agriculture prior to development in 1941 with the existing facility. As a result of residual contaminated soils caused by historical agriculture and industrial uses at the project site, soil remediation and clean up efforts are necessary. Chemicals associated with historical operations have been identified in soil and groundwater, including, but not limited to, volatile organic compounds (VOCs), metals, 1 – EXECUTIVE SUMMARY
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petroleum hydrocarbons, polycyclic aromatic hydrocarbons (PAHs), and polychlorinated biphenyls (PCBs) and have been investigated under the Department of Environmental Health and the San Diego Regional Water Quality Control Board (SDRWQCB). In 1998, SDRWQCB issued Cleanup and Abatement Order No. 98 -08 for the Rohr facility to abate discharges from its facility. SDRWQCB issued CAO R9-2021-0042 in July 2021 that includes directives and timelines to remediate soil, soil gas, and groundwater at the property.
Planning Areas A, B-1, and B-2 are located within the Chula Vista Bayfront Local Coastal Program and currently lie within the General Industrial (I) Zoning and Industrial (I) General Plan land use designations. Land uses in the vicinity of 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 east; and Chula Vista RV Resort and future development site for the Gaylord Pacific Resort Hotel and Convention Center to the west.
1.3 Project Description
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. Specific plans are a mechanism to ensure that projects develop in an organized and cohesive manner. Specific plans incorporate a development framework for detailed land use, circulation, infrastructure including drainage, sewer, and water facilities, and urban design and landscape plans. A comprehensive set of design guidelines and devel opment regulations are included to guide and regulate site planning, landscape, and architectural character within the Specific Plan area ensuring that excellence in design is achieved during project development. The Rohr Wohl Specific Plan establishes the procedures and requirements to approve new development within the Specific Plan area.
A General Plan and Land Use Plan Amendment is proposed to be processed concurrently with Specific Plan adoption, which would change the existing I -G (General Industrial) 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). These new designations would provide 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 existing zoning designation of I-G would be amended to complement the Collins Aerospace Campus to allow a flexible combination of light industrial, office, commer cial and visitor-oriented uses to complement both the overall Chula Vista Bayfront area and the western part of Chula Vista. California Government Code (Title 7, Division 1, Chapter 3, Article 8, Sections 65450 –65457) permits adoption and administration of specific plans as an implementation tool for the local general plan. Specific plans must demonstrate consistency in regulations, guidelines, and programs with the goals and policies set forth in the general plan. The Rohr Wohl 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 providing regulations that support the success of an employment area of the City.
1.3.1 Project Objectives
Following are the objectives of the proposed project:
Generate a diverse spectrum of employment opportunities and regain for Chula Vista the approximately 1,000 jobs that existed on the site during Rohr Industries operations. 1 – EXECUTIVE SUMMARY
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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 & 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.
1.3.2 Approvals and Amendments
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. When adopted by ordinance, the Specific Plan would become the zoning for all uses within the Specific Plan area. Where conflicts occur between the municipal code and the Specific Plan, the Specific Plan would prevail. Where standards are not included in the Specific Plan, the underlying code provisions would apply.
Approval of the proposed project would require the adoption of a General Plan Amendment and a new Specific Plan; amendment of the Development Agreement by and between the City of Chula Vista, the Redevelopment Agency of the City of Chula Vista, and Rohr, Inc., dated December 30, 1999, as amended; certification of the EIR; adoption of CEQA Findings and Statement of Overriding Considerations; and adoption of a mitigation monitoring and reporting program (MMRP).
The documents to be approved are as follows:
▪ Environmental Impact Report
▪ Specific Plan
▪ Tentative Map for Subdivision of Planning Area B-1
▪ Coastal Development Permit for Planning Area B-1
▪ Design Review for Planning Area B-1
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The documents to be amended are as follows:
▪ Chula Vista General Plan (City of Chula Vista 2005)
▪ Chula Vista Local Coastal Program
- Bayfront Local Coastal Program Land Use Plan (City of Chula Vista 2013) - Bayfront Specific Plan (City of Chula Vista 2018)
▪ Chula Vista Municipal Code Chapter 19
- Section 19.81: Bayfront Specific Plan – Scope and Purpose - Section 19.84: Bayfront Specific Plan – Land Use Zones - Section 19.85: Bayfront Specific Plan – Development Criteria
1.4 Areas of Controversy
Section 15123(b)(2) of the CEQA Guidelines requires that areas of controversy known to the lead agency be stated in the EIR summary. To determine the number, scope, and extent of the environmental topics to be addressed in this EIR, the City prepared an NO P and circulated them to interested public agencies, organizations, community groups, and individuals in order to receive input on the proposed project. The City also held a scoping/public information meeting to obtain agency and public input on the proposed project. Based on the NOP scoping process and comments received, among the issues that are addressed in the Draft EIR are the following (the EIR section that addresses the issue raised is provided in parentheses):
Biological resource impacts, including consideration of nesting Osprey (Section 5.3, Biological Resources) Cultural resources, including tribal cultural resources and outreach to Native American tribes (Section 5.4, Cultural and Tribal Cultural Resources)
Pedestrian and bicycle safety and access (Section 5.15, Transportation) Land use and planning and consistency with planning documents (Section 5.10, Land Use and Planning) Alternatives (Chapter 10, Alternatives).
1.5 Project 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 deta iled consideration are (i) failure to meet most of the basic project objectives, (ii) infeasibility, and/or (iii) 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.
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1.5.1 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.
1.5.2 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 fo od 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.
1.5.3 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.
1.5.4 Exclusion of All Planning Area B-2 Alternative
Exclusion of Planning Area B-2 entirely would have reduced construction and operational impacts compared to the proposed project in the near -term. However, B -2 would remain vacant, zoned General Industrial, and future development could still occur in Planning Area B-2, albeit would not be required to adhere to the design guidelines outlined in the Specific Plan. This alternative would reduce near -term traffic impacts because average daily trips would be reduced by 5,000 trips. There would also be a reduction in near-term construction emissions and noise; however, development would still likely occur in Planning Area B -2 at a later date, consistent with the underlying zoning and land use. Therefore, it’s unlikely that emissions and noise would be reduced in t he long-term. Impacts would not be substantially reduced under this alternative when compared to the proposed project.
1.6 Summary of Significant Environmental Impacts
Table 1 -1 provides a summary of the potential significant environmental impacts expected to result from the proposed project pursuant to the CEQA Guidelines Section 15123(b)(1). For more detailed discussion, please see Chapter 5 of this EIR. Table 1 -1 also lists the applicable mitigation measures related to the identified significant impacts, as well as the level of significance after mitigation is identified. The proposed project would 1 – EXECUTIVE SUMMARY
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result in potentially significant impacts, that would be reduced to less than significant with mitigation in the following areas: air quality; biological resources; cultural and tribal cultural resources; and geology and soils (paleontological resources) .
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2 Introduction
This chapter of the environmental impact report (EIR) describes the purpose, scope, and legislative authority of the EIR, the intent of the California Environmental Quality Act (CEQA) and other pertinent environmental rules and regulations, and the environmental review process. The section also includes the structure, required contents, and relationship of the EIR to other potential responsible or trustee agencies.
2.1 Project Purpose and Background
This EIR addresses the environmental effects associated with the proposed Rohr Wohl Specific Plan Project (project or proposed project). The proposed project will redevelop and repurpose land that has been developed and operated for industrial purposes since about 1941. Implementation of the project requires an approval of the EIR, Specific Plan, Tentative Map for Subdivision of Planning Area B -1, Coastal Development Permit for Planning Area B-1, Design Review for Planning Area B -1, Chula Vista General Plan Amendment, Local Coastal Plan Amendment, Chula Vista Municipal Code Chapter 19 Amendment (Sections 19.81, 19.84, 19.85), and a rezone.
This EIR was prepared in accordance with CEQA ( California Public Resources Code, Section 21000 et seq.), the CEQA Guidelines (14 CCR 15000 et seq.), and the City of Chula Vista (City) environmental review procedures. The City is the lead agency for the EIR and for processing of the project.
This EIR provides decision makers, public agencies, and the public with detailed information about the potential for significant adverse environmental impacts to occur as a result of the proposed project. Similarly, responsible agencies will use this EIR to fulfill their legal authority associated with permits issued for the project. The analysis and findings in this document reflect the independent judgment of the City.
2.2 Hierarchy of Planning Documents
2.2.1 City of Chula Vista General Plan
California law requires that each county and city adopt a General Plan “for the physical development of the County or City, and of any land outside its boundaries which … bears relation to its planning” (California Government Code, Section 65300). Each General Plan must be internally consistent and all discretionary land use plans and projects must also be consistent with the General Plan.
The City of Chula Vista City Council adopted an updated General Plan on December 13, 2005 (Resolution Nos. 2005-424, 2005 -425, 2005 -426; City of Chula Vista 2005 ). The General Plan outlines goals, objectives, and policies for land use in the City in response to the community’s vision for the City. This General Plan also guides day-to-day decision making to ensure that there is continuing progress toward attaining the General Plan goals.
The General Plan includes area plans for specific parts of the City, including the Bayfront Planning Area, where the project site is located. The Bayfront Planning Area encompasses approximately 2,620 acres, which includes uplands or filled areas above mean high tide; and wetlands. Most of the developed area within the Bayfront Planning Area currently consists of industrial and commercial uses. The remainder of the uplands is underutilized and either 2 – INTRODUCTION
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vacant or used for smaller industrial warehouse and commercial purposes. The existing development consists of low-rise buildings and open parking areas.
2.2.2 Bayfront Local Coastal Program
The Bayfront Local Coastal Program Amendment Bayfront Specific Plan was adopted in 2012 and amended in 2015 and 2018 (City of Chula Vista 2018). It governs the development of 722 acres of the City’s bayfront. The Bayfront Local Coastal Program designates the project site for Industrial General uses. This zone and land use designation provides for large-scale and more intensive industrial uses such as manufacturing and public utility plants.
The land use designation under the Bayfront Local Coastal Program reflects the historic industrial uses of the site associated with the Rohr aerospace industry. The land uses proposed under this Specific Plan are intended as a departure from heavy industrial uses to light industrial uses, business park, and visitor -serving uses, which are more compatible with and complement other uses planned for in the Specific Plan.
2.2.3 City of Chula Vista Multiple Species Conservation Program The municipalities of southern San Diego County collaborated in producing the Multiple Species Conservation Program (MSCP) Subregional Plan. The MSCP Subregional Plan is implemented through individual Subarea Plans adopted by each jurisdiction and would allow “take” authorization for covered species through specific conditions of coverage pursuant to Section 4(d) of the federal Endangered Species Act. The Chula Vista MSCP Subarea Plan 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 MSCP outlines covered projects, which include projects involving land use development within the City for which hardline preserve boundaries have been established pursuant to the approved MSCP Subarea Plan, and where conservation measures consistent with the MSCP Subregional Plan and Chula Vista Subarea Plan have been or will be specified as biding conditions of approval in such projects’ plans and approval. The proposed project was not identified as a covered project in the MSCP and it is not located within the boundaries of the preserve area.
2.3 Scope of the EIR
Pursuant to Section 15161 of the CEQA Guidelines, this document was prepared as a project EIR ; as such, it is “focused primarily on the changes in the environment that would result from the development” (i.e., the buildout of the proposed project). Where environmental impacts have been determined to be potentially significant, this EIR presents mitigation measu res directed at reducing those adverse environmental effects. The development of mitigation measures provides the lead agency with ways to substantia lly lessen or avoid the significant effects of the project on the environment, to the degree feasible. Alternatives to the proposed project are presented to evaluate whether there are alternative development scenarios that can further minimize or avoid sig nificant impacts associated with the project.
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2.4 Environmental Procedures
2.4.1 CEQA Compliance
The California Public Resources Code (Section 21000 et seq.) requires the preparation and certification of an EIR for any project that a lead agency determines may have a significant effect on the environment. This EIR has been prepared in compliance with all criteria, standards, and procedures of the CEQA Guidelines (14 CCR Section 15000 et seq.).
In the event that future projects , or uses, are proposed on the project site , consistent with the Specific Plan, for which environmen tal impacts m ight exceed the impacts disclosed throughout this EIR, additional CEQA documentation would be required.
2.4.2 Notice of Preparation and Scoping
CEQA establishes mechanisms whereby the public and decision makers can be informed about the nature of a proposed project and the extent and types of impacts that the project and its alternatives would have on the environment, should the project or alterna tives be implemented. Pursuant to Section 15082 of the CEQA Guidelines, the City circulated a Notice of Preparation (NOP) dated October 7, 2022, to begin a 30 -day public scoping period, to interested agencies, organizations, and parties. The NOP was also s ent to the State Clearinghouse at the California Governor’s Office of Planning and Research. The State Clearinghouse assigned a state identification number (SCH No. 2022100138) to this EIR.
The NOP is intended to encourage interagency communication regarding the proposed action so that agencies, organizations, and individuals are afforded an opportunity to respond with specific comments and/or questions regarding the scope and content of the EIR.
Comments received during the NOP public scoping period were considered during the preparation of this EIR. The NOP and comments are included in Appendix A to this EIR.
2.4.3 Overview of the EIR Process
This EIR will be made available to members of the public, public agencies, and interested parties for a 45-day public comment period in accordance with Section 15105 of the CEQA Guidelines. Public comment of the EIR is intended to focus “on the sufficiency of the document in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated” (14 CCR 15204). The Notice of Completion of the EIR will be filed with the State C learinghouse as required by Section 15085 of the CEQA Guidelines. In addition, the Notice of Availability of the EIR will be distributed pursuant to Section 15087 of the CEQA Guidelines. Interested parties may provide comments on the EIR in written form. T his EIR and all related technical appendices are available for review upon request during the 45 -day public comment period by the following means:
▪ The EIR is available to review electronically at: https://www.chulavistaca.gov/departments/development- services/planning/public-notices/environmental-notices
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▪ For additional options to review, please contact Arturo Ortuno, by email at [email protected] or phone at 619.409.-5864.
Once the 45-day public comment period has concluded, the City will review all public comments on the EIR, provide written responses to comments, and authorize revisions to the EIR text, if necessary. The final mitigation monitoring and reporting program (MMRP) will be incorporated into the Final EIR. Mitigation measures contained in the EIR consider future monitoring requirements and are written in sufficient detail to address impacts of the proposed project, referencing the appropriate implementing permi ts and plans. If one or more significant environmental impacts are determined, written findings for each of those significant effects, accompanied by an overriding justification and rationale for each finding in the form of a statement of overriding consider ations will also be included in the Final EIR, if necessary. The Final EIR includes all comment letters received, final written response to comments, a Final EIR preface, if applicable, edits made to the EIR as a result of public review/comment, and findings of fact and statement of overriding considerations, if necessary.
2.5 Intended Uses of the EIR
According to Section 21002.1(a) of CEQA, “[t]he purpose of an environmental impact report is to identify the significant effects of a project, to identify alternatives to the project, and to indicate the manner in which those significant effects can be mit igated or avoided.” This EIR provides relevant information concerning the potential environmental effects associated with construction and operation of the proposed project and identifies and evaluates potentially significant effects that may result from implementation of the proposed project. It is intended for use by decision makers and the public.
As the designated lead agency, the City has assumed responsibility for preparing this EIR. When deciding whether to approve the proposed project, the City will use the information provided in this EIR to consider potential impacts to the physical environme nt associated with the proposed project. The City will consider all written comments received on the EIR during the 45-day public comment period in making its decision to certify the EIR as complete and in compliance with CEQA and in making its determination whether to approve or deny the project. In the final review of the document, environmental considerations, and economic and social factors will be weighed to determine the most appropriate course of action.
After certification of the Final EIR, agencies with permitting authority over all or portions of the project will use the Final EIR as the basis for their evaluation of environmental effects related to the project and approval or denial of other applicable permits or authorizations.
2.6 Organization and Content of the EIR
This EIR is organized to provide a tiered project-level analysis of the potentially significant environmental impacts, mitigation measures, and alternatives for the proposed project. To describe the direct, indirect, and cumulative impacts, mitigation measures, and alternatives for the proposed project, this EIR is organized as follows:
▪ Chapter 1, Executive Summary, outlines the conclusions of the environmental analysis and a summary of the project as compared to the alternatives analyzed in the EIR. This section also includes a table summarizing all environmental impacts identified in this EIR alo ng with the associated project design features and mitigation measures proposed to reduce or avoid each impact. 2 – INTRODUCTION
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▪ Chapter 2, Introduction, serves as a foreword to this EIR, introducing the project background, relevant planning documents, the scope of the EIR, applicable environmental review procedures, the intended use and organization of the EIR, and the MMRP.
▪ Chapter 3, Environmental Setting, describes the project location and physical environmental setting. ▪ Chapter 4, Project Description, provides a thorough description of the proposed project and required discretionary approvals, along with project design features used as part of the City’s standard practice to minimize project impacts.
▪ Chapter 5, Environmental Impact Analysis, provides an analysis of the potentially significant environmental impacts identified, and proposed mitigation measures to reduce or avoid any potentially significant impacts. ▪ Chapter 6, Cumulative Impacts, provides an analysis of the cumulative effects of the proposed project. ▪ Chapter 7, Growth Inducement, discusses the project’s potential growth-inducing impacts. ▪ Chapter 8, Significant Irreversible Environmental Changes, addresses impacts that have been identified as significant and irreversible.
▪ Chapter 9, Effects Found Not to Be Significant, address es impacts that were determined to not be significant during the scoping process.
▪ Chapter 10, Alternatives, analyzes a range of reasonable alternatives to the proposed project that would lessen or avoid significant environmental effects of the proposed project. ▪ Chapter 11, References, provides a compiled list of references cited in each section of the EIR. ▪ Chapter 12, List of Preparers, provides a list of persons who contributed to the preparation of this EIR. ▪ Appendices include various technical studies and correspondence prepared for the project, as listed below and in the table of contents:
- A: NOP and Comment Letters
- B: Specific Plan
- C: Air Quality and GHG Report
- D: Biological Resources Report
- E: Phase I Cultural Resources Survey
- F: Paleontological Resources Records Search
- G1: Geotechnical Investigation Parcel A
- G2: Geotechnical Investigation Parcel B
- H1: Phase 1 ESA Parcel A
- H2: Phase 1 ESA Parcel B
- H3: Cleanup and Abatement Order No. R9-2021-0042
- I1: Preliminary Drainage Report
- I2: Priority Development Project Stormwater Quality Management Plan - I3: Updated Drainage Memorandum
- J: Noise Report
- K: Local Mobility Analysis
- L1: Water Service Analysis
- L2: Sewer Service Analysis
- L3: Water Supply Assessment
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- M: Mitigation Monitoring and Reporting Program
- N: Findings
2.7 Mitigation Monitoring and Reporting Program
The City will prepare an MMRP prior to project approval. The MMRP will include all mitigation measures outlined in the EIR, the responsible entity for implementation, implementation timing (prior to construction, during construction, post -construction), an d any follow -up reporting requirements (such as submittal of materials to regulatory agencies). The City, as the designated lead agency, is responsible for enforcing and verifying that each mitigation measure is implemented as required.
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Table of Contents
SECTION PAGE NO.
2 Introduction ...................................................................................................................................................... 2-1
2.1 Project Purpose and Background ...................................................................................................... 2-1
2.2 Hierarchy of Planning Documents ..................................................................................................... 2-1
2.2.1 City of Chula Vista General Plan .......................................................................................... 2-1
2.2.2 Bayfront Local Coastal Program .......................................................................................... 2-2
2.2.3 City of Chula Vista Multiple Species Conservation Program .............................................. 2-2
2.3 Scope of the EIR ................................................................................................................................. 2-2
2.4 Environmental Procedures ................................................................................................................ 2-3
2.4.1 CEQA Compliance ................................................................................................................. 2-3
2.4.2 Notice of Preparation and Scoping ...................................................................................... 2-3
2.4.3 Overview of the EIR Process................................................................................................. 2-3
2.5 Intended Uses of the EIR ................................................................................................................... 2-4
2.6 Organization and Content of the EIR ................................................................................................. 2-4
2.7 Mitigation Monitoring and Reporting Program ................................................................................. 2-6
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3 Environmental Setting
This chapter of the environmental impact report (EIR) provides a description of the existing site conditions, surrounding land uses, and land use planning context relevant to the proposed Rohr Wohl Specific Plan (project or proposed project). Additionally, this chapter includes a description and map of related projects and growth factor assumptions for the project area.
3.1 Existing Site Conditions
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 owned company, is completing soil and groundwater remediation in accordance with San Diego Regional Water Quality Control Board (RWQCB) Cleanup and Abatement Order (CA O) No. 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.
3.1.1 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 nterstate 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.
3.1.2 Existing Topography and Soils
Existing on-site grades are relatively flat with elevations of approximately 8 to 12 feet above mean sea level on the west and east, respectively. The site is located on the western portion of the coastal plain of San Diego County. The site is underlain by two surficial soil types (consisting of undocumented fill and Holocene -age Bay. Deposits) and two formational unit (consisting of Old Paralic Deposits and the San Diego Formation).
Undocumented fill associated with the existing site improvements is present across the majority of the site to depths of about 5 to 10 feet. In general, the fill consists of loose to medium dense, moist to wet, silty sand and possesses a “very low” to “low” expansion index (expansion index of 50 or less). The fill located below the groundwater elevation possesses a potential for liquefaction. Additionally, a zone of debris fill is located along the previous shoreline of the bay (along the western edge of the project stie). These materials are composed of concrete and 3 – ENVIRONMENTAL SETTING
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trash debris mixed with soils that extend to depths of 5 to 10 feet below ground surface. The upper portion of the undocumented fill is likely unsuitable for the support of proposed structures or structural fill and will require remedial grading limited to the groundwater elevation and/or saturated soil conditions (Appendices F and G).
Groundwater is encountered at a depth of approximately 5 to 20 feet below the existing ground surface across the plan area (approximate elevation of 1 to 7 feet above mean sea level). Groundwater will likely have a significant influence on construction of deep utilities (if constructed), and during remedial grading. Dewatering will likely be required for excavations below the fluctuating groundwater elevation.
3.1.3 Climate
The San Diego Air Basin experiences warm summers, mild winters, infrequent rainfalls, light winds, and moderate humidity. This usually mild climatological pattern is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds. The weather of the San Diego region, as in most of Southern California, is influenced by the Pacific Ocean and its semi -permanent high-pressure systems that result in dry, warm summers and mild, occasionally wet winters. The average temperature rang es (in degrees Fahrenheit) from the mid -40s to the high 90s. Most of the region’s precipitation falls during November through April, with infrequent (approximately 10%) precipitation during the summer. The average seasonal precipitation in the City of Chula Vista is approximately
9.7 inches; the amount increases with elevation as moist air is lifted over the mountains to the east (WRCC 2023).
3.1.4 Access
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.
3.2 Existing Land Use Designations
3.2.1 Existing General Plan Designations
The Chula Vista General Plan was adopted in 2005 and was recently amended in 2021 and includes policies and standards to guide the development of the City (City of Chula Vista 2005). The project site is designated in the City’s General Plan as Industrial (I). Per the General Plan, this designation is intended to allow all uses identified for the “Research” and “Limited Industrial” categories, plus heavier manufacturing, large -scale warehousing, transportation centers and public utilities.
3.2.2 Existing Zoning
The Zoning Ordinance is the primary tool for implementing the General Plan and is designed to protect and promote the public health, safety, comfort, convenience, prosperity, and general welfare of the people. The project site is currently zoned General Industrial (I-G). According to the City’s Municipal Code, the intent of this designation is to provide regulations for exclusive use of industrial development. 3 – ENVIRONMENTAL SETTING
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3.2.3 Local Coastal Plan
The purpose of the Chula Vista Bayfront Local Coastal Plan is to provide a detailed plan for orderly growth, development, redevelopment, and conservation of the City jurisdictional parcels located within the Chula Vista Bayfront coastal area. The Chula Vista Bayfront Local Coastal P lan also designates the project site Industrial- General (I-G). Per the Local Coastal Plan , this designation provides for large -scale and more intensive industrial uses such as manufacturing and public utility plants.
3.2.4 Development Agreement
Development Agreement by and Between City of Chula Vista, Redevelopment Agency of the City of Chula Vista, and Rohr, Inc., operating as BF Goodrich Aerospace Aerostructures Group, dated December 30, 1999 (approved by City Ordinance No. 1999-2800), as amended by Amendment to Development Agreement recorded March 23, 2011 as Document No, 2011-0153006 (approved by City Ordinance No. 3178).
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4 Project Description
This chapter of the environmental impact report (EIR) provides a description of the proposed Rohr Wohl Specific Plan Project (project or proposed project). The proposed project will redevelop and repurpose land that has been developed and operated for industrial purposes since about 1941. As required by Section 15124 of the California Environmental Quality Act (CEQA) Guidelines, this chapter includes the precise location of the project site, a statement of the project objectives, a general description of project characteristics that accounts for public service facilities, and a summary of the discretionary actions that would be required.
4.1 Location
The project site is approximately 44.8 acres located in the City of Chula Vista (City), California. The site is in the northwest portion of the City, 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 the San Diego Bay (Figure 4-1, Project Location). The site Assessor’s Parcel Numbers are 571-330-35, 36, 37, 38, 39, 40, 41, 42, 43, 44, and 45.
The project site is divided into three separate 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, totaling 26.13 acres. Planning Area B -2, which is located south of B -1, totals 9.36 acres (Figure 4-2, Site Plan).
4.2 Background
The subject property consists of developed land occupied by the former Rohr Aircraft Facility. The site was developed with several industrial buildings historically used for manufacturing, warehousing, research and development, and related office uses totaling approximately 1,048,841 square feet. One of the industrial buildings in Planning Area A , known as Building 29 (795 H Street), was used for research and development, tooling, and warehousing and distribution of aftermarket products until February 2021 . Renovations of that building commenced in 2021, including removal of approximately 50,000 square feet of interior mezzanine office space .
The renovations to the building in Planning Area A were completed in 2024. Planning Areas B-1 and B-2 were used for manufacturing operations, which ceased in approximately 2020. Ancillary uses continued operation at the site through the middle of 2021 (e.g., warehouse and outdoor storage for Collins Aerospace, decommissioning of plant equipment, shutdown/salvage of utili ties and external site facilities, and employee parking). September 2021 through October 2022 the site was used for parking for Collins Aerospace employees, and October 2022 through March 2023 asbestos abatement of the structures was conducted, steel and c opper were salvaged, and site utilities were disconnected. Demolition of the buildings in Planning Areas B -1 and B -2 (totaling approximately 766,837 square feet) commenced in May 2023 in connection with environmental remediation of the site.
Demolition in Planning Areas B-1 and B-2 are complete and soil remediation is underway as of the preparation of this EIR.
Historically, the project site was used for agricultur e prior to development in 1941 with the existing facility. As a result of residual contaminated soils caused by historical agriculture and industrial uses at the project site, soil remediation and cleanup efforts are necessary. Chemicals associated with his torical operations have been 4 – PROJECT DESCRIPTION
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identified in soil and groundwater, including, but not limited to, volatile organic compounds (VOCs), metals, petroleum hydrocarbons, polycyclic aromatic hydrocarbons (PAHs), and PCBs and have been investigated under the Department of Environmental Health DEH and the San Diego Regional Water Quality Control Board (SDRWQCB). In 1998, SDRWQCB issued Cleanup and Abatement Order No. 98-08 for the Rohr facility to abate discharges from its facility. SDRWQCB issued CAO R9-2021-0042 in July 2021 that includes directives and timelines to remediate soil, soil gas, and groundwater at the property.
Planning Areas A, B-1, and B-2 are located within the Chula Vista Bayfront Local Coastal Program and currently lie within the General Industrial (I) Zoning and Industrial (I) General Plan land use designations. Land uses in the vicinity of 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 east; and Chula Vista RV Resort and future development site for the Gaylord Pacific Resort Hotel and Convention Center to the west.
4.3 Project Objectives
Following are the objectives of the proposed project:
1. Generate a diverse spectrum of employment opportunities and regain for Chula Vista the approximately 1,000 jobs that existed on the site during Rohr Industries operations.
2. Foster Chula Vista’s capture of leading businesses and employers in existing and emerging economic sectors that drive the regional economy.
3. Encourage clean industrial, research & development, and office use designations (e.g., defense, Port - related, e-commerce, technology, hospitality, and medical device/life sciences).
4. 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.
5. Attract significant capital investment to Chula Vista at vacant and underutilized property.
6. Highlight the proximity to the “E” Street and “H” Street Trolley Stations to encourage transit usage by visitors and workers.
7. Expand mobility options of today and the future and thoughtfully address Vehicle Miles Traveled (“VMT”).
8. 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.
9. Provide flexibility for land uses and development that evolves as the Chula Vista Bayfront matures over the coming years and decades.
10. Provide for roadways, infrastructure, and utilities to support on-site land uses as the project evolves.
11. 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.
12. 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.
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4.4.1 Approvals and Amendments
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. When adopted by ordinance, the Specific Plan would become the zoning for all uses within the Sp ecific Plan area. Where conflicts occur between the municipal code and the Specific Plan, the Specific Plan would prevail. Where standards are not included in the Specific Plan, the underlying code provisions would apply.
Approval of the proposed project would require the adoption of a General Plan Amendment and a new Specific Plan; amendment of the Development Agreement by and between the City of Chula Vista, the Redevelopment Agency of the City of Chula Vista, and Rohr, Inc., dated December 30, 1999, as amended; certification of the EIR; adoption of CEQA Findings and Statement of Overriding Considerations; and adoption of a mitigation monitoring and reporting program (MMRP).
The documents to be approved are as follows:
▪ Environmental Impact Report
▪ Specific Plan
▪ Tentative Map for Subdivision of Planning Area B-1
▪ Coastal Development Permit for Planning Area B-1
▪ Design Review for Planning Area B-1
The documents to be amended are as follows:
▪ Amendment to the Development Agreement (1999, amended 2011) ▪ Chula Vista General Plan (City of Chula Vista 2005)
▪ Chula Vista Local Coastal Program
- Bayfront Local Coastal Program Land Use Plan (City of Chula Vista 2013) - Bayfront Specific Plan (City of Chula Vista 2018)
▪ Chula Vista Municipal Code Chapter 19
- Section 19.81: Bayfront Specific Plan – Scope and Purpose - Section 19.84: Bayfront Specific Plan – Land Use Zones - Section 19.85: Bayfront Specific Plan – Development Criteria
4.4.2 Access and Circulation Network
4.4.2.1 Site Access
The project site is bounded to the north by G Street, to the east by Bay Boulevard, and to the south by H Street (Figure 4 -3, Circulation) . All these streets currently provide direct access to the project site. The following information provides a description of these existing roadways and what is proposed with the project.
G Street: This roadway is a Private Street along the western two thirds of the frontage with Planning Area B1 and a Public Street with no access, curb, gutter, or sidewalk and is only 40 feet wide, between the former SD&AE railroad 4 – PROJECT DESCRIPTION
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and the San Diego Gas and Electric Company (SDG&E) substation. Across the frontage of Planning Area A, G Street is a Public Street with a curb, gutter, and sidewalk.
This roadway would primarily serve as a service road providing “back -of-house” access to the proposed uses on site, while also serving as an access to many public utility corridors and an SDG&E substation. All trucking activities occurring on/within Planning Area B-1 would utilize G Street exclusively.
Bay Boulevard: This roadway runs parallel to I-5 along the east property line and is designated as a Class III Collector.
This roadway would also serve as a service access road.
H Street: This roadway is designated as a four-lane Major Arterial. Recent and existing street improvements include new sidewalks, landscape, palm trees, lighting, and a separated bicycle path on the south side of the street. This roadway would also provide several access points into the project site , including a future curb cut in the future raised median in H Street to provide full access at the main project driveway.
Public Transit: The Metropolitan Transit Station (MTS) H Street Transit Station is the closest transit center to the project site, within 0.25 mile s, located on H Street immediately east of I -5. The MTS E Street Transit station is located 0.6 miles north of the project site immediately east of I-5. Both stops provide access to the MTS Blue Line Trolley and several bus routes. Bus Routes 932, 709, 705, 704, and 701 are accessible from these two stations.
4.4.2.2 Internal Circulation
Private Streets: Circulation internal to the project site is provided through several private drives.
Pedestrian and Bicycle Circulation: Pedestrian walkways and/or corridors would be provided between buildings, parking areas, and all site facilities for safe access. Cross circulation between vehicles and pedestrians would be minimized.
4.4.3 Public Service and Utilities
4.4.3.1 Wet Utilities
Water Facilities: Water service would be provided via existing water connections to the public water system.
Water service to the project site is provided by the Sweetwater Authority. Planning Areas A and B -1 are served by a 12 -inch potable water main located within G Street. Planning Areas A and B -2 are served by a 16 -inch water main located in H Street. Refer to Section 5. 16, Utilities and Service Systems, for a detailed description of water service and connection.
Sewer Facilities: Sewer service would be provided by the City via existing connections to the public sewer system.
The City of Chula Vista provides sewer collection and conveyance but does not operate its own wastewater treatment facilities. Wastewater treatment is provided by the City of San Diego Metropolitan Wastewater Authority.
Wastewater from the project site would be conveyed by the Ci ty of Chula Vista’ s local 12 -inch main sewer line located in G Street and main line in the utility corridor of former Marina Parkway.
Wastewater from Planning Area B-2 flows north through private easements across Planning Area B-1, and combined flow to a single point of connection in Marina Parkway. Planning Area B-1 flows north to a single point of connection in (private) G Street. Planning Area A is also served by the City sewer main in G Street. No sewer mains exist within Bay Boulevard. The City main sewer line in G Street flows to the existing City Sewage Pump Station sited at the 4 – PROJECT DESCRIPTION
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northwest corner of Planning Area B -2, which then lifts the sewage into dual force mains in G Street, prior to connecting to the 78-inch City of San Diego Interceptor at G Street and the former SD&AE railroad corridor.
4.4.3.2 Drainage and Stormwater Facilities
On-site runoff is collected and transported by concrete gutters into storm drains located along the western property line of Planning Areas B -1 and B -2. These private storm drains will continue to discharge to existing outfall connectionsconnect 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 as overland flow into a n existing ditch along its western property line before entering the City’s public storm drain system along H Street.
All drainage facilities will be designed in consideration of the following goals:
▪ Low Impact Development/water quality features will be incorporated on site, through a combination of site- specific and regional methods.
▪ Water quality features will include a combination of controls within each building lot or site, as well as the downstream area of the planning areas.
▪ Water quality features will include swales, bioretention features, and mechanical treatment.
4.4.3.3 Dry Utilities
Dry utilities would be extended underground throughout the project site, primarily within drive aisles. Telephone, cable television, and internet service would be provided by companies such as Cox Communications, Time Warner, and AT&T. Gas and electric services would be provided by SDG&E. Gas and electric services exist at service points fronting G Street (private) and H Street and additional points of connection may be established. The existing overhead electrical distribution line running within the 150 -foot-wide SDG&E easement corridor will remain. The existing overhead electrical distribution line running within the private portion of G Street will remain. All other utility lines within the public streets fronting the property are underground, except for the overhead electrical line along the south side of public G Street, which will remain.
4.4.3.4 Schools
The City of Chula Vista is served by the Chula Vista Elementary School District and the Sweetwater Union High School District. The nearest schools to the project site are Mueller Charter School and Chula Vista Middle School, which are less than 1 mile from the project site. Chula Vista High School is within 2 miles of the project site.
4.4.3.5 Police and Fire Services
The Chula Vista Police Department provides police protection for the City and will also serve the project site. The Chula Vista Police Station on 315 4th Avenue will provide police protection for the project and is located approximately 1 mile from the project site.
The Chula Vista Fire Department provides fire protection services and emergency first response services to the project site and to approximately 275,000 people within the Chula Vista Fire Protection District. The Chula Vista Fire Department 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 (447 F Street, Chula Vista, California). 4 – PROJECT DESCRIPTION
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4.4.3.6 Parks
The closest park to the project site is in the Bayfront at Bayside/Marina Park. No public park space would be provided as part of the project.
4.4.4 Construction Phasing and Conceptual Grading
It is anticipated that development of the proposed project elements for Planning Areas B -1 and B-2 would occur over approximately 5 years. The anticipated sequence of construction is as follows, with some phases overlapping:
Planning Area B -1
▪ Demolition (B-1 and B-2): Completed prior to start of proposed project in connection with site remediation. ▪ Site Preparation (Phase 1; B-1 and B-2): 2 weeks
▪ Grading (Phase 1): 1.5 months
▪ Building Construction (Phase 1): 21 months
▪ Paving (Phase 1): 1 month
▪ Architectural Coating: 1 month
Planning Area B -2
▪ Minimal Grading (Phase 2; B-2): 1 month
▪ Building Construction (Phase 2): 11 months
▪ Paving (Phase 2): 1 month
▪ Architectural Coating (Phase 3): 1 month
Construction is proposed to occur Monday through Saturday, between 7:00 a.m. and 7:00 p.m., to comply with Section 19.68 of the City’s Code of Ordinances.
4.4.5 Project Design Features
The project would include several sustainability design features in pursuit of the project’s objectives to reduce potential energy and water usage, promote pedestrian and bicycle travel, and reduce potential greenhouse gas emissions. The proposed sustainability features include the following and will be made Conditions of Approval:
Air Quality Project Design Features
PDF-Site Management (SM) -1: Standard construction practices would be employed to reduce fugitive dust emissions and include watering of the active sites and exposed surfaces up two times per day, depending on weather conditions; watering unpaved roads, and limiting vehicle speeds on unpaved roads. Construction of the Projec t would be subject to S an Diego Air Pollution Control District (SDAPCD) Rule 55 – Fugitive Dust Control. Compliance with Rule 55 would limit fugitive dust that may be generated during grading and construction activities. 4 – PROJECT DESCRIPTION
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Greenhouse Gas Project Design Features
PDF-Regulation Compliance (RC) -1: Operational Mobile Source Emissions Reductions Measures - The project shall implement the following measures.
▪ Legible, durable, weather-proof signs shall be placed at truck access gates, loading docks, and truck parking areas that identify applicable California Air Resources Board (CARB) anti -idling regulations. At a minimum, each sign shall include: (1) instructions for truck drivers to shut off engines when not in use; (2) instructions for drivers of diesel trucks to restrict idling to no more than 5 minutes once the vehicle is stopped, the transmission is set to “neutral” or “park,” and the parking brake is enga ged; and (3) telephone numbers of the building facilities manager and CARB to report violations. Prior to the issuance of an occupancy permit, the City of Chula Vista shall conduct a site inspection to ensure that the signs are in place. ▪ Tenants shall train managers and employees on efficient scheduling and load management to eliminate unnecessary queuing and idling of trucks. Staff in charge of keeping vehicle records shall be trained in diesel technologies and compliance with CARB regulations by attending CARB- approved courses as well as maintaining on-site records demonstrating compliance. ▪ Leasing preference shall be given to prospective tenants with a facility -owned and operated fleet that is alternative/zero-emissions.
▪ Prior to tenant occupancy, the developer or successor(s) in interest shall provide documentation to the City of Chula Vista demonstrating that occupants/tenants of the Project site have been provided documentation on funding opportunities, such as the Carl Moyer Program, that provide incentives for using cleaner-than-required engines and equipment. ▪ The minimum number of automobile electric vehicle (EV) charging stations required by the California Code of Regulations Title 24 shall be provided prior to issuance of a Certificate of Occupancy. In addition, the buildings shall include electrical infrastructure sufficiently sized to accommodate the potential installation of additional automobile EV charging stations in the future. Electrical infrastructure shall be provided such that EV charging s tations can be installed on 20% of the Project’s total autom obile parking spaces. Buildings with over 200 parking spaces shall include an electrical system and other infrastructure sufficiently -sized oversize electrical rooms by 25 percent or by providing a secondary electrical room to accommodate the potential expanded installation of EV charging stations in the future. The electrical system and infrastructure must be clearly labeled with noticeable and permanent signage which informs future occupants/owners of the existence of this infrastructure. ▪ Tenants shall be in, and monitor compliance with, all current air quality regulations for on-road trucks including CARB’s Heavy -Duty (Tractor -Trailer) Greenhouse Gas Regulation, Periodic Smoke Inspection Program, and the Statewide Truck and Bus Regulation.
PDF-RC-2: Operational Energy Source Emissions Reductions Measures - The Project shall implement the following measures.
▪ The project shall be designed such that all buildings with occupied rooms shall have some form of daylighting (e.g. skylights or windows) each building features skylights that cover a minimum of 3% of the total roof area of the Project.
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▪ Photovoltaic infrastructure shall be provided on the rooftops of project buildings in accordance with the proposed land use. Industrial/warehouse buildings shall provide a minimum 3% of the total roof area for photovoltaic arrays at building construction. All other proposed land uses shall provide a minimum 1 0% of the total roof area for photovoltaic arrays at building construction. such that a minimum of 25% of the total roof area of the project includes photovoltaic arrays at Project buildout. Project buildings shall include an electrical system and other infrastructure sufficiently sized to accommodate the potential installation photovoltaic arrays in the future up to 50% of the total roof area of the project. The electrical system and infrastructure must be clearly labeled with noticeable and permanent signage which informs future occupants/owners of the existence of this infrastructure. ▪ Project building plans shall specify that all fixtures installed in restrooms and employee break areas shall be U.S. Environmental Protection Agency (EPA) Certified WaterSense or equivalent. ▪ Project building plans shall specify that all heating, cooling, lighting, and appliance fixtures installed be Energy Star -rated. Information on energy efficiency, energy -efficient lighting and lighting control systems, energy management, and existing energy incentive programs shall be provided to future tenants of the project.
▪ Prior to the issuance of permits that would allow the installation of landscaping, the City of Chula Vista shall review and approve landscaping plans for the site that require: (1) a plant palette emphasizing drought -tolerant plants; (2) use of water -efficient irrigation techniques; and (3) sufficient shade trees are provided so that at least 30% of the automobile parking areas will be shaded within 15 years after project construction is complete (excluding the truck courts where trees cannot be planted due to interference with truck maneuvering). The City of Chula Vista shall inspect for adherence to these requirements after landscaping installation. ▪ Structures shall be equipped with outdoor electric outlets in the front and rear of the structures to facilitate use of electrical lawn and garden equipment.
Noise Project Design Features
PDF-Noise Best Practices (NBP) -1: The following is a list of best practices for limiting construction noise that would be implemented by the contractor:
▪ The project contractor will, to the extent feasible, schedule construction activities to avoid concurrent operation of several pieces of construction equipment proximate to an offsite noise-sensitive receptor.
▪ All construction equipment, fixed or mobile, will be equipped with properly operating and maintained mufflers.
▪ Construction noise reduction methods such as shutting off idling equipment, maximizing the distance between construction equipment staging areas and adjacent residences, and use of electric air compressors and similar power tools, rather than diesel equipment, will be used where feasible.
▪ Construction hours, allowable workdays, and the phone number of the job superintendent shall be clearly posted at all construction entrances to allow surrounding property owners to contact the job superintendent if necessary. In the event the City receives a complaint, appropriate corrective actions will be implemented and a report of the action provided to the reporting party. 4 – PROJECT DESCRIPTION
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General Project Design Features
PDF-Building Materials: All proposed buildings should be constructed with high -quality and durable building materials to minimize the replacement costs and construction waste that result from periodic renovations. Where possible, developments should incorporate materials with recycled content to divert the amount of waste generated by construction and demolition.
PDF-Interior Finishes: Developments are encouraged to use regional materials (locally harvested, manufactured and/or appropriate to local climate) and rapidly renewable materials for interior finishes.
PDF-Reduction in Ambient Temperatures: 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 temperatures and solar heat gain on constructed surfaces.
PDF-Exterior Lighting: Exterior lighting will should be directed and designed to prevent direct glare into adjacent dwelling units and onto neighboring uses/ properties.
PDF-Weather Resistance: All buildings should be designed to increase shade and to protect residents from wind, sun, and rain with architectural features (such as, recessed windows and entrances).
PDF-Building Materials: New construction should incorporate non -polluting and non -toxic materials and finishes with zero or low volatile organic compounds (VOCs).
PDF-Noise Attenuation: Insulating materials and landscaping should be used to attenuate the noises generated within and outside the project site.
PDF- Landscape Water: To maximize water efficiency, new landscape designs will 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 California-friendly plants, shrubs and trees is also encouraged.
PDF-Organic Waste Reduction: Landscapes within the Specific Plan area shall incorporate the use of certified compost and mulch in accordance with SB1383 regulations for organic waste reduction.
PDF-Construction Energy Use: The project will provide temporary electricity to the project site during the building construction phases and prohibit the use of diesel-fueled/natural gas fueled generators during the building construction phases.
PDF-EV Parking: The project will provide electric vehicle and bicycle parking. 4 – PROJECT DESCRIPTION
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5 Environmental Analysis
The following sections analyze the potential environmental impacts that may occur as a result of implementation of the proposed Rohr Wohl Specific Plan Project (proposed project or project). Each issue analysis section includes a description of existing conditions, regulatory setting, the criteria for the determination of impact significance, evaluation of potential project impacts including mitigation measures (if applicable), and a conclusion of significance after mitigation for impacts identified as requiring mitigation (if applicabl e).
The environmental issues addressed in this chapter include the following:
▪ Aesthetics
▪ Air Quality
▪ Biological Resources
▪ Cultural and Tribal Cultural Resources
▪ Energy
▪ Geology and Soils
▪ Greenhouse Gas Emissions
▪ Hazards and Hazardous Materials
▪ Hydrology and Water Quality
▪ Noise
▪ Land Use and Planning
▪ Population and Housing
▪ Public Services
▪ Recreation
▪ Transportation
▪ Utilities and Service Systems
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5.1 Aesthetics
This section describes the existing visual conditions of the Rohr Wohl Specific Plan Project (project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the proposed project.
5.1.1 Existing Conditions
5.1.1.1 Regulatory Framework
Federal
There are no federal regulations relevant to aesthetics for this project.
State
California Scenic Highway Program
The California Scenic Highway Program was created in 1963 with the intent “to protect and enhance the natural scenic beauty of California highways and adjacent corridors, through special conservation treatment” (Caltrans 2020). The state laws that govern the Scenic Highway Program are Sections 260 through 263 of the Streets and Highways Code. A highway may be designated scenic based on the natural landscape visible by travelers, the scenic quality of the landscape, and the extent to which development intrudes upon the views of the highway. The Scenic Highway Program includes both officially designated scenic highways and highways that are eligible for designation.
It is the responsibility of local jurisdictions to apply for scenic highway approval, which req uires the adoption of a Corridor Protection Program (Caltrans 2020). In addition, once a scenic highway is designated, the local jurisdiction is responsible for regulating development within the scenic highway corridor.
The nearest officially designated scenic highway, State Route 75, is across San Diego Bay and approximately 2.2 miles west/southwest of the project site. The nearest eligible state scenic highway, State Route 75 from Interstate 5 (I-5) west to the Coronado /Imperial Beach border, is approximately 2.9 miles southwest of the project site (Caltrans 2020).
Local
City of Chula Vista General Plan
The City of Chula Vista General Plan contains objectives and policies to preserve and enhance aesthetic resources.
Specifically, the Land Use and Transportation Element includes policies that strive to protect Chula Vista’s open space network and contains design policies for features such as view s, entryways, gateways, streetscapes, buildings, parks, and plazas. In addition to Scenic Roadways, the General Plan identifies valued scenic vistas and open space throughout Chula Vista, as discussed under the “Scenic Resources and Scenic Vistas” subheading in this section. Marina Parkway is a designated scenic roadway in the General Plan (City of Chula Vista 2005).
As of the January 2024 site visit, a portion of the southern Project site boundary fence was affixed with vinyl screening fabric that limited overall visibility to the project site as experienced from the intersection of Marina Parkway and H Street. In addition, the presence of existing fencing and parked vehicles on the elevated, graveled
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lot to the south of the Project site generally blocks or obstructs the project site from view of northbound motorists on Marina Parkway as they pass alongside the Marina and approach H Street. While the vinyl screen fencing along the Project site and cons truction staging use of the nearby lot to the south are temporary features/conditions in the landscape, t he project site will continue to have limited visibility from Marina due to future foreseeable development of Hotel/Office, Residential, Retail, and Hotel/Cultural Retail uses along the Marina Parkway corridor between Interstate 5 and H Street as envisioned in the Chula Vista Bayfront Master Plan.
Land Use and Transportation Element
The project site is designated for General Industrial use (City of Chula Vista 2005).
The General Plan contains the following objectives and policies relevant to the proposed project relative to aesthetics (City of Chula Vista 2005):
▪ Policy LUT 6.3. Require that the design of new residential, commercial, or public developments is sensitive to the character of existing neighborhoods through consideration of access, compatible building design and massing, and building height transitions, while maintaining the goals and values set forth in the General Plan. Within TFAs [Transit Focus Areas] , design provisions should include requirements for a minimum building stepback of 15 feet for every 35 feet in height, for edges abutting residential uses. ▪ Policy LUT 6.5 . Require, through sensitive and attractive design, that neighborhood retail centers and commercial service buildings are compatible with the surrounding neighborhood. ▪ Policy LUT 8.3. Ensure that buildings are appropriate to their context and designed to be compatible with surrounding uses and enhance the desired character of their District. ▪ Policy LUT 9.1. Create consistent entry features for City entryways and gateways so people recognize that they are entering Chula Vista.
▪ Policy LUT 9.3. As part of the approval process for projects within designated City entryway/gateway areas, the City shall confirm that the design conforms to applicable entryway/gateway design guidelines and standards. ▪ Objective LUT 11. Ensure that buildings and related site improvements for public and private development are well-designed and compatible with surrounding properties and districts. ▪ Policy LUT 11.1. Promote development that creates and enhances positive spatial attributes of major public streets; open spaces; cityscape; mountain and bay sight lines; and important gateways into the City. ▪ Policy LUT 11.2. Promote and place a high priority on quality architecture, landscape, and site design to enhance the image of Chula Vista, and create a vital and attractive environment for businesses, residents, and visitors.
▪ Policy LUT 11.4. Actively promote architectural and design excellence in buildings, open space, and urban design
▪ Objective LUT 13. Preserve scenic resources in Chula Vista, maintain the City ’s open space network, and promote beautification of the City.
▪ Policy LUT 13.1. Identify and protect important public viewpoints and viewsheds throughout the Planning Area, including features within and outside the planning area, such as: mountain; native habitat areas; San Diego Bay; and historic resources.
▪ Policy LUT 13.3. Screen unsightly industrial properties on the Bayfront, or convert such properties to uses that are consistent with the desired visual character of the Bayfront. As described in Section 11.0 of this Element and the Bayfront Master Plan.
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[Note that the project site is outside of the land use plan boundaries of the Chula Vista Bayfront Master Plan.]
▪ Policy LUT 13.4. Any discretionary projects proposed adjacent to scenic routes, with the exception of individual single -family dwellings, shall be subject to design review to ensure that the design of the development proposal will enhance the scenic quality of the route. R eview should include site design, architectural design, height, landscaping, signage, and utilities. Development adjacent to designated scenic routes should be designed to:
– Create substantial open areas adjacent to scenic routes through clustering development; – Create a pleasing streetscape through landscaping and varied building setbacks; and – Coordinate signage, graphics and/or signage requirements, and standards.
Scenic Resources and Scenic Vistas
The General Plan identifies significant scenic resources and open space that help to define various area’s visual and community character within Chula Vista. Scenic vistas and open space identified in the General Plan include the Otay River and Sweetwater River Valleys , Upper and Lower Otay Lakes , Sweetwater Reservoir , San Miguel/Mother Miguel Mountains, and the San Diego Bay (City of Chula Vista 2005). These open space areas make up the majority of the Chula Vista Greenbelt, the backbone of Chula Vista’s open space and park system, which consists of a 28 -mile-long open space system encircling Chula Vista ( City of Chula Vista 2003a ). The Greenbelt includes Multiple Species Conservation Program Preserve lands (City of Chula Vista 2003 b), general open space, and existing and future trails, and connects several of Chula Vista’s existing and future public parks.
Additional natural open space areas within Chula Vista are identified in General Plan Figure 5 -5, Open Space Network (City of Chula Vista 2005) . The closest identified scenic vista and open space area to the project site is San Diego Bay, approximately 0.3 miles west of the project site.
Gateways
The General Plan identifies entryways and gateways that offer opportunities to improve Chula Vista ’s visual appearance and establish a community image through design treatments such as signage, landscap ing, and architectural design enhancements. The City of Chula Vista designates both Primary and Secondary Gateways.
Primary Gateways are from freeways and should appear visually inviting, provide adequate direction to places of interest, and have high-quality design features (City of Chula Vista 2005). Secondary Gateways are locations where a significant entry into the City occurs from an adjacent community and should provide travelers with a clear impression that they are entering the City (City of Chula Vista 2005).
Designated Primary Gateways with proximity to the project site include H Street and J Street (both from I-5 and to the west). There are no Secondary Gateways near the project site (City of Chula Vista 2005).
City -Designated Scenic Roadways
The City has designated several Scenic Roadways for their views of natural features and roadway characteristics, including enhanced landscaping, adjoining natural slopes, or special design features. Marina Parkway (from J Street to E Street) is the sole designated scenic roadway near the project site (City of Chula Vista 2005).
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City of Chula Vista Municipal Code
While the project site is designated for General Industrial use, the project proposes a General Plan and Land Use Plan Amendment. The General Plan and Land Use Amendment would be processed concurrently with Specific Plan adoption and change the existing I-G (General Industrial) 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).
Light and glare are regulated by Chapter 17.28 and Section 19.66.100 of the Chula Vista Municipal Code , respectively. Chapter 17.28, Unnecessary Lights, is intended to prevent lighting from creating a nuisance by regulating the use of lighting in and around residential areas. The ordinance recognizes that lighting is widely used in commercial and industrial zones for the purpose of advertising and security , and that such lighting is essential to the conduct of many commercial and industrial enterprises. The ordinance requires that all light sources used for advertising, security, or safety purposes be arranged or shielded in such a manner as to not constitute a public nuisance for residential property owners (Section 17.28.020). Further, and as required by Section 17.28.040, all lighting plans in multiple-family, commercial, and industrial zones must be submitted to the Zoning Administrator for approval prior to installation. In addition, and as stipulated in Section 17.28.060, lighting from any use that is unshielded or focuses beams directly on adjacent residential property is prohibited at all times.
Section 19.66.100, Glare, prohibits direct or sky -reflected glare from floodlights and high-temperature processes that produce glare that is visible at the points of measurement, as specified in Section 19.66.060, Locations. Within the Industrial zone, the point of measurement is 500 feet from the establishment or use, or at any point within an adjacent zone other than an Industrial zone.
5.1.1.2 Existing Aesthetic Setting
On-Site Conditions
The project site consists of 44.8 acres 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 west of I-5, north of H Street, south of G Street, and east of Marina Parkway ; it is within the City of Chula Vista ’s Bayfront Planning Area (see Figure 4-1 in Chapter 4, Project Description, of this Environmental Impact Report).
As described in Chapter 4, Project Description, t he project site is divided into three separate planning areas (see Figure 4-2 in Chapter 4). 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 approximately 9.29 acres. The generally rectangular shaped area is developed and supports a long and rectangular (220 feet wide by 910 feet long), aged two -story industrial warehouse-type building (approximately 282,004 square feet) and a paved asphalt surface parking lot in its southerly, H Street – adjacent area. The cement building is clad in metallic and tan vertical siding along its easterly, second-story façade.
Along its west -facing elevation, a series of large openings are present where window backs and projecting rectangular overhangs have been recently removed. Mature, non-native trees (primarily eucalyptus) are clustered in pockets along the site’s eastern (i.e., adjacent to Bay Bou levard and its meandering sidewalk ) and western boundaries. Lastly, and as of a January 2024 field visit, the parking lot and south -facing elevation of the building were under active renovation, with new landscape areas being installed near H Street and a new building extension being added. See Figure 5.1-1, Existing Conditions: Planning Area A, for photographs of existing site conditions.
The largest planning area, Planning Area B-1, is 26.13 acres and is bound by Planning Area A on the east, Planning Area B-2 on the south, and Marina Parkway on the west. A portion of the site’s northern boundary is bound by
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G Street, with the remaining boundaries parallelling a private road (see Figure 4-2). As with adjacent Planning Area B--2 (that is 9.36 acres), Planning Area B -1 was previous developed with an expansive , two- to three-story aged, industrial warehouse-style building and ancillary facilities, but is currently vacant (previous on-site uses have been demolished and removed). As observed during the January 2024 field visit, the southern boundary of Planning Area B-2 is lined by a 6- to 7-foot-high chain-link fence to which sections of newer, black and older green vinyl screening fabric have been installed (the sections of green vinyl presented faded coloring and areas that had been torn and/or lifted by winds). A series of vehicles , including passenger trucks, backhoes, a water truck, and a small crane/lift bucket truck, were observed on site, as were several portable bathrooms, large (approximately 20 feet high) and long mounds of dirt, and assortment of low scattered debris. See Figure 5.1-2, Existing Conditions: Planning Areas B-2 and B-1, for photographs of existing site conditions as experienced from H Street.
Surrounding Land Uses
Land uses surrounding the project site include vacant properties, undeveloped and natural lagoon/wildlife refuge lands, the mostly active Collins Aerospace campus, a small SDG&E substation, the triangular Bay Boulevard Park (a pocket park), and the Seven Mile Casino (housed in a single-story structure with several curved metal projections generally located above the ground-floor windows) to the north; a commercial building (currently housing The Galley restaurant), the Chula Vista Marina, and future development associated with the Chula Vista Bayfront Master Plan to the southwest and south; Bay Boulevard and I-5 to the east; and the under-construction Gaylord Pacific Resort Hotel and Convention Center to the west. See Figure 5.1-3, Existing Conditions: Surrounding Area, which shows the commercial uses and parking at the marina , and the under -construction resort hotel. Previously disturbed and gently sloping lands south of the project site, H Street, and its adjacent two-lane bike path are currently surfaced in gravel and are used for parking by construction personnel working on the in-progress Gaylord Pacific Resort Hotel and Convention Center (see Figure 5.1-4, Existing Conditions: Surrounding Area) . As shown in Figure 5.1-3, the rectangular convention center structure and expansive 22-story Gaylord Pacific Resort Hotel and Convention Center are under construction, and as of January 2024, metallic and cement structural systems remained exposed on the hotel (some exterior paneling and windows had been installed on the south- and east-facing hotel exteriors), and two large cranes were present on site. A temporary, gravel-surfaced construction staging area populated by a series of grey and modular, single -story trailers is located south of the convention center site (see Figure 5.1-4).While present at the time of January 2024 site visit, the two large cranes are temporary features in the landscape and will be removed once construction of the Gaylord Pacific Resort Hotel and Convention Center is completed in approximately Spring 2025 (Port of San Diego 2024) . Also, the graveled surfaced construction staging area referenced above is a temporary use and is ident ified as future space for Hotel/Cultural Retail uses in the Chula Vista Bayfront Master Plan (Port of San Diego 2024).
Scenic Vistas
As described in Section 5.1.1.1, Regulatory Framework, the closest General Plan–identified scenic vista and open space area to the project site is San Diego Bay , approximately 0.3 mile s west of the project site. Views to the San Diego Bay are not available from the project site due to existing adjacent development associated with the Gaylord Pacific Resort Hotel and Convention Center (vertical hotel and related development tends to block westerly views, including San Diego Bay views , from the project site). Views to San Diego Bay are also not available from H Street between Bay Boulevard and Marina Parkway (i.e., segment of H Street that parallels the project site).
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Scenic Highways
Marina Parkway (from J Street to E Street) is the sole locally designated scenic roadway in the project area. As of the January 2024 field visit, the segment of Marina Parkway north of H Street is closed (and has been demolished) to accommodate construction of the Gaylord Pacific Resort Hotel and Convention Center. Currently and as of January 2024, the project site has limited visibility from Marina Parkway , with the exception of the approximately 315-foot-long northbound segment from Sandpiper Way to H Street. Available views to northbound road users along this segment consist of the under-construction Gaylord Pacific Resort Hotel and Convention Center, the hotel and convention center construction staging site (bound by Sandpiper Way on the south and Marina Parkway on the east), and the slightly elevated and graveled lot south of H Street and east of Marina Parkway that is currently used for construction parking. The vinyl-fabric and chain-link fencing installed along the southern boundary of the project site is also visible from the Marina Parkway/H Street intersection.
As under-construction uses are completed and the Chula Vista Bayfront is built out, Marina Parkway is anticipated to continue to provide limited views to the project site. In addition to the future Hotel/Cultural Retail uses described above that will be lo cated south of the project site, Chula Vista Bayfront Master Plan envisions Hotel/Office, Residential, and Retail uses along the Marina Parkway corridor from Interstate 5 to H Street and these uses would potentially obstruct or interrupt potential views to the project site.
Light and Glare
Limited sources of lighting and glare from existing uses are located within the boundaries of Planning Area A and are associated with the existing on -site structure. Lighting elements and support poles previously located in the Planning Area A parking lot (near H Street and in the southern portion of the site) had been removed prior to the January 2024 field visit; however, observations made during the field visit indicate that the redesigned parking lot would include overhead lighting installed at regular intervals. Because Planning Areas B-1- and B-2 are vacant and previous development including outdoor lighting elements has been demolished and removed, there are currently no stationary sources of permanent light or glare in these areas. Streetlights are installed along H Street and Marina Parkway south of H Street; the segment north of H Street is closed and currently contains no streetlights. While lighting is not installed in the construction parking lot located south of the project site and H Street, and lights were not observed in the construction staging area on Marina Parkway and south of the convention center, future uses on the current staging area site would include outdoor lighting typical of Hotel and Retail spaces. Lighting is installed in the Marina parking lot off of Marina Parkway. In addition to providing lighting for general illumination and security, the lighting elements listed above are potential sources of glare ; however, the described elements are generally shielded and directed downward. Thus, these existing lighting sources are not a substantial source of potential glare in the surrounding area.
Viewers
Groups provided views to the project site are generally limited to motorists on local area roads, including H Street, Bay Boulevard, and Marina Parkway; cyclists on the H Street –adjacent bike path and the nearby segments of the Bayshore Bikeway; and Marina visitors (in particular, those in the public parking lot adjacent to Marina Parkway).
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5.1.2 Thresholds of Significance
The significance criteria used to evaluate the project ’s impacts to aesthetics 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 aesthetics would occur if the project would:
1. Have a substantial adverse effect on a scenic vista.
2. Substantially damage scenic resources including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.
3. In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings. (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, conflict with applicable zoning and other regulations governing scenic quality.
4. Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.
5.1.3 Impacts
Two visual simulations of the Project as experienced from publicly accessible vantage points in the surrounding area were prepared to aid in the assessment of potential impacts to existing views and visual character. The selected vantage points are representative viewpoints available to viewer groups in the local area that offer clear views to the Project site. The viewpoints are located on northbound H Street and the southbound lane of the public bike path that paral lels H Street near the Project site. Existing photographs from the selected viewpoints are presented as Figure 5.1-5a, View 1: Northbound H Street looking northeast towards Project site (Existing Conditions) and Figure 5.1 -6a, View 2: Southbound on H Street Bike Path looking northwest towards Project site and active construction (Existing Conditions). Visual simulations of the Project with and without development on Planning Area B-2 as experienced from these viewpoints are presented on Figure 5.1 -5b, View 1: Northbound H Street looking northeast towards Project site (Proposed Conditions) and Figure 5.1-6b, View 2: Southbound on H Street Bike Path looking northwest towards Project site and active construction (Proposed Conditions) . The “without development on Planning Area B -2” scenario is depicted in visual simulations to account for delayed (i.e., 2028 start date) construction on this site and the approximate two year period (2026-2028) between which Planning Area B-1 would be built out and development would operate prior to start of construction on Planning Area B-2.
Would the project have a substantial adverse effect on a scenic vista? The project includes rezones and a general plan amendment, no part of which would conflict with the rules governing scenic quality. To the extent they address scenic quality, they are discussed below.
The project site is in the City’s Bayfront Planning Area , and the closest General Plan–identified scenic vista to the project site is San Diego Bay. Although only approximately 0.3 miles to the west, public views to San Diego Bay are not available from the project site; or from nearby mobile vantage points including Bay Boulevard or H Street (see Figure 5.1-1 that shows views of the project site from an adjacent segment of H Street. Also and as demonstrated in the captured westerly view from H Street presented on Figure 5.1-1, views to the San Diego Bay are not available across the Project site due to the presence of the 22-story Gaylord Pacific Resort Hotel and Convention Center (and parking structure) that are located to the south of the Project site and effectively block elements located further south (including the San Diego Bay) from view. Implementation of the Specific Plan and construction and operation
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of potential future commercial, industrial, technology, and business park development in Planning Areas A (maximum permitted building height of 80 feet) , B-1 (maximum permitted building height of 45 feet) , and B -2 (maximum permitted building height of 60 feet) would not result in blockage or substantial interruption of existing available views to San Diego Bay from H Street or other local roads. While potential future development of structures on the site would be visible from H Street and other local roads , the presence of existing development in the immediate vicinity and specifically, to the south of the Project site including the 22 -story Gaylord Pacific Resort Hotel and Convention Center effectively blocks the San Diego Bay from view of the nearest public roads to the east and south of the Project site. Therefore, i mpacts to scenic vistas from H Street and Bay Boulevard would be less than significant.
Marina Parkway (from J Street to E Street) is the sole locally designated scenic roadway in the project area. Although views to San Diego Bay are occasionally available from Marina Parkway (brief views to the Bay are available through gaps in existing trees from approximately Bay Boulevard west to Marina Way; a distance of approximately
0.22 miles), from north of Marina Way, views to the Bay are blocked by street trees, trees planted in and around marina parking lots, docked boats at the marina, and single -story buildings at the marina. On the northbound approach to Sandpiper Way and at the Marina Parkway/H Street intersection, westerly views toward the San Diego Bay are more constrained and fully blocked by single -story construction staging trailers ; vinyl-covered chain-link fencing; and the under-construction, 22-story Gaylord Pacific Resort Hotel and Convention Center. See Figure 5.1-
3. Marina Parkway is currently closed and demolished between H Street and G Street, and as experienced from the intersection of Marina Parkway and H Street, the project site is to the northeast. From the “open” segment of Marina Parkway from G Street north to Lagoon Drive, the project site is to the southeast. 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 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. Impacts would be less than significant.
Would the project substantially damage scenic resources, including, but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway?
The project site does not contain natural or built scenic resources. Planning Area A supports an aged two -story industrial warehouse–type building and a paved asphalt surface parking lot. Although modifications to the parking lot are currently underway, the existing warehouse -type building is not proposed for removal or substantial alteration. Planning Areas B -1 and B -2 were previously developed with large two - to three -story industrial warehouse–style building and ancillary facilities; however, these struc tures have been recently demolished. The areas are currently vacant and present as a large dirt lot supporting (on occasion) construction vehicles and stockpiles of dirt. The project site is also not readily visible from a state scenic highway because the nearest state scenic highway (State Route 75) is across San Diego Bay and approximately 2.2 miles west/southwest of the project site. Because 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, no impacts to views from a state scenic highway would occur.
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Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Implementation of the Specific 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 result in the introduction of numerous sources of lighting and glare to the previously development but currently vacant (and recently demolished) project site. During construction, on-site activities within the three Planning Areas would comply with Section 19.68 (Performance Standards and Noise Control) of the City’s Code of Ordinance. During the approximate 5-year construction period, activities , including site preparation, grading, building construction, paving, and architectural coating, would generally occur during daylight hour. However, during winter months and assuming construction contractors elect to work beyond sunset and till 7:00 p.m., the use of mobile lighting may be required.
During potential future use of lighting during construction, the frequency of nighttime lighting use would be limited, the duration of use would typically be brief, and the location of lighting would be limited to areas of active construction (i.e., illumination of the entirety of the project site and/or individual planning areas would not occur).
In addition, lighting would typically be directed downward and shielded so as to not result in unnecessary skyglow or substantial light trespass onto neighboring properties. Further and consistent with the City’s Multiple Species Conservation Program Subarea Plan Agency Management Issues (City of Chula Vista 2003b) , the project would implement best management practices to protect preserve lands and sensitive species from construction night lighting. In addition, the project site encompasses industrial lands within the City’s Bayfront Planning Area, and the nearest residential uses are east of the site and east of I-5. Based on the distance from light sources operating on the project site and the proposed frequency and duration of use, temporary lighting during construction would not result in substantial light or glare such that nighttime views in the area would be substantially affected. Thus, lighting and glare impacts during construction of potential future commercial, industrial, technology, and busi ness park development would be less than significant.
Development and operation of potential future commercial, industrial, technology, and business park uses in Planning Areas A, B-1, and B-2 would result in additional lighting sources on the project site, and more generally, in the Bayfront Planning Area. Although specific lighting plans and schedules have not been prepared, the project site is likely to support lighting and potential glare sources typical of commercial, industrial, and business park development. For example, site lighting would likely inclu de entry monument and signage at the project site entrance off H Street ; parking lot lighting ; illuminated building fascia signage on commercial uses/buildings ; exterior-mounted lighting on buildings ; and lighting in paseos, greenways, courtyards, common areas, and pedestrian paths. Although buildout of the project site is likely to result in an increase in lighting sources on the project site compared to the prior industrial warehouse that was recently demolished, new exterior lighting sources would be directed downward and designed to prevent direct glare onto neighboring uses/properties (see PDF-4 in Chapter 4, Project Description) and on more distant refuge lands north and northwest of the project site (i.e., Planning Area B-1). Exterior lighting sources would also generally be shielded so as to minimize the potential for received glare and uplighting/skyglow, and to ensure consistency with the City’s Multiple Species Conservation Program Subarea Plan Agency Management Issues (Lighting) (City of Chula Vista 2003b). All lighting for project site operations would provide adequate shielding to protect preserve lands and sensitive species from night lighting. In addition, lighting sources associated with future development on the project site would operate in a largely developed area consisting of existing industrial warehouses and business park/technology development/structures, and an under -construction, large-scale hotel and adjacent convention center that will include numerous exterior lighting fixtures/sources to support overall site programming and uses. Based on the analysis presented above, exterior lighting installed on the project site to support operations would not adversely affect nighttime views in the area. Impacts would be less than significant.
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The potential for new site lighting to produce substantial glare that could adversely affect nighttime views is addressed above (impacts would be less than significant). Regarding future site development, building materials, and other sources of potential glare, design of future development would be carried out in compliance with the design guidelines established in the Rohr Wohl Specific Plan. Specific to building materials, Chapter 8, Design Guidelines, of the Rohr Wohl Specific Plan requires that buildin g finishes be non-reflective, use of reflective glass is restricted, and mirrored glass is prohibited (see Section 8-B of the Rohr Wohl Specific Plan [Appendix B]). Because future development on the project site would incorporate non-reflective finishes, include restricted use of reflective glass, and would not include use of mirrored glass, potential future commercial, industrial, technology, and business park development would not result in substanti al glare that would adversely affect daytime views in th e area.
Impacts would be less than significant.
5.1.4 Level of Significance Prior to Mitigation
Impacts related to aesthetics would be less than significant.
5.1.5 Mitigation Measures
No mitigation measures would be required.
5.1.6 Level of Significance After Mitigation
No mitigation measures would be required. Impacts related to aesthetics would be less than significant.
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Path Z \Projects\j1454101\MAPDOC\DOCUMENT\EIR\Asthetics FIGURE 5.1-1
Existing Conditions: Planning Area A
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View north from H Street to existing development on Planning Area AView west from H Street near Planning Area A
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Existing Conditions: Planning Areas B-2 and B-1
Rohr Wohl Specific Plan
FIGURE 5.1-2
Path Z \Projects\j1454101\MAPDOC\DOCUMENT\EIR\Asthetics View northeast from H Street towards Planning Area B-2 View northwest from H Street Bike Path looking towards Planning Areas B-2 and B-1
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Existing Conditions: Surrounding Area
Rohr Wohl Specific Plan
FIGURE 5.1-3
Path Z \Projects\j1454101\MAPDOC\DOCUMENT\EIR\Asthetics View southwest from Marina Parkway towards Chula Vista Marina View northwest from Marina Parkway at Sandpiper Way towards under construction Gaylord Pacific Resort Hotel
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Existing Conditions: Surrounding Area
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FIGURE 5.1-4
Path Z \Projects\j1454101\MAPDOC\DOCUMENT\EIR\Asthetics View east from H Street bike path towards construction parking lot to south of Project site
View south from Bay Boulevard near G Street towards under construction site, existing substation, under construction parking structure and 22-story resort hotel
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View 1: Northbound H Street looking northeast towards Project site (Proposed Conditions) Rohr Wohl Specific Plan
FIGURE 5.1-5b
Path Z \Projects\
Visual Simulation of Future Site Development (no development on Planning Area B-2) Visual Simulation of Future Site Development (development shown on Planning Area B-2)
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View 2: Southbound on H Street Bike Path looking northwest towards Project site and active construction (Existing Conditions) Rohr Wohl Specific Plan
FIGURE 5.1-6a
Path Z \Projects\j1454101\MAPDOC\DOCUMENT\EIR\Asthetics
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View 2: Southbound on H Street Bike Pathlooking northwest towards Project site and active construction (Proposed Conditions) Rohr Wohl Specific Plan
FIGURE 5.1-6b
Path Z \Projects\
Visual Simulation of Future Site Development (no development on Planning Area B-2) Visual Simulation of Future Site Development (development shown on Planning Area B-2)
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5.2 Air Quality
This section describes existing conditions, identifies associated regulatory requirements, evaluates potential air quality 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 Air Quality and Greenhouse Gas Emissions Technical Report prepared for the project by Dudek in August 2024. The complete report is contained in Appendix C of this EIR.
5.2.1 Existing Conditions
5.2.1.1 Regulatory Framework
Federal
Criteria Air Pollutants
The federal Clean Air Act (CAA), passed in 1970 and last amended in 1990, forms the basis for the national air pollution control effort. The U.S. Environmental Protection Agency ( EPA) is responsible for implementing most aspects of the Clean Air Act (CAA), including the setting of National Ambient Air Quality Standards (NAAQS) for major air pollutants, hazardous air pollutant (HAP) standards, approval of state attainment plans, motor vehicle emission standards, stationary source emission standards and permits, acid rain control measures, stratospheric ozone (O3) protection, and enforcement provisions.
NAAQS are established by the EPA for “criteria pollutants” under the CAA, which are O 3, carbon monoxide ( CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), coarse particulate matter ( PM10), fine particulate matter ( PM2.5), and lead. The NAAQS describe acceptable air quality conditions designed to protect the health and welfare of the citizens of the nation. The CAA requires the EPA to reassess the NAAQS at least every 5 years to determine whether adopted standards are adequate to protect public health based on current scientific evidence. States with areas that exceed the NAAQS must prepare a state implementation plan (SIP) that demonstrates how those areas will attain the standards within mandated time frames.
Hazardous Air Pollutants
The 1977 CAA Amendments required the EPA to identify national emission standards for hazardous air pollutants to protect the public health and welfare. HAPs include certain volatile organic chemicals, pesticides, herbicides, and radionuclides that present a tangible hazard, based on scientific studies of exposure to humans and other mammals. Under the 1990 CAA Amendments, which expanded the control program for HAPs, 189 substances and chemical families were identified as HAPs.
State
Criteria Air Pollutants
The California Clean Air Act was adopted in 1988 and establishes the state’s air quality goals, planning mechanisms, regulatory strategies, and standards of progress. Under the California Clean Air Act, the task of air quality management and regulation has been legislatively granted to CARB, with subsidiary responsibilities assigned to air quality management districts and air pollution control districts at the regional and county levels. CARB is
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Idling of Commercial Heavy -Duty Trucks (13 CCR 2485)
In July 2004, CARB adopted an Airborne Toxic Control Measure (ATCM) to control emissions from idling trucks. The ATCM prohibits idling for more than 5 minutes for all commercial trucks with a gross vehicle weight rating over 10,000 pounds.
The ATCM contains an exception that allows trucks to idle while queuing or involved in operational activities.
In-Use Off -Road Diesel -Fueled Fleets (13 CCR 2449 et seq.) In July 2007, CARB adopted an ATCM for in-use off-road diesel vehicles. This regulation requires that specific fleet average requirements be met for NOx emissions and for particulate matter emissions. Where average requirements cannot be met, Best Available Control Technology requirements apply. The regulation also includes several recordkeeping and reporting requirements.
In response to AB 8 2X, the regulations were revised in July 2009 (effective December 3, 2009) to allow a partial postponement of the compliance schedule in 2011 and 2012 for existing fleets. On December 17, 2010, CARB adopted additional revisions to further delay the deadlines, reflecting reductions in diesel emissions due to the poor economy and overestimates of diesel emissions in California. The revisions delayed the first compliance date until no earlier than January 1, 2014, for large fleets, with fin al compliance by January 1, 2023. The compliance dates for medium fleets were delayed until an initial date of January 1, 2017, and a final compliance date of January 1, 2023. The compliance dates for small fleets were delayed until an initial date of January 1, 2019, and a final compliance date of January 1, 2028. Correspondingly, the fleet average targets were made more stringent in future compliance years. The revisions also accelerated the phaseout of equipment with older equipment added to existing large and medium fleets over time, requiring the addition of Tier 2 or higher engines starting on March 1, 2011, with some exceptions: Tier 2 or higher engines on January 1, 2013, without exception; and Tier 3 or higher engines on January 1, 2018 (January 1, 2023, for small fleets).
On October 28, 2011 (effective December 14, 2011), the Executive Officer approved amendments to the regulation. The amendments included revisions to the applicability section and additions and revisions to the definitions. The initial date for requiring th e addition of Tier 2 or higher engines for large and medium fleets, with some exceptions, was revised to January 1, 2012. New provisions also allow for the removal of emission control devices for safety or visibility purposes. The regulation also was amend ed to combine the particulate matter and NOx fleet average targets under one, instead of two, sections. The amended fleet average targets are based on the fleet’s NOx average, and the previous section regarding particulate matter performance requirements was deleted completely. The Best Available Control Technology requirements, if a fleet cannot comply with the fleet average requirements, were restructured and clarified. Other amendments to the regulations included minor administrative changes to the regulatory text.
In-Use On -Road Diesel -Fueled Vehicles (13 CCR 2025)
On December 12, 2008, CARB adopted an ATCM to reduce NOx and particulate matter emissions from most in-use on-road diesel trucks and buses with a gross vehicle weight rating greater than 14,000 pounds. The original ATCM regulation required fleets of on -road trucks to limit their NOx and particulate matter emissions through a combination of exhaust retrofit equipment and new vehicles. The regulation limited particulate matter emissions for most fleets by 2011, and limited NOx emissions for most fleets by 2013. The regulation did not require any vehicle to be replaced before 2012 and never required that all vehicles in a fleet be replaced.
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In December 2009, the CARB Governing Board directed staff to evaluate amendments that would provide additional flexibility for fleets adversely affected by the poor California economy. On December 17, 2010, CARB revised this ATCM to delay its implementation along with limited relaxation of its requirements. Starting on January 1, 2015, lighter trucks with a gross vehicle weight rating of 14,001 to 26,000 pounds with 20-year-old or older engines need to be replaced with newer trucks (2010 model year emissions equivalent, as defined in the regulation). Trucks with a gross vehicle weight rating greater than 26,000 pounds with 1995 model year or older engines needed to be replaced as of January 1, 2015. Trucks with 1996–2006 model year engines must install a Level 3 (85% control) diesel particulate filter starting on January 1, 2012, to January 1, 2014, depending on the model year, and then must be replaced after 8 years. Trucks with 2007–2009 model year engines have no requirements until 2023, at which time they must be replaced with 2010 model year emissions equivalent engines, as defined in the regulation.
Trucks with 2010 model year engines would meet the final compliance requirements. The ATCM provides a phase- in option under which a fleet operator would equip a percentage of trucks in the fleet with diesel particulate filters, starting at 30% as of January 1, 2012, with 100% by January 1, 2016. Under each option, delayed compliance is granted to fleet operators who have complied or will comply with requirements before the required deadlines.
On September 19, 2011 (effective December 14, 2011), the Executive Officer approved amendments to the regulations, including revisions to the compliance schedule for vehicles with a gross vehicle weight rating of 26,000 pounds or less to clarify that all vehicles must be equipped with 2010 model year emissions equivalent engines by 2023. The amendments included revised and additional credits for fleets that have downsized; implemented early particulate matter retrofits; incorporated hybrid vehicles, alternative-fueled vehicles, and vehicles with heavy-duty pilot ignition engines; and implemented early addition of newer vehicles. The amendments included provisions for additional flexibility, such as for low-usage construction trucks, and revisions to previous exemptions, delays, and extensions. Other amendments to the regulations included minor administrative changes to the regulatory text, including recordkeeping and reporting requirements related to other revisions.
California Health and Safety Code Section 41700
Section 41700 of the California Health and Safety Code states that a person shall not discharge from any source whatsoever quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or that endanger the comfort, repose, health, or safety of any of those persons or the public, or that cause, or have a natural tendency to cause, injury or damage to business or property. This section also applies to sources of objectionable odors.
Local
San Diego Air Pollution Control District
While CARB is responsible for the regulation of mobile emission sources within the state, local air quality management districts and air pollution control districts are responsible for enforcing standards and regulating stationary sources. The project site is located within the SDAB, which is under the jurisdiction of the SDAPCD, and is therefore, subject to the guidelines and regulations of SDAPCD. Federal and State attainment plans adopted by the SDAPCD are summarized below.
Federal Attainment Plans
SDAPCD has prepared the 2020 Plan for Attaining the National Ambient Air Quality Standards for Ozone in San Diego County (2020 Attainment Plan) that demonstrates how the region will further reduce air pollutant
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emissions to attain the current NAAQS for ozone. The 2020 Attainment Plan was approved by the SDAPCD on October 14, 2020. On November 19, 2020, CARB adopted the 2020 Attainment Plan for attaining the Federal 8-hour 75 ppb and 70 ppb Ozone standards and projects attainment for the standards by 2026 and 2032, respectively (SDAPCD 2020a). The 2020 Attainment Plan will be submitted to the EPA as a revision to the California State Implementation Plan (SIP) for attaining the ozone NAAQS.
In December 2016, the SDAPCD adopted an update to the Eight-Hour Ozone Attainment Plan for San Diego County (2008 O 3 NAAQS). The 2016 Final Eight -Hour Ozone Attainment Plan for San Diego County indicates that local controls and state programs would allow the region to reach attainment of the federal 8 -hour O3 standard (1997 O3 NAAQS) by 2018 (SDAPCD 2016a). In this plan, SDAPCD relies on the Regional Air Quality Strategy (RAQS) to demonstrate how the region will comply with the federal O3 standard. The RAQS details how the region will manage and reduce O 3 precursors (NO x and VOCs) by identifying measures and regulations intended to reduce these pollutants. The control measures identified in the RAQS generally focus on stationary sources; however, the emissions inventories and projections in the RAQS address all potential sources, including those under the authority of CARB and EPA. Incentive programs for reduction of emissions from heavy -duty diesel vehicles, off -road equipment, and school buses are also established in the RAQS.
Currently, the County is designated as moderate nonattainment for the 2008 O 3 NAAQS and maintenance for the 1997 O3 NAAQS. As documented in the 2016 Final Eight -Hour Ozone Attainment Plan for San Diego County, the County has a likely chance of obtaining attainment due to the transition to low emission cars, stricter new source review rules, and continuing the requireme nt of general conformity for military growth and the San Diego International Airport. SDAPCD will also continue emission control measures inc luding ongoing implementation of existing regulations in ozone precursor reduction to stationary and area -wide sources, subsequent inspections of facilities and sources, and the adoption of laws requiring Best Available Retrofit Control Technology for cont rol of emissions (SDAPCD 2016a).
State Attainment Plans
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 2021a).
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 NOx and VOC. The 2022 RAQS emphasizes O3 control measures but also identifies complementary measures and strategies th at can reduce emissions of Greenhouse Gases (GHGs) and PM. It also includes new analyses exploring O3 and its relationship to public health, mobile sources, under-resourced communities, and GHGs and climate change (SANDAG 2023). Further, the 2022 RAQS identifies strategies to expand SDAPCD regional partnerships, identify more opportunities to engage the
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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 PM2.5) (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).
SDAPCD Rules and Regulations
As stated previously, SDAPCD is responsible for planning, implementing, and enforcing federal and state ambient standards in the SDAB. The following rules and regulations apply to all sources in the jurisdiction of SDAPCD:
▪ SDAPCD Regulation II: Rule 10: Permits Required. Requires an Authority to Construct and Permit to Operate for new stationary sources of air pollution (SDAPCD 1996). ▪ SDAPCD Regulation IV: Prohibitions; Rule 50: Visible Emissions. Prohibits any activity causing air contaminant emissions darker than 20% opacity for more than an aggregate of 3 minutes in any consecutive 60-minute time period. In addition, Rule 50 prohibits any diesel pile -driving hammer activity causing air contamina nt emissions for a period or periods aggregating more than 4 minutes during the driving of a single pile (SDAPCD 1997).
▪ SDAPCD Regulation IV: Prohibitions; Rule 51: Nuisance. Prohibits the discharge, from any source, of such quantities of air contaminants or other materials that cause or have a tendency to cause injury, detriment, nuisance, annoyance to people and/or the public, or damage to any business or property (SDAPCD 1976). ▪ SDAPCD Regulation IV: Prohibitions; Rule 55: Fugitive Dust. Regulates fugitive dust emissions from any commercial construction or demolition activity capable of generating fugitive dust emissions, including active operations, open storage piles, and inactive disturbed areas, as well as track-out and carry-out onto paved roads beyond a project site (SDAPCD 2009).
▪ SDAPCD Regulation IV: Prohibitions; Rule 67.0.1: Architectural Coatings. Requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC content of various coating categories (SDAPCD 2015).
▪ SDAPCD Regulation IV: Prohibitions; Rule 67.7: Cutback and Emulsified Asphalts. This rule prohibits manufacturers, distributors, and end users of cutback and emulsified asphalt materials for the paving, construction or maintenance of parking lots, driveways, streets and highways from applying asphalt material or road oils which conta in more than 0.5 percent by volume VOC which evaporate at 260º C (500º F) or less (SDAPCD 1979).
San Diego Association of Governments
SANDAG is the regional planning agency for the County and serves as a forum for regional issues relating to transportation, the economy, community development, and the environment. SANDAG serves as the federally designated metropolitan planning organization for the County. With respect to air quality planning and other regional
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issues, SANDA h s prepared San iego Fo war : The egional Plan (Regi nal Pl n) for he San Dieg regi n (S NDAG 20 5). The Reg ona Plan com ines he big pic ure v sion for how th region w ll ro over the n xt 35 ye rs wit an imp ementa i n progr m o help make that vis on a reality The Regi nal Pla , inc ud ng i s S st inable Com uni ie Strat gy (SCS), is built on an ntegrated set of public policie , s rategies, nd investments o main ai , ma ag , and imp ove the trans or ati n s stem so tha it mee s the div rse need of he an Dieg re ion hroug 20 0. The Re io al P an was upda ed in 2021, wh ch was he result of years of pla nin , da a analy is, a d community ngagement to reimag n the San Diego eg on wi h transforma ive transport tion sy tem a sustain ble pattern of gr wth and dev lopm nt, and nnov tive dem n and manag ment stra egies (SANDA 2021a). The 2 21 egional Plan inc udes a SCS, hic descri es coo din ted tran por ation nd land use
lan in tha e ceeds the st te’s ar e f r reducing per apit GHG e iss ons s t y CARB. The stat - ma dated target is 1 % red cti n —co pared wi h 20 5 —in per c pit GHG emis io s fro ca s an light-d ty tr cks y 20 5. The 2021 Regio al Plan ach eves a 0% r du tion b t en. The 021 R gio al Plan also pu s forth a orecast d development pat ern that is driven by re io al go ls for sus ainab lity, m bility, hous ng affor abili y, and e onom c p osperit .
C ty f
Ch la Vista
Chu a V sta G ner l Pl n
The Cit of Chula Vista Gen ral Pla was updated y the City n Decemb r 3, 2005 and mos recen ly men ed in 2 20. The General P an rovi es l ng-term tr teg to addre s p anning is ues or he rowth and devel pment of he City and is com osed of th fo lowing si eleme ts: lan use a d transport tion, economic dev lopment publi
acili ies nd se vic s, saf ty e em nt grow h man gement, environm ntal a d hou ing (Ci y of hu a ista 2 05). The ro ect s te is located in the Bayfront Plann ng rea and H rbo Distri t su are o the General Pla (C ty of Chula Vi ta 2005). The policies for impr vin air qualit in he General P an are as follo s:
Land U
s and Transportation El men
Policy L T- .2: E co rage ne de elopm nt that s organ zed around compact w lkable mixed- se ne ghborhoods and di tricts in order o c nserve open sp ce resources minimize i fras ruct re co ts a d reduce reliance n the automo ile
Policy LU -16
.1: Pr mote t e deve opment of el -pl nned commun ties that wi l t nd o e sel suppo ti e and, thus reduce the len th of ve icular rip , redu e dependency n the automobil , and encourage the use of othe m d s of t av l.
Policy LUT-
23. : Encou age th use of bi ycl s and w lking as alte natives to drivi g.
Policy LUT-23.
: Foste the devel pmen of a s stem of int r-conne ting bicyc e route thro ghout the City nd region.
Policy L
UT
23.5: Pr v de l nka es betwee bicyc e acilities hat uti ize circulatio element alignme ts and open spac co ridors.
Poli y
LUT-23 8: Provide and main ain a s fe and fficient system of sid walks, t ails, a d pedestrian crossings.
Policy LUT-23.14: Require new development projects to provide internal bikeway systems with connections to the citywide bicycle networks.
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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.
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.
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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.
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 Climate Action Plan (CAP). The CAP includes goals and policies to strengthen the City’s climate action efforts that have been underway since 2000.
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 i s 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).
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5.2.1.2 Existing Setting
The Project site is located within the boundaries of the San Diego Air Basin (SDAB). The SDAB is one of 15 air basins that geographically divide the State of California. The SDAB lies in the southwest corner of California and covers 4,260 square miles with the San Diego region.
Air pollutants are emitted by a variety of sources, including mobile sources (vehicles), area sources (hearths, consumer product use, architectural coatings, and landscape maintenance equipment), energy sources (natural gas), and stationary sources (generators or other stationary equipment). Some air pollutants need to be examined at the local level, and others are predominately an issue at the regional level. For instance, ozone (O3) is formed in the atmosphere in the presence of sunlight by a series of chemical reactions involving oxides of nitrogen (NOx) and reactive organic gas (ROG) (also termed volatile organic compounds (VOCs)). Because these reactions are broad scale in effects, O 3 is typically analyzed at the regional level (i.e., in the SDAB) rather than the local level. On the other hand, air pollutants such as coarse particulate matter (PM10), fine particulate matter (PM2.5), carbon monoxide (CO), and toxic air contaminants (TACs) are a potential concern in the immediate vicinity of the pollutant source because the pollutants are emitted directly by or are formed close to the source. Therefore, the study area for emissions of PM10, PM2.5, CO, and TACs is the local area near the source, such as in the vicinity of the Project Site, and the study area for regional pollutants such as NOx and ROGs is the entire SDAB.
Meteorological and Topographical Conditions
Air quality is a function of the rate and location of pollutant emissions under the influence of meteorological conditions and topographic features that influence pollutant movement and dispersal. Atmospheric conditions such as wind speed, wind direction, atmospheric stability, and air temperature gradients interact with the physical features of the landscape to determine the movement and dispersal of air pollutants, and consequently affect air quality.
The weather of the San Diego region, as in most of Southern California, is influenced by the Pacific Ocean and its semi-permanent high-pressure systems that result in dry, warm summers and mild, occasionally wet winters. The average temperature ranges (in degrees Fahrenheit) from the mid -40s to the high 90s. Most of the region’s precipitation falls from November to April, with infrequent (approximately 10%) precipitation during the summer.
The average seasonal precipitation along the coast is approximately 10 inches; the amount increases with elevation as moist air is lifted over the mountains (WRCC 2016).
The topography in the San Diego region varies greatly, from beaches on the west to mountains and desert on the east; along with local meteorology, it influences the dispersal and movement of pollutants in the basin. The mountains to the east prohibit dispersal of pollutants in that direction and help trap them in inversion layers.
The interaction of ocean, land, and the Pacific High-Pressure Zone maintains clear skies for much of the year and influences the direction of prevailing winds (westerly to northwesterly). Local terrain is often the dominant factor inland, and winds in inland mountainous areas tend to blow through the valleys during the day and down the hills and valleys at night.
The SDAB experiences frequent temperature inversions. Subsidence inversions occur during the warmer months as descending air associated with the Pacific High-Pressure Zone meets cool marine air. The boundary between the two layers of air creates a temperature inversion that traps pollutants. The other type of inversion, a radiation inversion, develops on winter nights when air near the ground cools by heat radiation and air aloft remains warm.
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The shallow inversion layer formed between these two air masses also can trap pollutants. As the pollutants become more concentrated in the atmosphere, photochemical reactions occur that produce O 3, which contributes to the formation of smog. Smog is a combination of smoke and other particulates, O 3, hydrocarbons, oxides of nitrogen (NOx) and other chemically reactive compounds which, under certain conditions of weather and sunlight, may result in a murky brown haze that causes adverse health effects (CARB 2023c).
Light daytime winds, predominantly from the west, further aggravate the condition by driving air pollutants inland, toward the mountains. During the fall and winter, air quality problems are created due to carbon monoxide (CO) and NOx emissions. CO concentrations are generally higher in the morning and late evening. In the morning, CO levels are elevated due to cold temperatures and the large number of motor vehicles traveling. Higher CO levels during the late evenings are a result of stagnant atmospheric c onditions trapping CO in the area. Since CO is produced almost entirely from automobiles, the highest CO concentrations in the SDAB are associated with heavy traffic. Nitrogen dioxide (NO2) levels are also generally higher during fall and winter days.
Under certain conditions, atmospheric oscillation results in the offshore transport of air from the Los Angeles region to San Diego County. This often produces high O3 concentrations, as measured at air pollutant monitoring stations within San Diego County. The transport of air pollutants from Los Angeles to San Diego has also occurred within the stable layer of the elevated subsidence inversion, where high levels of O3 are transported.
Pollutants and Effects
Criteria Air Pollutants
Criteria air pollutants are defined as pollutants for which the federal and state governments have established ambient air quality standards, or criteria, for outdoor concentrations to protect public health. The federal and state standards have been set, with an adequate margin of safety, at levels above which concentrations could be harmful to human health and welfare. These standards are designed to protect the most sensitive persons from illness or discomfort. Pollutants of concern include O3, NO2, CO, sulfur dioxide (SO2), PM10, PM2.5, and lead. These pollutants are discussed in the following paragraphs. 1 In California, sulfates, vinyl chloride, hydrogen sulfide, and visibility - reducing particles are also regulated as criteria air pollutants.
Ozone (O3). O3 is a strong-smelling, pale blue, reactive, toxic chemical gas consisting of three oxygen atoms. It is a secondary pollutant formed in the atmosphere by a photochemical process involving the sun’s energy and O 3 precursors. These precursors are mainly NO x and VOCs. The maximum effects of precursor emissions on O 3 concentrations usually occur several hours after they are emitted and many miles from the source. Meteorology and terrain play major roles in O3 formation, and ideal conditions occur during summer and early autumn on days with low wind speeds or stagnant air, warm temperatures, and cloudless skies. O3 exists in the upper atmosphere O3 layer (stratospheric O 3) and at the Earth’s surface in the troposphere. 2 The O 3 that the U.S. Environmental Protection Agency (EPA) and the CARB regulate as a criteria air pollutant is produced close to the ground level, where people live, exercise, and breathe. Ground-level O3 is a harmful air pollutant that causes numerous adverse health effects and is thus considered “bad” O 3. Stratospheric, or “good,” O 3 occurs naturally in the upper
1 The following descriptions of health effects for each of the criteria air pollutants associated with project construction and operations are based on the U.S. Environmental Protection Agency’s “ Criteria Air Pollutants” (EPA 2022 a) and the California Air Resources Board’s “Glossary of Air Pollutant Terms” (CARB 2023c) published information. 2 The troposphere is the layer of the Earth’s atmosphere nearest to the surface of the Earth. The troposphere extends outward about 5 miles at the poles and about 10 miles at the equator.
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atmosphere, where it reduces the amount of ultraviolet light (i.e., solar radiation) entering the Earth’s atmosphere.
Without the protection of the beneficial stratospheric O3 layer, plant and animal life would be seriously harmed.
O3 in the troposphere causes numerous adverse health effects; short-term exposures (lasting for a few hours) to O3 at levels typically observed in Southern California can result in breathing pattern changes, reduction of breathing capacity, increased susceptibility to infections, inflammation of the lung tissue, and some immunological changes (EPA 2013).
Inhalation of O3 causes inflammation and irritation of the tissues lining human airways, causing and worsening a variety of symptoms. Exposure to O3 can reduce the volume of air that the lungs breathe in, thereby causing shortness of breath.
O3 in sufficient doses increases the permeability of lung cells, rendering them more susceptible to toxins and microorganisms. The occurrence and severity of health effects from O3 exposure vary widely among individuals, even when the dose and the duration of exposure are the same. Research shows adults and children who spend more time outdoors participating in vigorous physical activities are at greater risk from the harmful health effects of O3 exposure.
While there are relatively few studies on the effects of O3 on children, the available studies show that children are no more or less likely to suffer harmful effects than adults. However, there are a number of reasons why children may be more susceptible to O3 and other pollutants. Children and teens spend nearly twice as much time outdoors and engaged in vigorous activities as adults. Children breathe more rapidly than adults and inhale more pollution per pound of their body weight than adults. Also, children are less likely than adults to notice their own symptoms and avoid harmful exposures. Further research may be able to better distinguish between health effects in children and adults. Children, adolescents and adults who exercise or work outdoors, where O3 concentrations are the highest, are at the greatest risk of harm from this pollutant (CARB 2023ca).
Nitrogen Dioxide (NO2). NO2 is a brownish, highly reactive gas that is present in all urban atmospheres. The major mechanism for the formation of NO2 in the atmosphere is the oxidation of the primary air pollutant nitric oxide (NO), which is a colorless, odorless gas. NO x plays a major role, together with VOCs, in the atmospheric reactions that produce O 3. NO x is formed from fuel combustion under high temperature or pressure. In addition, NO x is an important precursor to acid rain and may affect both terrestrial and aquatic ecosystems. The two major emissions sources are transportation and stationary fuel combustion sources such as electric utility and industrial boilers.
NO2 can irritate the lungs, cause bronchitis and pneumonia, and lower resistance to respiratory infections (EPA 2022a). A large body of health science literature indicates that exposure to NO2 can induce adverse health effects.
The strongest health evidence, and the health basis for the ambient air quality standards for NO 2, results from controlled human exposure studies that show that NO 2 exposure can intensify responses to allergens in allergic asthmatics. In addition, a number of epidemiological studies have demonstrated associations between NO 2 exposure and premature death, cardiopulmonary effects, decreased lung function growth in children, respiratory symptoms, emergency room visits for asthma, and intensified allergic responses. Infants and children are particularly at risk because they have disproportionately higher exposure to NO 2 than adults due to their greater breathing rate for their body weight and their typically greater outdoor exposure duration. Several studies have shown that long-term NO2 exposure during childhood, the period of rapid lung growth, can lead to smaller lungs at maturity in children with higher levels of exposure compared to children with lower exposure levels. In addition, children with asthma have a greater degree of airway r esponsiveness compared with adult asthmatics. In adults, the greatest risk is to people who have chronic respiratory diseases, such as asthma and chronic obstructive pulmonary disease (CARB 2023d).
Carbon Monoxide (CO). CO is a colorless, odorless gas formed by the incomplete combustion of hydrocarbon, or fossil fuels. CO is emitted almost exclusively from motor vehicles, power plants, refineries, industrial boilers, ships, aircraft, and
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trains. In urban areas, such as the Project location, automobile exhaust accounts for the majority of CO emissions. CO is a non-reactive air pollutant that dissipates relatively quickly; therefore, ambient CO concentrations generally follow the spatial and temporal distributions of vehicular traffic. CO concentrations are influenced by local meteorological conditions—primarily wind speed, topography, and atmospheric stability. CO from motor vehicle exhaust can become locally concentrated when surface-based temperature inversions are combined with calm atmospheric conditions, which is a typical situation at dusk in urban areas from November to February. The highest levels of CO typically occur during the colder months of the year, when inversion conditions are more frequent.
CO is harmful because it binds to hemoglobin in the blood, reducing the ability of blood to carry oxygen. This interferes with oxygen delivery to the body’s organs. The most common effects of CO exposure are fatigue, headaches, confusion and reduced mental alertness, light-headedness, and dizziness due to inadequate oxygen delivery to the brain. For people with cardiovascular disease, short-term CO exposure can further reduce their body’s already compromised ability to respond to the increased oxygen demand s of exercise, exertion, or stress.
Inadequate oxygen delivery to the heart muscle leads to chest pain and decreased exercise tolerance. Unborn babies whose mothers experience high levels of CO exposure during pregnancy are at risk of adverse developmental effects. Unborn babies, infants, elderly people, and people with anemia or with a history of heart or respiratory disease are most likely to experience health effects with exposure to elevated levels of CO (CARB 2023e).
Sulfur Dioxide (SO 2). SO2 is a colorless, pungent gas formed primarily from incomplete combustion of sulfur - containing fossil fuels. The main sources of SO2 are coal and oil used in power plants and industries; as such, the highest levels of SO2 are generally found near large industrial complexes. In recent years, SO2 concentrations have been reduced by the increasingly stringent controls placed on stationary source emissions of SO2 and limits on the sulfur content of fuels.
Controlled human exposure and epidemiological studies show that children and adults with asthma are more likely to experience adverse responses with SO2 exposure, compared with the non-asthmatic population. Effects at levels near the 1 -hour standard are those of asthma exacerbation, including bronchoconstriction accompanied by symptoms of respiratory irritation such as wheezing, shortness of breath, and c hest tightness, especially during exercise or physical activity. Also, exposure at elevated levels of SO 2 (above 1 parts per million [ppm]) results in increased incidence of pulmonary symptoms and disease, decreased pulmonary function, and increased risk of mortality. Older people and people with cardiovascular disease or chronic lung disease (such as bronchi tis or emphysema) are most likely to experience these adverse effects (CARB 2023e).
SO2 is of concern both because it is a direct respiratory irritant and because it contributes to the formation of sulfate and sulfuric acid in particulate matter (NRC 2005). People with asthma are of particular concern, both because they have increased baseli ne airflow resistance and because their SO 2-induced increase in airflow resistance is greater than in healthy people, and it increases with the severity of their asthma (NRC 2005). SO 2 is thought to induce airway constriction via neural reflexes involving irritant receptors in the airways (NRC 2005).
Particulate Matter (PM). Particulate matter pollution consists of very small liquid and solid particles floating in the air, which can include smoke, soot, dust, salts, acids, and metals. Particulate matter can form when gases emitted from industries and motor vehicles undergo ch emical reactions in the atmosphere. PM 2.5 and PM 10 represent fractions of particulate matter. Coarse particulate matter (PM 10) consists of particulate matter that is 10 microns or less in diameter and is about 1/7 the thickness of a human hair. Major sources of PM 10 include crushing or grinding operations; dust stirred up by vehicles traveling on roads; wood -burning stoves and fireplaces; dust from construction, landfills, and agriculture; wildfires and brush/waste burning; industrial sources; windblown dust from open lands; and atmospheric chemical and photochemical reactions. Fine particulate matter (PM 2.5) consists of
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particulate matter that is 2.5 microns or less in diameter and is roughly 1/28 the diameter of a human hair. PM2.5 results from fuel combustion (e.g., from motor vehicles and power generation and industrial facilities), residential fireplaces, and woodstoves. In addition, PM2.5 can be formed in the atmosphere from gases such as sulfur oxides (SOx), NOx, and VOCs.
PM2.5 and PM10 pose a greater health risk than larger-size particles. When inhaled, these tiny particles can penetrate the human respiratory system’s natural defenses and damage the respiratory tract. PM 2.5 and PM10 can increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and reduce the body’s ability to fight infections. Very small particles of substances such as lead, sulfates, and nitrates can cause lung damage directly or be absorbed into the blood s tream, causing damage elsewhere in the body. Additionally, these substances can transport adsorbed gases such as chlorides or ammonium into the lungs, also causing injury.
Whereas PM10 tends to collect in the upper portion of the respiratory system, PM2.5 is so tiny that it can penetrate deeper into the lungs and damage lung tissue. Suspended particulates also damage and discolor surfaces on which they settle and produce haze and reduce regional visibility.
A number of adverse health effects have been associated with exposure to both PM2.5 and PM10. For PM2.5, short-term exposures (up to 24-hour duration) have been associated with premature mortality, increased hospital admissions for heart or lung causes, acute and chronic bronchitis, asthma attacks, emergency room visits, respiratory symptoms, and restricted activity days. These adverse health effects have been reported primarily in infants, children, and older adults with preexisting heart or lung diseases. In addition, of all of the common air pollutants, PM2.5 is associated with the greatest proportion of adverse health effects related to air pollution, both in the United States and worldwide based on the World Health Organization’s Global Burden of Disease Project. Short-term exposures to PM10 have been associated primarily with worsening of respiratory diseases, including asthma and chronic obstructive pulmonary disease, leading to hospitalization and emergency department visits (CARB 2023f).
Long-term exposure (months to years) to PM2.5 has been linked to premature death, particularly in people who have chronic heart or lung diseases, and reduced lung function growth in children. The effects of long-term exposure to PM10 are less clear, although several studies suggest a link between long -term PM 10 exposure and respiratory mortality. The International Agency for Research on Cancer published a review in 2015 that concluded that particulate matter in outdoor air pollution causes lung cancer (CARB 2023f).
Lead. Lead in the atmosphere occurs as particulate matter. Sources of lead include leaded gasoline; the manufacturing of batteries, paints, ink, ceramics, and ammunition; and secondary lead smelters. Prior to 1978, mobile emissions were the primary source of atmospheric lead. Between 1978 and 1987, the phaseout of leaded gasoline reduced the overall inventory of airborne lead by nearly 95%. With the phaseout of leaded gasoline, secondary lead smelters, battery recycling, and manufacturing facilities are bec oming lead-emissions sources of greater concern.
Prolonged exposure to atmospheric lead poses a serious threat to human health. Health effects associated with exposure to lead include gastrointestinal disturbances, anemia, kidney disease, and in severe cases, neuromuscular and neurological dysfunction. Of particular concern are low-level lead exposures during infancy and childhood. Such exposures are associated with decrements in neurobehavioral performance, including IQ performance, psychomotor performance, reaction time, and growth. Children are highly susceptible to the effects of lead.
Volatile Organic Compounds (VOCs). Hydrocarbons are organic gases that are formed from hydrogen and carbon and sometimes other elements. Hydrocarbons that contribute to formation of O 3 are referred to and regulated as
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VOCs (also referred to as reactive organic gases). Combustion engine exhaust, oil refineries, and fossil-fueled power plants are the sources of hydrocarbons. Other sources of hydrocarbons include evaporation from petroleum fuels, solvents, dry-cleaning solutions, and paint.
The primary health effects of VOCs result from the formation of O3 and its related health effects. High levels of VOCs in the atmosphere can interfere with oxygen intake by reducing the amount of available oxygen through displacement. Carcinogenic forms of hydrocarbons, such as benzene, are considered TACs.
Sulfates. Sulfates are the fully oxidized form of sulfur, which typically occur in combination with metals or hydrogen ions. Sulfates are produced from reactions of SO 2 in the atmosphere and can result in respiratory impairment, as well as reduced visibility.
Vinyl Chloride. Vinyl chloride is a colorless gas with a mild, sweet odor, which has been detected near landfills, sewage plants, and hazardous waste sites, due to the microbial breakdown of chlorinated solvents. Short -term exposure to high levels of vinyl chloride in air can cause nervous system effects, such as dizziness, drowsiness, and headaches. Long-term exposure through inhalation can cause liver damage, including liver cancer.
Hydrogen Sulfide. Hydrogen sulfide is a colorless and flammable gas that has a characteristic odor of rotten eggs.
Sources of hydrogen sulfide include geothermal power plants, petroleum refineries, sewers, and sewage treatment plants. Exposure to hydrogen sulfide can result in nuisance odors, as well as headaches and breathing difficulties at higher concentrations.
Visibility-Reducing Particles. Visibility-reducing particles are any particles in the air that obstruct the range of visibility. Effects of reduced visibility can include obscuring the viewshed of natural scenery, reducing airport safety, and discouraging tourism. Sources of visibility-reducing particles are the same as for PM2.5.
Non-Criteria Pollutants
Toxic Air Contaminants (TACs). A substance is considered toxic if it has the potential to cause adverse health effects in humans, including increasing the risk of cancer upon exposure, or acute and/or chronic noncancer health effects.
A toxic substance released into the air is considered a TAC. TACs are identified by federal and state agencies based on a review of available scientific evidence. In the State of California, TACs are identified through a two-step process that was established in 1983 under the Toxic Air Contaminant Identification and Control Act. This two-step process of risk identification and risk management and reduction was designed to protect residents from the health effects of toxic substances in the air. In addition, the California Air T oxics “Hot Spots” Information and Assessment Act, Assembly Bill (AB) 2588, was enacted by the legislature in 1987 to address public concern over the release of TACs into the atmosphere. The law requires stationary sources to report the types and quantities of certain substances routinely released into the air. The goals of the Air Toxics "Hot Spots" Act are to collect emission data, to identify facilities having localized impacts, to ascertain health risks, to notify nearby residents of significant risks, and t o reduce those significant risks to acceptable levels.
Examples include certain aromatic and chlorinated hydrocarbons, certain metals, and asbestos. TACs are generated by several sources, including stationary sources such as dry cleaners, gas stations, combustion sources, and laboratories; mobile sources such as automobiles; and area sources such as landfills. Adverse health effects associated with exposure to TACs may include carcinogenic (i.e., cancer -causing) and noncar cinogenic effects.
Noncarcinogenic effects typically affect one or more target organ systems and may be experienced on either short- term (acute) or long-term (chronic) exposure to a given TAC.
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Diesel Particulate Matter (DPM). DPM is part of a complex mixture that makes up diesel exhaust. Diesel exhaust is composed of two phases, gas and particle, both of which contribute to health risks. More than 90% of DPM is less than 1 micrometer in diameter (about 1/70th the diameter of a human hair), and thus is a subset of PM2.5 (CARB 2023g). DPM is typically composed of carbon particles (“soot,” also called black carbon) and numerous organic compounds, including over 40 known cancer -causing organic substances. Examples of these chemicals include polycyclic aromatic hydrocarbons, benzene, formaldehyde, acetaldehyde, acrolein, and 1,3 -butadiene (CARB 2023g). CARB classified “particulate emissions from diesel -fueled engines” (i.e., DPM) as a TAC in August 1998 (17 CCR 93000). DPM is emitted from a broad range of diesel engines: on -road diesel engines of trucks, buses, and cars and off -road diesel engines including locomotives, marine vessels, and heavy -duty construction equipment, among others. Approximately 70% of all airborne cancer risk in California is associated with DPM (CARB 2000). To reduce the cancer risk associated with DPM, California Air Resources Board (CARB) adopted a diesel risk reduction plan in 2000 (CARB 2000). Because it is part of PM 2.5, DPM also contributes to the same non -cancer health effects as PM 2.5 exposure. These effects include premature death; hospitalizations and emergency department visits for exacerbated chronic heart and lung disease, including asthma; increased respiratory symptoms; and decreased lung function in children. Several studies suggest that exposure to DPM may also facilitate development of new allergies (CARB 202 3g). Those most vulnerable to non -cancer health effects are children whose lungs are still developing and the elderly who often have chronic health problems.
Odorous Compounds. Odors are generally regarded as an annoyance rather than a health hazard. Manifestations of a person’s reaction to odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and respiratory effects, nausea, vomiting and headache). The ability to detect odors varies considerably among the population and overall is quite subjective. People may have different reactions to the same odor. An odor that is offensive to on e person may be perfectly acceptable to another (e.g., coffee roaster). An unfamiliar odor is more easily detected and is more likely to cause complaints than a familiar one. In a phenomenon known as odor fatigue, a person can become desensitized to almost any odor, and recognition may only occur with an alteration in the intensity. The occurrence and severity of odor impacts depend on the nature, frequency, and intensity of the source; wind speed and direction; and the sensitivity of receptors.
Valley Fever. Coccidioidomycosis, more commonly known as “Valley Fever,” is an infection caused by inhalation of the spores of the Coccidioides immitis fungus, which grows in the soils of the southwestern United States.
San Diego County (County) is not considered a highly endemic region for Valley Fever, as the latest report from the County of San Diego Health and Human Services Agency Public Health Services indicated the County has 6.3 cases per 100,000 people (County of San Diego 2021). In the zip code area of the Project site (91910), the case rate is reported as 11.9 cases per 100,000 people (County of San Diego 2021).
Sensitive Receptors
Some land uses are considered more sensitive to changes in air quality than others, depending on the population groups and the activities involved. People most likely to be affected by air pollution, as identified by the California Air Resources Board (CARB), include children, older adults, and people with cardiovascular and chronic respiratory diseases. According to the SDAPCD, sensitive receptors are those who are especially susceptible to adverse health effects from exposure to toxic air contaminants, such as children, the elderly, and the ill. Sensitive receptors include residences, schools (grades Kindergarten through 12), libraries, day care centers, nursing homes, retirement homes, health clinics, and hospitals within 2 kilometers of the facility (SDA PCD 2022c). The closest sensitive receptors to the project site are existing multi-family residences east of I-5, east of the project site’s boundaries.
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Operational Emissions
Project-generated operational criteria air pollutant emissions were estimated for area sources, energy sources, and mobile sources using CalEEMod. The first full year of operations was assumed to be 20 30, consistent with the anticipated end of construction. This provides a conservative estimate as emissions would decrease as the buildout year increase because of improved vehicle technologies and more stringent regulations. The calculation of area, energy, and mobile air pollutant emissions is explained below.
Area Sources
CalEEMod was used to estimate operational emissions from area sources, including emissions from consumer product use, architectural coatings, and landscape maintenance equipment. Emissions associated with natural gas usage in space heating and water heatin g are calculated in the building energy use module of CalEEMod, as described in the following text.
Consumer products are chemically formulated products used by household and institutional consumers, including detergents; cleaning compounds; polishes; floor finishes; cosmetics; personal care products; home, lawn, and garden products; disinfectants; sanitizers; aerosol paints; and automotive specialty products. Other paint products, furniture coatings, or architectural coatings are not considered consumer products (CAPCOA 2022). Consumer product VOC emissions are estimated in CalEEMod based on the floor area of nonresidential buildings and on the default factor of pounds of VOC per building square foot per day. For parking lot land uses, CalEEMod estimates VOC emissions associated with use of parking surface degreasers based on a square footage of parking s urface area and pounds of VOC per square foot per day.
VOC off-gassing emissions result from evaporation of solvents contained in surface coatings such as in paints and primers using during building maintenance. CalEEMod calculates the VOC evaporative emissions from application of nonresidential surface coatin gs based on the VOC emission factor, the building square footage, the assumed fraction of surface area, and the reapplication rate. The VOC emission factor is based on the VOC content of the surface coatings, and SDAPCD Rule 67.0.1 (Architectural Coatings) governs the VOC (or ROG) content for interior and exterior coatings, which is 50 grams per liter VOC for the interiors and exteriors of the buildings. The CalEEMod default of 100 grams per liter was assumed for parking area coatings. The model default reapplication rate of 10% of area per year is assumed. Consistent with CalEEMod defaults, it is assumed that the nonresidential surface area for painting equals 2.0 times the floor square footage, with 75% assumed for interior coating and 25% assumed for exterior surface coating (CAPCOA 2022). For the parking lot, the architectural coating area is assumed to be 6% of the total square footage, consistent with the supporting CalEEMod studies provided as an appendix to the CalEEMod User’s Guide (CAPCOA 2022).
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 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).
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handling equipment are forklifts, pallet jacks, and yard trucks, which are designed for moving cargo containers.
Yard trucks are also known as yard goats, utility tractors, hustlers, yard hostlers, and yard tractors. The SCAQMD published a summary of operational survey results from 34 operating high-cube warehouses (SCAQMD 2014). The SCAQMD survey reported an average of 0.12 forklifts/pallet jacks per 1,000 square feet of building area, which was applied to the project . This estimate is for total forklifts and pallet jacks. Pallet jacks are small as they are primarily used to lift small loads in tight quarters (and are electric or manual); therefore, assuming all pieces of equipment are forklifts is conservative. The SCAQMD study also identified 3.6 yard trucks per 1 million square feet.
For this project, based on the maximum square footage of building space permitted by the project, on-site modeled operational equipment includes a total of 56 forklifts for Planning Area B-1 and 24 forklifts for Planning Area A for a total of 80 forklifts. In addition, one yard truck each was assumed for Planning Area A and B -1. Of the total 80 forklifts, approximately half were assumed to be electric with the remaining modeled as diesel with Tier 4 compliant engines. The yard trucks were assumed to be diesel. See Appendix C for detail calculations.
Stationary Sources
A stationary source is defined as any building, structure, facility, or installation which emits or may emit any pollutants.
Planning Areas A and B -1 may include refrigerated uses; accordingly, back-up generators may be required during emergency outages. One 500-hp emergency back-up generator was included for each building in Planning Areas with potential refrigerated uses (A and B-1). Emergency backup diesel generators are considered stationary sources and subject to permitting from the SDAPCD. The modeling assumed the generators would be consistent with statewide average emission factors for a 2030 operational year and would operate up to 50 hours annually.
Health Risk Assessment
Construction Health Risk Assessment
An HRA was performed to evaluate potential health risk associated with construction of the project. The following discussion summarizes the dispersion modeling and HRA methodology; supporting construction HRA documentation, including detailed assumptions, is presented in Appendix C.
For risk assessment purposes, PM 10 in diesel exhaust is considered DPM, originating mainly from off -road equipment operating at a defined location for a given length of time at a given distance from sensitive receptors.
Less-intensive, more-dispersed emissions result from on road vehicle e xhaust (e.g., heavy-duty diesel trucks). For the construction HRA, the CalEEMod scenario for the project was adjusted to reduce diesel truck one -way trip distances to 1,320 feet (0.25 miles) to estimate emissions from truc k pass-by at proximate receptors. The air dispersion modeling methodology was based on SDAPCD’s accepted modeling practices (SDAPCD 2022 c). Air dispersion modeling was performed using the EPA’s American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) Version 22112 modeling system (computer software) with the Lakes Environmental Software implementation/user i nterface, AERMOD View Version 11.2.0 (EPA 2022b) . The HRA followed the Office of Environmental Health Hazard Assessment (OEHHA) 2015 guidelines (OEHHA 2015) and SDAPCD guidance to calculate the health risk impacts at all proximate receptors as further discussed below. The dispersion modeling included the use of standard regulatory default options. AERMOD parameters were se lected consistent with the SDAPCD and EPA guidance and identified as representative of the Project site and Project activities. Principal parameters of this modeling are presented in Table 5.2-11.
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Would the project conflict with or obstruct implementation of the applicable air quality plan? SDAPCD and SANDAG are responsible for developing and implementing the clean air plans for attainment and maintenance of the NAAQS and CAAQS in the SDAB; specifically, the SIP and RAQS. 4 The federal O3 maintenance plan, which is part of the SIP, was last updated in 2020. The SIP includes a demonstration that current strategies and tactics will maintain acceptable air quality in the SDAB based on the NAAQS. The RAQS was initially adopted in 1991 and is u pdated every 3 years (most recently in 20 22). The RAQS outlines SDAPCD’s plans and control measures designed to attain the CAAQS for O 3. The SIP and RAQS rely on information from CARB and SANDAG, including mobile and area source emissions, as well as information regarding projected growth in San Diego County and the cities in the County, to project future emissions and then determine from that the strategies necessary for the reduction of emissions through regulatory controls. CARB mobile source emission pr ojections and SANDAG growth projections are based on population, vehicle trends, and land use plans developed by San Diego County and the cities in the County as part of the development of their general plans. The 2022 RAQS continues to build upon previous progress to reduce ground -level ozone, but also complements regional actions addressing greenhouse gases and climate change.
If a project proposes development that is greater than that anticipated in the local plan and SANDAG’s growth projections, the project might conflict with the SIP and RAQS and may contribute to a potentially significant cumulative impact on air quality.
The approximately 44.8-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 is currently developed with two main indus trial buildings and several smaller outbuildings. One of the buildings on site is approximately 282,004 square feet and was used for research and development, tooling, and warehousing and distribution of aftermarket products until early 2021. The other two larger buildings on site have a combined square footage of 733,977. There are also 11 smaller outbuildings totaling 32,860 square feet. These buildings were used for manufacturing, warehouse, and distribution operations until approximately 2020.
Population
SANDAG estimates future population, housing, land use, and economic growth throughout San Diego County and in individual cities, including the City of Chula Vista. On May 25, 2018, the Series 14 2050 Regional Growth Forecast was accepted by the SANDAG Board of Directors for planning purposes (SANDAG 2018). This forecast serves as the foundation for San Diego Forward: The Regional Plan and other planning documents across the region. SANDAG projects the region’s population will grow by 437,000 people between 2016 and 2050. This forecast is consistent with previous expectations although future growth rates have been reduced due to increased domestic migration out of the region. The growth in population will drive job growth and housing demand within the region , adding nearly 440,000 jobs and more than 280,000 housing units by 2050 (SANDAG 2021b).
The City of Chula Vista is anticipated to have a population of 284,835 by 2025, which comprises approximately
8.2% of the population in the San Diego region. As shown in Table 5.2-13, the SANDAG Series 14 Regional Growth Forecast for 2050 predicts population, housing, and employment for the San Diego Region, as well as for the City of Chula Vista, for 2016 through 2050.
4 For this discussion, the relevant federal air quality plan is the O3 maintenance plan (SDAPCD 2016b). The RAQS is the applicable plan for purposes of state air quality planning. Both plans reflect growth projections in the SDAB.
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opportunities, however, this population growth would not be considered to be greater than what is planned by the General Plan and SANDAG growth estimates because the proposed project would restore what was previously a major job center for the City of Chula Vista.
The proposed project would rejuvenate an underutilized property creating employment opportunities and restoring the approximate 1,000 jobs that existed on site. Furthermore, 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 patter n that promotes orderly growth by developing on a site with existing industrial us es. Based on the preceding, it is not anticipated that the project would contribute to substantial population and employment growth and associated VMT that was not anticipated for the project site in the existing General Plan and SANDAG Growth Estimates. However, because the project would be seeking a General Plan Amendment it is possible that the future job growth on the project site may be more intensive than what previously existed and therefore not within job growth projections from SANDAG.
The anticipated growth in employment and population and consequently VMT would therefore not be within regional growth forecasts. Implementation of the proposed project could conflict with or obstruct the implementation of the RAQS and/or applicable portions of the SIP , and the impact would be potentially significant without mitigation.
Implementation of Mitigation Measure AQ -1 (MM-AQ-1) would ensure that the appropriate growth and land use projections at the project site would be incorporated into the next SANDAG RTP/SCS and the following SDAPCD Clean Air Plan, which would resolve this inconsistency in the future.
Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard? Construction
Construction of the proposed project would result in the temporary addition of pollutants to the local airshed caused by on-site sources (i.e., off-road construction equipment, soil disturbance, and VOC off-gassing) and off-site sources (vendor and haul truck trips, and worker vehicle trips). Construction emissions can vary substantially day to day, depending on the level of activity, the specific type of operation, and for dust, the prevailing weather conditions.
Criteria air pollutant emissions associated with construction activities were quantified using CalEEMod. Default values provided by the program were used where detailed project information was not available. A detailed depiction of the construction schedule —including information regarding phasing, equipment used during each phase, haul trucks, vendor trucks, and worker vehicles—is included above.
Development of the project would generate air pollutant emissions from entrained dust, off-road equipment, vehicle emissions, asphalt pavement application, and architectural coatings. As described previously, fugitive dust would be limited through compliance with SDAPCD Rule 55, which requires the restriction of visible emissions of fugitive dust beyond the property line. This measure is incorporated into the project as PDF-SM AQ-1, and is detailed in Chapter 4, Project Description.
Table 5.2-17 shows the estimated maximum unmitigated daily construction emissions associated with the construction phases of the Project. Complete details of the emissions calculations are provided in Appendix C.
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exceedances of County of San Diego thresholds. Generally, the VOCs in architectural coatings and asphalt are of relatively low toxicity. Additionally, SDAPCD Rule 67.0.1 restricts the VOC content of coatings for both construction and operational applications.
In addition, VOCs and NOx are precursors to O3, for which the SDAB is designated as nonattainment with respect to the NAAQS and CAAQS (the SDAB is designated by EPA as an attainment area for the 1 -hour O3 NAAQS standard and 1997 8-hour NAAQS standard). The health effects associated with O3, as discussed in Section 5.2.1.2, under Criteria Air Pollutants, are generally associated with reduced lung function. The contribution of VOCs and NO x to regional ambient O3 concentrations is the result of complex photochemistry. The increases in O3 concentrations in the SDAB due to O3 precursor emissions tend to be found downwind from the source location to allow time for the photochemical reactions to occur. However, the potential for exacerbating excessive O3 concentrations would also depend on the time of year that the VOC emissions would occur because exceedances of the O3 NAAQS and CAAQS tend to occur between April and October when solar radiation is highest. The holistic effect of a single project’s emissions of O 3 precursors is speculative due to the lack of quantitative methods to assess this impact.
Nonetheless, the VOC and NO x emissions associated with Project construction could minimally contribute to regional O3 concentrations and the associated health impacts. Due to the minimal contribution during construction and operation, as well as the existing good air quality in coastal San Diego areas, health impacts would be considered less than significant.
Regarding NO2, which is a constituent of NO x, construction of the Project would not contribute to exceedances of the NAAQS and CAAQS for NO 2 since NO x emissions would be less than the applicable SDAPCD threshold. NO 2 health impacts are associated with respiratory irritation, which may be experienced by nearby receptors during the periods of heaviest use of off -road construction equipment. However, these operations would be relatively short term, and the off-road construction equipment would be operating on various portions of the site and would not be concentrated in one portion of the site at any one time. Construction of the Project would not require any stationary emission sources that would create substantial, localized NO2 impacts.
As discussed earlier, PM2.5 and PM10 pose a greater health risk than larger-size particles. When inhaled, these tiny particles can penetrate the human respiratory system’s natural defenses and damage the respiratory tract. PM 2.5 and PM10 can increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and reduce the body’s ability to fight infections. Similar to O3, construction of the Project would not exceed thresholds for PM 10 or PM2.5 and would not contribut e to exceedances of the NAAQS and CAAQS for particulate matter. Due to the minimal contribution of particulate matter during construction and operation, health impacts would be considered less than significant.
Based on the preceding considerations, health impacts from project-related criteria air pollutant emissions would be considered less than significant.
Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Construction
Odors would be generated from vehicles and/or equipment exhaust emissions during construction of the project.
Odors produced during construction would be attributable to concentrations of unburned hydrocarbons from tailpipes of construction equipment and architectural coatings. Such odors are temporary and for the types of construction activities anticipated for Project components, would generally remain localized and occur at
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magnitudes that would not affect substantial numbers of people. Therefore, impacts associated with odors during construction would be considered less than significant.
Operational
Due to the subjective nature of odor impacts, the number of variables that can influence the potential for an odor impact, and the variety of odor sources, there are no quantitative or formulaic methodologies to determine if potential odors would have a significant impact. Examples of land uses and industrial operations that are commonly associated with odor complaints include agricultural uses, wastewater treatment plants, food processing facilities, chemical plants, composting, refineries, landfills, dair ies, and fiberglass molding facilities. In addition to the odor source, the distance between the sensitive receptor(s) and the odor source, as well as the local meteorological conditions, are considerations in the potential for a project to frequently expose the public to objectionable odors.
Although localized air quality impacts are focused on potential impacts to sensitive receptors, such as residences and schools, other land uses where people may congregate (e.g., workplaces) or uses with the intent to attract people (e.g., restaurants and visitor -serving accommodations) should also be considered in the evaluation of potential odor nuisance impacts. The project is a commercial development that would include a restaurant use.
Restaurants are typically equipped with modern ventilation and odor control systems that effectively mitigate the release of cooking odors into the surrounding environment. Additionally, the future restaurant would be situated within a commercial zone where the presence of various food -related smells may be anticipated and deemed acceptable. The meteorology indicates that the wind blows towards Planning Area PA-A-2 and across I -5; accordingly, any odors that do escape would generally be transient and localized, and they would dissipate quickly without affecting a substantial number of people. Finally, regulatory compliance with the City’s municipal code section 19.66.090 ensures that odor impacts are minimized, further reducing the likelihood of significant adverse effects on the surrounding community. Based on the preceding, the project is not expected to produce nuisance odors that would impact a substantial number of people; therefore, impacts related to odors caused by the project would be less than significant.
5.2.4 Level of Significance Prior to Mitigation
Conflict with Air Quality Plan
The project’s employment growth of 1,000 jobs may be inconsistent with what was anticipated in SANDAG’s job growth estimates and thus would conflict with the Clean Air Plan which is based on anticipated growth resulting in a potentially significant impact.
Construction Emissions
As determined above, 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.
Toxic Air Contaminants
Construction
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
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below the 1.0 significance threshold; however, the project would exceed the cancer risk threshold of 10 in a million and would potentially significant without mitigation.
Operation
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.
5.2.5 Mitigation Measures
The following mitigation measures would be implemented in order to reduce the identified potentially significant impacts:
Clean Air Plan
MM-AQ-1 Update the Regional Growth Forecast. The applicant will inform the San Diego Association of Governments (SANDAG) of the project so that SANDAG’s next Regional Transportation Plan/Sustainable Communities Strategy, 2025 Regional Plan , can appropriately reflect employment locations and forecasts in Chula Vista. The updated information provided to SANDAG is anticipated be used by the San Diego Air Pollution Control District (SDAPCD) to update th eir Regional Air Quality Strategy (RAQS) Plan. The applicant shall prepare and submit a letter notifying SDAPCD of this revised forecast for use in the future updates to the plan as required.
Construction Emissions
MM AQ-2: Low VOC Paints. The project shall use super-compliant VOC paint (defined as less than 10 g/L of VOC) during project construction for architectural coatings.
Toxic Air Contaminants
Construction
MM AQ-3 Provision of Electrical Infrastructure for Construction and Use of Electric Construction Equipment. After the grading phase of Project construction, the Project Applicant or successor in interest shall provide temporary electrical hook ups to the power grid, rather than diesel -fueled generators, for contractors’ electric construction tools, such as saws, drills and compressors. The use of diesel-fueled generators for on -site construction activities shall be prohibited unless electrical infrastructure is not yet available on the Project site. Diesel-fueled generators may be used for off- site construction work. All off -road equipment with a power rating below 19 kilowatts (e.g., plate compactors, pressure washers) used during Project construction must be electric-powered. The Project Applicant or successor in interest shall include these requirements in applicable bid documents, purchase orders, and contracts with successful contractors.
MM AQ-4 Tier 4 Final Construction Equipment. Prior to the commencement of any construction activities, the applicant or its designee shall provide evidence to the City of Chula Vista (City) that for off-road equipment with engines rated at 75 horsepower or greater, no construction equipment shall be
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used that is less than Tier 4 Final. In the event of changed circumstances (e.g., changes in availability of specific types of construction equipment), the applicant may submit a request to the City to apply an equivalent method of achieving project-generated construction emissions that fall below the numeric cancer risk standards established by the South Coast Air Quality Management District (S CAQMD). Documentation using industry -standard emission estimation methodologies shall be furnished to the City Community Development Department demonstrating that estimated project-generated construction emissions would not exceed the applicable SCAQMD cancer risk threshold with the alternate construction method(s). If the documentation demonstrates project - generated construction emissions will remain below the applicable SCAQMD cancer risk threshold, then the City may approve the alternate construction method(s) at the Development Director's discretion. Required construction equipment fleet and methodologies approved by the City shall be included in the in the contract specifications for the applicant’s contractor.
Operation
MM AQ-5 Cargo Handling Equipment. All cargo handling equipment (including yard trucks, hostlers, yard goats, pallet jacks, and forklifts) shall be zero -emission vehicles. Each building shall include the necessary charging stations or other necessary infrastructure for cargo handling equip ment. The building manager or their designee shall be responsible for enforcing these requirements.
MM AQ-6 Tier 4 Emergency Generators. The project operations shall be conditioned to operate with Tier 4 Final certified emergency generators.
MM AQ-7 Truck Requirements and Restrictions. Prior to issuance of a building permit, the City shall confirm the following:
▪ The loading docks shall be designed to accommodate SmartWay trucks. ▪ Applicant shall provide project specifications, drawings, and calculations that demonstrate that main electrical supply lines and panels have been sized to support heavy truck charging facilities when these trucks become available.
- The calculations shall be based on reasonable predictions from currently available truck manufacturer’s data. Electrical system upgrades that exceed reasonable costs shall not be required.
Prior to issuance of a certificate of occupancy, the City shall confirm the following:
▪ Any tenant lease agreement shall require tenants that do not already operate 2010 and newer trucks to apply in good faith for funding to replace/retrofit their trucks, such as Carl Moyer, VIP, Prop 1B, SmartWay Finance, or other similar funds. If awarded, the tenant shall be required to accept and use the funding. Tenants shall be encouraged to consider the use of alternative fueled trucks, as well as new or retrofitted diesel trucks. Tenants shall also be encouraged to become SmartWay Partners, if eligible. This measure shall not apply to trucks that are not owned or operated by the facility operator or facility tenants since it would be legally infeasible to prohibit access to the site by any truck that is otherwise legal to operate on California roads and highways.
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▪ Legible, durable, weather-proof signs shall be placed at truck access gates, loading docks, and truck parking areas that identify applicable California Air Resources Board (CARB) anti-idling regulations. At a minimum, each sign shall include instructions for truck drivers to shut off engines when not in use; instructions for drivers of diesel trucks to restrict idling to no more than 5 minutes once the vehicle is stopped, the transmission is set to “neutral” or “park,” and the parking brake is engaged; and telephone numbers of the building facilities manager and CARB to report violations. Prior to the issuance of an occupancy permit, the City shall conduct a site inspection to ensure that the signs are in place.
MM AQ-8 Transportation Demand Management. The project shall include contractual language in tenant lease agreements requiring that any facility operator with more than 100 employees require the establishment of a transportation demand management program to reduce employee commute vehicle emissions. Measures to reduce employee commute emissions may include but are not limited to the following:
▪ Offering secure bicycle storage, and changing facilities; ▪ Providing free or discounted transit passes to encourage employees to use public transportation;
▪ Establishing carpool or vanpool groups to reduce the number of single-occupancy vehicles on the road;
▪ Establishing a car-sharing or bicycle-sharing program; ▪ Providing on-site amenities such as cafeterias, fitness centers, etc. to reduce the need for employees to travel during the day;
▪ Providing incentives to encourage employees to use alternative modes of transportation.
5.2.6 Level of Significance After Mitigation
Clean Air Plan
Implementation of MM-AQ-1 would ensure that the appropriate employment growth projections at the project site would be incorporated into the next SANDAG RTP/SCS (anticipated to be in 202 5) and would thereby be incorporated into the following SDAPCD RAQS. Based on the above considerations, the project’s potential to conflict with or obstruct implementation of the applicable air quality plan would be less than significant with mitigation incorporated into the project.
Construction Emissions
Table 5.2-23 shows the mitigated emissions from construction with the incorporation of MM AQ -2. As shown, the mitigated construction emissions from the project would fall below the SCAQMD’s thresholds of significance, resulting in a less than significant impact with mitigation incorporated.
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5.3 Biological Resources
This section describes the existing biological resource conditions of the project site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the proposed Rohr Wohl Specific Plan Project (project or proposed project). The discussion in this section is based on the Biological Resources Report, prepared for the project by Rocks Biological Consulting (RBC) in March 2023 (Appendix D).
5.3.1 Existing Conditions
5.3.1.1 Regulatory Framework
Federal
Federal Endangered Species Act
The federal Endangered Species Act of 1973 (ESA), as amended (16 USC 1531 et seq.), provides for listing of endangered and threatened species of plants and animals and designation of critical habitat for listed animal species. The ESA also prohibits all persons subject to U.S. jurisdiction from “taking” endangered species, which includes any harm or harassment. Section 7 of the ESA requires that federal agencies, prior to project approval, consult the U.S. Fish and Wildlife Service (USFWS) and/or the National Marine Fisheries Service to ensure adequate protection of listed species that may be affected by the project.
Migratory Bird Treaty Act
The Migratory Bird Treaty Act (MBTA) (16 USC 703 et seq.) is a federal statute that implements treaties with several countries on the conservation and protection of migratory birds. The list of bird species covered by the MBTA is extensive and is detailed in Title 50 of the Code of Federal Regulations ( CFR), Section 10.13. The regulatory definition of “migratory bird” is broad and includes any mutation or hybrid of a listed species, including any part, egg, or nest of such a bird (50 CFR 10.12). Migratory b irds are not necessarily federally listed endangered or threatened birds under the ESA. The MBTA, which is enforced by USFWS, makes it unlawful “by any means or in any manner, to pursue, hunt, take, capture, [or] kill” any migratory bird or attempt such actions, except as permitted by regulation. The applicable regulations prohibit the take, possession, import, export, transport, sale, purchase, barter, or offering of these activities, except under a valid permit or as permitted in the implementing regulati ons (50 CFR 21.11). It is important to note that “take” as defined under the federal MBTA is not synonymous with “take” as defined under the ESA. The MBTA definition of “take” lacks a “harm and harassment” clause comparable to “take” under the ESA; thus, the MBTA authority does not extend to activities beyond the nests, eggs, feathers, or specific bird parts.
State
California Endangered Species Act
Similar to the federal ESA, the California ESA of 1970 provides protection to species considered threatened or endangered by the State of California (California Fish and Game Code, Section 2050 et seq.). The California ESA recognizes the importance of threatened and endangered fish, wildlife, and plant species and their habitats, and
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prohibits the taking of any endangered, threatened, or rare plant and/or animal species unless specifically permitted for education or management purposes.
California Fish and Game Code
The California Fish and Game Code regulates the handling and management of the state’s fish and wildlife.
Most of the code is administered or enforced by the California Department of Fish and Wildlife (CDFW).
Section 1602 regulates activities that would divert or obstruct the natural flow or substantially change the bed, channel, or bank of any river, stream, or lake that supports fish or wildlife. CDFW has jurisdiction over riparian habitats associated with watercourses. Jurisdictional waters are delineated by the outer edge of riparian vegetation or at the top of the bank of streams or lakes, whichever is wider. CDFW jurisdiction does not include tidal areas or isolated resources.
Sections 3503, 3503.5, and 3513 of the California Fish and Game Code prohibit the “take, possession, or destruction of bird nests or eggs.” Section 3503 states: “It is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by this cod e or any regulation made pursuant thereto.” Section 3513 states: “It is unlawful to take or possess any migratory nongame bird as designated in the MBTA or any part of such migratory nongame bird except as provided by rules a nd regulations adopted by the Secretary of the Interior under provisions of the Migratory Bird Treaty Act.” Porter -Cologne Water Quality Control Act
The intent of the Porter -Cologne Water Quality Control Act (Porter-Cologne Act) is to protect water quality and the beneficial uses of water, and it applies to both surface water and groundwater. Under this law, the State Water Resources Board develops statewide water quality plans, and the nine Regional Water Quality Control Boards (RWQCBs) develop basin plans that identify beneficial uses, water quality objectives, and implementation plans.
The RWQCBs have the primary responsibility to implement the provisions of both statewide and basin plans. All waters of the state are regulated under the Porter -Cologne Act, including isolated waters that are no longer regulated by the U.S. Army Corps of Engineers. Recent changes in state procedures require increased analysis and mitigation. Developments with impact to jurisdictional waters of the state must demonstrate compliance with the goals of the act by developing stormwater pollution prevention plans, standard urban stormwater mitigation plans, and other measures to obtain a Clean Water Act, Section 401 certification and/or Waste Discharge Requirement.
Local
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 USFWS, CDFW, the California Native Plant Society (CNPS), 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 fo r 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 Pl an (City of Chula Vista 2003), will be made by the City for such Take Authorization of the covered Narrow Endemic Species.
Wetlands Protection
As part of the California Environmental Quality Act (CEQA) review, development projects that contain wetlands would be required to demonstrate that impacts to wetlands have been avoided to the greatest extent practicable and, where impacts are nonetheless proposed, that such impacts have been minimized. For unavo idable impacts to wetlands within the Development Area, the MSCP Subarea Plan requires mitigation in accordance with the defined wetlands mitigation ratios . The wetlands mitigation ratios provide a standard for each habitat type but may be adjusted depending on the functions and values of both the impacted wetlands, as well as the wetlands mitigation
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proposed by the project. The City may also consider the wetland habitat type(s) being impacted and used for mitigation in establishing whether these standards have been met (City of Chula Vista 2003).
MSCP Adjacency Management Issues
As stated in Section 7.5.2 , Adjacency Management Issues, of the City’s MSCP Subarea Plan (City of Chula Vista 2003), all new developments are required to adhere to the following adjacency guidelines:
▪ Drainage: All developed and paved areas must prevent the release of toxins, chemicals, petroleum products, exotic plant materials and other elements that might degrade or harm the natural environment or ecosystem processes within the Preserve. This can be accomplished using a variety of methods including natural detention basins, grass swales or mechanical trapping devices. These systems should be maintained approximately once a year, or as often as needed, to ensure proper functioning. Maintenance should include dredging out sediments if needed, removing exotic plant materials, and adding chemical - neutralizing compounds (e.g., clay compounds) when necessary and appropriate. - Develop and implement urban runoff and drainage plans which will create the least impact practicable for all development adjacent to the Preserve. All development projects will be required to meet NPDES [National Pollutant Discharge Elimination System] standards and incorporate BMPs [best management practices] as defined by the City’s Standard Urban Storm [Water] Mitigation Plan (SUSMP). - Pursuant to the San Diego Regional Water Quality Control Board Municipal Permit, and the City of Chula Vista Storm Water Management Standards Requirements Manual, which includes the SUSMP, all development and redevelopment located within or directly adjace nt to or discharging directly to an environmentally sensitive area (as defined in the Municipal Permit and the Local SUSMP) are required to implement site design, source control, and treatment control BMPs. The BMPs shall, at a minimum include:
- Control post-development peak storm water runoff discharge rates and velocities to maintain or reduce pre-development downstream erosion and to protect stream habitat; - Conserve natural areas where feasible;
- Minimize storm water pollutants of concern in runoff; - Remove pollutants of concern from urban runoff;
- Minimize directly connected impervious areas where feasible; - Protect slopes and channels from eroding;
- Include storm drain stenciling and signage;
- Include additional water quality provisions applicable to individual project categories; - Ensure that post-development runoff does not contain pollutant loads which cause or contribute to an exceedance of water quality objectives or which have not been reduced to the maximum extent practicable; and,
- Implement BMPs close to pollutant sources.
- Require all NPDES -regulated projects to implement a combination of BMPs as close to potential pollutant sources as feasible.
▪ Toxic Substances: All agricultural uses, including animal-keeping activities, and recreational uses that use chemicals or general by -products such as manure, potentially toxic or impactive to wildlife, sensitive species, habitat, or water quality need to incorporate method s on their site to reduce impacts caused by
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the application and/or drainage of such materials into the Preserve. Methods shall be consistent with requirements of the RWQCB and NPDES standards.
▪ Lighting: Lighting of all developed areas adjacent to the Preserve should be directed away from the Preserve wherever feasible and consistent with public safety. Where necessary, development should provide adequate shielding with non-invasive plant materials (preferably native), berming, and/or other methods to protect the Preserve and sensitive species from night lighting. Consideration should be given to the use of low-pressure sodium lighting.
▪ Noise: Uses in or adjacent to the Preserve should be designed to minimize noise impacts. Berms or walls should be constructed adjacent to commercial areas and any other use that may introduce noises that could impact or interfere with wildlife utilization of the Preserve. Excessively noisy uses or activities adjacent to breeding areas, including temporary grading activities, must incorporate noise reduction measures or be curtailed during the breeding season of sensitive bird species, consistent with Table 3-5 of the MSCP Subregional Plan.
- Where noise associated with clearing, grading or grubbing will negatively impact an occupied nest for the least Bell’s vireo during the breeding season (March 15 to September 15), noise levels should not exceed 60 L eq [energy equivalent level] . However, on a case by -case basis, if warranted, a more restrictive standard may be used. If an occupied least Bell’s vireo nest is identified in a pre-construction survey, noise reduction techniques, such as temporary noise walls or berms, shall be incorporated into the construction plans to reduce noise levels below 60 Leq. - Where noise associated with clearing, grubbing or grading will negatively impact, an occupied nest for raptors between January 15 and July 31 or the coastal California gnatcatcher between February 15 and August 15 (during the breeding season), clearing, grubbing or grading activities will be modified if necessary, to prevent noise from negatively impacting the breeding success of the pair. If an occupied raptor or coastal California gnatcatcher nest is identified in a pre-construction survey, noise reduction techniques shall be incorporated into the construction plans. Outside the bird breeding season(s) no restrictions shall be placed on temporary construction noise. ▪ Invasives: No invasive non-native plant species shall be introduced into areas immediately adjacent to the Preserve. All open space slopes immediately adjacent to the Preserve should be planted with native species that reflect the adjacent native habitat. The plant l ist contained in the Wildland/Urban Interface: Fuel Modification Standards, Appendix L of the MSCP Subarea Plan , must be reviewed and utilized to the maximum extent practicable when developing landscaping plans in areas adjacent to the Preserve. ▪ Buffers: There shall be no requirements for buffers outside the Preserve, except as may be required for Wetlands pursuant to Federal and/or State permits, or by local agency CEQA mitigation conditions. All open space requirements for the Preserve shall be incorporated into the Preserve. Fuel modification zones must be consistent with Section 7.4.4 of the Subarea Plan.
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, 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 District subarea of the General Plan (City of Chula Vista 2005). The policies for preserving biological resources in the General Plan are as follows:
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Environmental Element
Objective E1: Conserve Chula Vista’s sensitive biological resources.
Policy E 1.1: Implement the City of Chula Vista MSCP Subarea Plan
5.3.1.2 Existing Biological Resources
The project site is divided into two parcels, totaling approximately 44.8 acres, and is located along the southern end of the San Diego Bay in the City of Chula Vista, San Diego County, California. The project site is roughly bounded by Laguna Drive and G Street to the north, I nterstate 5 and Bay Boulevard to the east, H Street to the south, and Marina Parkway to the west (Figure 4-1). Sweetwater River is located approximately 1.1 miles north of the project site.
Methods
The impacts analysis in this section is based on a biological resources technical report prepared by RBC, which is provided in Appendix D to this EIR. This study consisted of (1) analysis of existing biological information within the study area, ( 2) general biological survey and vegetation mapping, ( 3) habitat assessments for special -status species, (4) analysis of potential project impacts on biological resources, and (5) analysis of project conformance with federal, state, and local biological regulations.
RBC prepared field maps using geographic information systems, CDFW’s California Natural Diversity Database , USFWS’s Information for Planning and Consultation (IPaC) database, and CNPS’s electronic Inventory of Rare Plants to identify special-status species that have potential to occur within the project site. RBC also identified soils present on site using Natural Resources Conservation Service data and mapping (Appendix D).
The project study area includes the proposed project site and a 100-foot buffer surrounding the site, resulting in a
60.6-acre study area. RBC biologists visited the project site in April 2022 to conduct general biological surveys for the flora and fauna, vegetation mapping, and a constraints -level assessment for jurisdictional wetlands/waters.
Biologists used several tools to conduct their surveys , including binoculars for observation, the Jepson Manual:
Vascular Plants of California for plant identification, and local botanical knowledge.
General Physical Characteristics
RBC found that the approximately 60.6-acre study area is primarily composed of developed land with ornamental vegetation and disturbed habitat. The study area is not within or directly adjacent to lands designated as a preserve under the City MSCP Subarea Plan, although a preserve does occur 500 feet to the north. Additionally, there are no topographical depressions or basins with the project site that would support vernal wildlife and plant species (Appendix D).
Vegetation Communities
The study area is composed of developed land primarily made of up industrial buildings and parking lots. RBC identified four vegetation types within the proposed project study area during the biological field surveys. These consist of upland habitats including developed area, disturbed habitat, eucalyptus woodland, and ornamental vegetation. Acreages of these vegetation types are identified in Table 5.3-1, and each is discussed in more detail
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communities are distributed throughout San Diego County, especially in highly populated areas and regions with increased off-roading activities (Oberbauer et al. 2008).
RBC identified 2.4 acres of disturbed habitat within the study area, located in isolated patches along the periphery of the project site . “Disturbed habitat on site consists of bare soil or gravel with sparse ruderal, non -native vegetation, as well as a small number of native broom baccharis ( Baccharis sarothroides), mulefat (B. salicifolia), and deerweed (Acmispon glaber var. glaber)” (Appendix D).
Eucalyptus Woodland
“Eucalyptus woodland habitats can range from single -species thickets with little to no shrubby understory to scattered trees over a well-developed herbaceous and shrubby understory. In most cases, eucalyptus forms a dense stand with a closed canopy. Eucalyptus species produce a large amount of leaf and bark litter, the chemical and physical characteristics of which limit the ability of other species to grow in the understory, decreasing floristic diversity. Overstory composition is typically limited to one species of the genus, or mixed stands composed of several Eucalyptus species; few native overstory species are present within eucalyptus planted areas, except in smaller cleared pockets” (Oberbauer et al. 2008). Characteristic species of the community include Eucalyptus spp., including E. globulus (blue gum) and E. camaldulensis (river red gum). They are found in San Diego County and in coastal or foothill regions with access to water stores.
The 1.1-acre eucalyptus woodland habitat occurs along the eastern project buffer and within the small patches in the southern portion of the project site that are dominated by gum trees, which are not native and were planted or became naturalized in these areas. Blue gum and river red gum are the dominant species within the study area of the eucalyptus woodland habitat (Appendix D).
Rare, Threatened, Endangered, Endemic, Sensitive and/or City MSCP Subarea Plan - Covered Species
In preparation of the Biological Technical Report, general surveys were conducted for plant and animal species and habitats that are considered sensitive according to the USFWS, CNPS, and the CDFW’s California Natural Diversity Database record for the National City 7.5 -minute quadrangle. RBC assessed e ach special-status species for its potential to occur within the study area, as shown in Table 5.3-2. For the general biological surveys, faunal activity at the time was moderate with most spring season species unavailable and the late spring and summer flowering species not present. RBC did not observe any federally and/or state-listed, California Rare Plant Rank, and/or City MSCP Subarea Plan-covered plant species in the study area. A list of all plant species that were observed in the study area is provided in Appendix E to the Biological Technical Report (Appendix D).
City MSCP Subarea Plan Narrow Endemic Plant Species Potential for Occurrence Narrow Endemic Species are those with very restricted habitat that only occur in the San Diego County region.
Specific protections apply to Narrow Endemic Species in accordance with the City MSCP Subarea Plan. As shown in Table 5.3-2, RBC found that no Narrow Endemic Species have a moderate or high potential to occur on the project site due to the lack of suitable habitat. project site is 99% developed with impervious surfaces that do not allow for native plant growth. The small areas of the project site co mposed of disturbed habitat (0.2 acre s) and planted eucalyptus (0.1 acres) are not suitable for endemic plant species because they have been historically graded and are isolated from any areas of natural habitat. Additionally, the project site is composed solely of Huerhuero–Urban
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nest to the north of the active nest as a perch. However, these nests were removed on October 21, 2022, once fledglings were no longer dependent on the nests, in compliance with the MBTA and following consultation with CDFW. RBC documented that no direct impacts on osprey or other avian species occurred during removal of the two on-site inactive osprey nests and associated manmade structures. Based on the historic presence of nesting osprey and the continued presence of other similar manmade structures suit able for nesting, osprey have a moderate potential for occurrence on site (Appendix D).
American Peregrine Falcon
The American peregrine falcon is considered a fully protected species by CDFW when nesting. This species breeds in several different habitats, including urban areas. The most common peregrine falcon nesting locations in California are cliffs, tall buildings, and bridges ; they rarely will use older nests of other bird species . This species does not build nests; rather, their eggs are laid in indentations on cliffs, buildings, or bridges. American peregrine falcons usually prey on small to medium birds such as ducks, pigeons, and songbirds.
The American peregrine falcon was listed as endangered under the federal ESA in 1970 and the California ESA in 1971 because the number of known breeding pairs had dropped by 95% from the early 1900s to 1970 due to habitat loss and the widespread use of the pesticide DDT , which caused eggshell thinning that resulted in failed nesting attempts. DDT was banned in 1972 and widespread recovery efforts were implemented. T he American peregrine falcon has recovered across its range and was delisted by USFWS in 1999 and by CDFW in 2009.
During the general biological survey, RBC observed one immature American peregrine falcon was “flying through the western portion of the project site. As it was passing through, it dove between vacant industrial buildings where rock pigeon, a common prey for peregrine falcon, had previously been observed. The observed individual did not appear to oc cupy the project site, and evidence of on -site nesting or long -term use was not documented ” (Appendix D).
Although American peregrine falcon was observed during the survey, RBC concluded that the project site has low potential to support nesting by this species. Although abundant avian prey is available throughout the project site, the buildings on site are shorter than typical peregrine falcon nesting locations; therefore, the project site does not provide suitable nesting habitat (Appendix D).
Special -Status Wildlife Potential for Occurrence
RBC identified special-status wildlife species with potential to occur in the project region by searching the California Natural Diversity Database and the Information for Planning and Conservation database for a 3-mile radius surrounding the study area. RBC then used best professional judgment based on the presence/absence of suitable habitat for special-status species and professional experience to determine the potential for each species to occur on site. RBC noted that clayey soil (Huerhuero–Urban land complex, 2% to 9% slopes) composes the western extent of the project site. No depressional areas or vernal poo ls suitable to support ponding or Anostraca species are present within the project site as all on -site areas of lower topography are associated with asphalt drainages (Appendix D). Appendix D to the Biological Technical Report identifies species potential for occurrence within or immediately adjacent to the project site.
RBC concluded that two CDFW species of special concern, pallid bat (Antrozous pallidus) and western mastiff bat (Eumops perotis californicus), have a moderate potential to occur on site and that no other special-status and/or
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City MSCP Subarea Plan-covered wildlife species have a moderate or high potential to occur on site due to the lack of suitable habitat (Appendix D).
Pallid Bat
Pallid bat occurs throughout California at low elevations and inhabits dry habitats such as grasslands, shrublands, woodlands, and forests. The pallid bat is a nocturnal species that day roosts in caves, rock s, mines, hollow trees, and buildings. The species forages in open areas above ground level and captures prey on ground. Pallid bats consume a variety of insects and arachnids. They form maternity colonies in early April, do not migrate, and will hibernate in small groups or solely during winter near their roost.
Pallid bats have had a major decline on the California coast, as they are highly sensitive to disturbances in their roosting sites. Their roosting sites are critical for maintaining normal metabolic function and growth. Disturbance factors include the destruction of roost sites, closure of mines, loss of roost trees, pest extermination in buildings, and pesticide use.
RBC found that t he vacant buildings on the project site have crevices and small rooms that could be utilized by pallid bats for roosting. The project site does not support highly suitable foraging habitat; however, disturbed lots to the north and south of the site are open and support prey species consumed by this species. As such, pallid bat has a moderate potential for occurrence on the project site (Appendix D).
Western Mastiff Bat
Western mastiff bat is found in open, semi-arid habitats such as woodlands, coastal scrub, grasslands, palm oases, chapparal, desert scrub, and urban land. This species forages in open habitats by catching insects in the air and they typically eat winged insects that are active at night, such as moths, crickets, beetles, and grasshoppers.
Western mastiff bat is the largest species of native bat in the U nited States. Their large wings enable rapid flight but limit maneuverability; thus, they cannot fly from a flat surface and instead must free-fall to begin flight. Roosts must be high enough for them to gain speed as they fall, generally greater than 9 feet in height. This species requires crevices for roosting, typically in rocks, buildings, trees, and tunnels. They sometimes share roosts with other species, including pallid bat. Western mastiff bats are non-migratory and active all year round.
Western mastiff bats are threatened by urban ization, activities that destroy or disturb habitats, recreational climbing, pest control in buildings, pesticide applications on agricultural lands, and loss of open drinking water sites.
RBC found that the vacant buildings on the project site have high crevices that could be utilized by western mastiff bats for roosting. The project site does not support highly suitable foraging habitat; however, moderately suitable foraging habitat is present nearby on undeveloped lands north and south of the site. As such, western mastiff bat has a moderate potential for occurrence on the project site (Appendix D).
Potential Federal and State Jurisdictional Aquatic Resources RBC conducted a constraints-level aquatic resources assessment of the project site and study area to identify areas that may be considered potentially jurisdictional under the U.S. Army Corps of Engineers pursuant to Section 404 of the Clean Water Act; the RWQCB pursuant to Section 401 of the Clean Water Act and the Porter-Cologne Act; CDFW pursuant to California Fish and Game Code Section 1602; or the California Coastal Commission pursuant to California Public Resources Code Section 3000 et seq., but did not conduct a formal jurisdictional delineation per
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federal and state guidelines. RBC reviewed the U.S. Geological Survey National Hydrography Dataset and the USFWS National Wetland Inventory to determine if potentially jurisdictional aquatic features had been previously identified within the study area. During the site survey, RBC assessed areas with depressions, drainage patterns, wetland vegetation, or riparian vegetation for potential jurisdictional status, with focus on the presence of defined channels, soils, and hydrology (Appendix D).
RBC observed a paved road along the western project boundary with six in -ground stormwater collection grates.
The paved areas near the grates have a slight slope and may convey sheet flow during storm events; however, this paved road did not appear to be a potentially jurisdictional aquatic resource . The in-ground stormwater collection grates that were also observed are along the east side an industrial building in the western part of the project site which also did not appear to contain a potentially jurisdictional aquatic resource.
No other areas with depressions (including vernal pools), drainage patterns, defined channels, and/or wetland vegetation were observed during the survey. Additionally, the project site is composed solely of Huerhuero–Urban land complex soils that are not considered to be hydric within San Diego County. RBC determined that the project site does not support areas that could be considered jurisdictional by the U.S. Army Corps of Engineers , RWQCB, California Coastal Commission, and CDFW based on the results of the constraints-level aquatic resources assessment.
5.3.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to biological resources are based on Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.) . According to Appendix G, a significant impact related to biological resources would occur if the project would:
1. Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.
2. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.
3. Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.
4. Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.
5. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
6. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.
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Osprey
Two osprey nests were observed at the project site (one historic and one active in spring 2022). These nests were observed on light poles within a developed parking lot on the project site. Demolition of all development within that portion of the project site, including the light poles, is proposed. Osprey nests on the project site had been used for at least 2 consecutive years (2021 and 2022; CCB 2022) and an active nest site was also recorded in 2006 (Dudek 2006). Regarding direct impacts, osprey have a moderate potential for nesting on the site; therefore, impacts would be potentially significant prior to mitigation (MM-BIO-2, Osprey Nests).
Migratory Birds
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, Nesting Birds) would be required.
Bats
Pallid bat and western mastiff bat have a moderate potential to occur on the project site , as the on-site vacant buildings may support suitable roosting habitat for both species. Pallid bats are considered rare along the San Diego coast; the most recent pallid bat observation was documented approximately 0.5 miles north of the project site in 2015. The nearest record of western mastiff bat is approximately 3 miles from the project site.
The area is not known to support roosting colonies of special-status bats; therefore, construction is not anticipated to substantially affect either species. Nonetheless, prior to mitigation (MM-BIO-4, Special-Status Bats, and MM-BIO- 5, Avoidance Measures for Special-Status Bats) impacts would be potentially significant.
Indirect Impacts
Indirect impacts to special -status bird species may occur if construction is conducted during the nesting season (generally February 15–August 31) and the nesting raptor season (January 15 –July 31). Potential short-term or temporary indirect impacts to special-status plants or wildlife (if they occur) adjacent to but outside the project site could primarily result from construction activities and include impacts related to or resulting from the generation of fugitive dust; changes in hydrology resulting from construction, including sedimentation and erosion; and the introduction of chemical pollutants (including herbicides).
Ospreys tend to exhibit strong site fidelity and nest reuse, including by individuals other than the original nest builders. In expanding populations, nest reuse rates are as high as 95% (Appendix D). Therefore, indirect impacts on this species resulting from the removal of the two historic nests on site were considered. A field survey conducted by RBC biologists on June 8, 2022, found five other active osprey nests within 1.5 miles of the project site. In addition, two inactive historic osprey nests and at least 10 structures that appear to be suitable for osprey nesting were located within 1.5 miles of the project site. Therefore, due to the presence of other unoccupied nesting habitat in the local area, removal of the on-site nests outside of breeding season would not likely result in a substantial adverse indirect effect to the local population.
Dust control will be implemented per the Air Quality Technical Report (Appendix C) to limit impacts of fugitive dust on sensitive habitat and species. The project would incorporate methods to control runoff, including site design,
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source control, and treatment control BMPs. The project would be required to meet NPDES regulations and incorporate BMPs during construction. In addition, permanent BMPs would be incorporated in accordance with the City’s SUSMP.
Furthermore, the project must comply with the guidelines set forth in the “Adjacency Management Issues ” discussion in Section 7.5 of the City’s MSCP Subarea Plan, which requires implementation of BMPs to ensure that adjacency issues do not arise due to project activities. These practices include, but are not limited to, the use of silt fencing or fiber rolls around work areas, restriction of cons truction activities to daylight hours, and use of non - invasive plant species in ornamental landscaping. Therefore, compliance with regional and local laws, regulations, and policies, would ensure that indirect impacts would be less than significant.
Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S.
Fish and Wildlife Service?
Of the 44.8 acre project iste, 44.5 acres are developed, 0.2 acres are disturbed habitat, and 0.1 acres are eucalyptus woodland. All of these vegetation communities are Tier IV habitat, and the project site is not located within preserved lands. Pursuant to the City MSCP Subarea Plan, impacts to Tier IV habitats are not considered significant. Thus, the proposed project would result in no impact to riparian habitats or other sensitive natural communities.
Would the project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? The constraints-level aquatic resources assessment conducted during preparation of the Biological Technical Report found that no jurisdictional aquatic resources, vernal pools, or any other aquatic features occur on site.
There are no depressions, drainage patterns, defined channels, and/or wetland vegetation. Additionally, the project site is composed solely of Huerhuero–Urban land complex soils and made lands, which are not considered to be hydric within San Diego County. As such, the project site does no t support areas that could be considered jurisdictional by the U.S. Army Corps of Engineers , RWQCB, California Coastal Commission , or CDFW . Thus, the proposed project would have no impact on any such resources.
Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
The proposed project site is not identified as a regional wildlife corridor per the City MSCP Subarea Plan. The site is already developed and fenced and there are no adjacent native habitats. The project does not propose any new barriers, such as new development or fencing, that would prevent wildlife movement; therefore, there would be no impacts on wildlife corridors due to project implementation.
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Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? The 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. 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.
Nonetheless, all new developments must adhere to specific guidelines listed above in the regulatory framework section under MSCP Adjacency Management Issues. Following is an analysis of the project’s compliance with each of the MSCP Adjacency Management Issues:
Drainage. Construction activities would be required to implement 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 project materials are discharged from the project site. All methods used would be consistent with requirements of the RWQCB and NPDES standards.
Lighting. Construction activities would be performed during daylight hours to avoid the need for light shielding.
Should 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 californica) or the least Bell’s vireo (Vireo bellii pusillus). Raptors, such as osprey, 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 re quired 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 preserve lands. As such no buffers are proposed.
In addition, the City‘s General Plan Policy E.1 (City of Chula Vista 2005) and Municipal Code Section 14.20 require conservation of the City’s sensitive biological resources and compliance with the City’s SUSMP. The project would not significantly impact City-designated sensitive areas and/or cause non-stormwater to discharge into stormwater systems. The project would comply with applicable drainage and stormwater permits and implement features such
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as vegetated detention/water quality basins to avoid the potential release of toxins, chemicals, and other elements from entering the City’s stormwater system.
The proposed project would involve removal of several trees. The 1.1-acre eucalyptus woodland habitat occurs along the eastern project site and within the small patches in the southern portion of the project site that are dominated by gum trees, which are not native and were planted or became naturalized in these areas. The City does not have any codes specific to tree removal or tree preservation. The closest related code would refer to the City Municipal Code 12.32.160, which states that any tree, palm, shrub or plant shall be authorized (by the City’s Department of Public Works) to be removed to remedy a dangerous condition.
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.
5.3.4 Level of Significance prior to Mitigation
Prior to mitigation, the proposed project would have potentially significant impacts associated with special-status wildlife. Impacts would be reduced to a less-than-significant level after implementation of the mitigation measures listed in Section 5.3.5.
5.3.5 Mitigation Measures
The following mitigation measures would be required in order to reduce potential biological impacts:
MM-BIO-1 Nesting Raptors. Vegetation clearing, structure removal, and ground disturbing activities should be conducted outside of the raptor nesting season (January 15 –July 31), where feasible. If these activities occur during the raptor nesting season, a qualified biologist shall conduct a nesting raptor survey within 3 days prior to any disturbance of the project site, including tree and shrub removal, disking, demolition activities, and grading. If active raptor nests are identified, the biologist shall establish suitable buffers around the nests depending on the level of activity within the buffer and species observed, and no construction activity may occur within the buffer areas until the nests are no longer occupied and the juvenile birds can survive independently from the nests, as determined by the qualified biologist . Raptor species will generally have an avoidance buffer of 500 feet; however, these buffers may be reduced in consultation with the California Department of Fish and Wildlife. In additi on, noise reduction measures consistent with the City of Chula Vista Multiple Species Conservation Program Subarea Plan shall be implemented if deemed necessary by the qualified biologist. If active nests are not identified, vegetation clearing, and ground-disturbing activities may commence. If ground-disturbing activities are scheduled outside the raptor nesting season, a nesting raptor survey will not be required.
MM-BIO-2 Osprey Nests. Should any osprey nests be established within the project site prior to commencement of construction, nesting structures shall be removed only during the non-breeding season (January 15 to July 31) and subject to monitoring by a qualified biologist during nest removal to ensure there are no direct impacts on osprey who may use the structures as perches during non-breeding season. If nests are found, the City and applicant will coordinate with CDFW
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and obtain a Scientific Collecting Permit if nest removal activities are required. Coordination with USFWS would also be required in order to ensure all protections under the Migratory Bird Treaty Act are adhered to.
MM-BIO-3 Nesting Birds. Vegetation clearing, structure removal, and ground-disturbing activities should be conducted outside of the nesting season (generally February 15 –August 31). If these activities occur during the nesting season, a qualified biologist will conduct a nesting bird survey within 3 days prior to any disturbance of the project site, including tree and shrub removal, disking, demolition activities, and grading. If active nests are identified, the biologist shall establish suitable buffers around the nests depending on the level of activity within the buffer and species observed, and the buffer areas shall be avoided until the nests are no longer occupied and the juvenile birds can survive independently from the nests. Bird species other than raptors will have an avoidance buffer of 300 feet. These buffers may be reduced in consultation with the California Department of Fish and Wildlife . If active nests are not identified, vegetation clearing and ground -disturbing activities may commence. If ground-disturbing activities are scheduled outside the nesting season, a nesting bird survey may not be required.
MM-BIO-4 Special-Status Bats. Pre-construction surveys for special-status bat species shall be conducted by a qualified biologist prior to demolition of buildings and other structures potentially used for roosting. Pre -construction surveys shall take place no more than 14 days prior to the start of demolition activities. If active roosts are identified, a biological monitor shall be employed to direct avoidance measures (identified in MM-BIO-5). Following completion of the survey, a report will be submitted to the City of Chula Vista that documents the findings.
MM-BIO-5 Avoidance Measures for Special-Status Bats. If special-status bat species are detected during pre-construction surveys, biological monitoring shall be conducted by a qualified biologist to ensure that project activities do not result in direct take. The biologist shall be present for all demolition activities in areas known or suspected to support roosting bats. The biological monitor shall perform clearance surveys at the start of each workday in areas scheduled for immediate demolition. The monitor will direct project activities away from special -status bat species, should they be found on site, to ensure that impacts on these species are avoided to the fullest extent possible. If present, bats are expected to flush from the project site at the onset of demolition activities. However, if they persist on site through demolition of non-roost site areas, consultation with the California Department of Fish and Wildlife may be required.
MM-BIO-6 MSCP Subarea Plan Consistency and Adjacency. The project must comply with the guidelines set forth in the ‘Adjacency Management Issues’ discussion of Section 7.5 of the City MSCP Subarea Plan, which requires implementation of best management practices to ensure that adjacency issues do not arise due to project activities. These practices include, but are not limited to, the use of silt fencing or fiber rolls around work areas, restriction of construction activities to daylight hours, and use of non- invasive plant species in ornamental landscaping. In addition, the project will comply with the City’s SUSMP which requires measures to control erosion during and following construction.
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5.3.6 Level of Significance after Mitigation
The mitigation measures listed in Section 5.3.5 would reduce potential impacts associated with biological resources to a less-than-significant level.
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5.4 Cultural and Tribal Cultural Resources
This section describes the existing cultural resources conditions of the project site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the proposed Rohr Wohl Specific Plan Project (project or proposed project). The discussion in this section is based on the Phase I Cultural Resources Survey for the project, prepared for the project by Brian F. Smith & Associates (BFSA) in August 2024 (Appendix E).
5.4.1 Existing Conditions
5.4.1.1 Regulatory Framework
Federal
National Historic Preservation Act
The National Historic Preservation Act (NHPA) (54 USC 300101 et seq.) establishes the nation’s policy for historic preservation and a program for the preservation of historic properties by requiring federal agencies to consider effects to significant cultural resources (e.g., historic properties) prior to undertaki ngs, which includes a project, activity, or program either funded, permitted, licenses, or approved by a federal agency.
Section 106 of the NHPA requires federal agencies to consider the effects of projects on historic properties (resources included in or eligible for the National Register of Historic Places [NRHP]). It also gives the Advisory Council on Historic Preservation and the state historic preservation offices an opportunity to consult. Federal agencies issuing permits for the proposed project will be required to comply with NHPA requirements.
Executive Order 11593, Protection and Enhancement of the Cultural Environment Executive Order 11593 (36 FR 8921) (1) orders the protection and enhancement of the cultural environment through requiring federal agencies to administer the cultural properties under their control in a spirit of stewardship and trusteeship for future generations; (2) initiates measures necessary to direct their policies, plans, and programs in such a way that federally owned sites, structures, and objects of historical, architectural, or archaeological significance are preserved, restored, and maintained f or the inspiration and benefit of the people; and (3) in consultation with the Advisory Council on Historic Preservation, institutes procedures to ensure that federal plans and programs contribute to the preservation and enhancement of non-federally owned sites, structures, and objects of historical, architectural, or archaeological significance (16 USC 470-1).
National Register of Historic Places
The NRHP is the nation’s official list of historic places. The NRHP is overseen by the National Park Service and requires that a property or resource eligible for listing in the NRHP meet one or more of the following four criteria at the national, state, or local level to ensure integrity and obtain official designation:
▪ Criterion A. The property is associated with events that have made a significant contribution to the broad patterns of our history.
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▪ Criterion B. The property is associated with the lives of persons significant to our past. Eligible properties based on this criterion are generally those associated with the productive life of the individual in the field in which the person achieved significance.
▪ Criterion C. The property embodies the distinctive characteristics of a type, period, or method of construction, or represents the work of a master, or possesses high artistic value, or represents a significant and distinguishable entity whose components lack individual distinction. ▪ Criterion D. The property has yielded, or is likely to yield, information important to prehistory or history.
In addition to meeting at least one of these four criteria, eligible or listed properties must also retain sufficient physical integrity of those features necessary to convey historic significance. The NRHP has identified the following seven aspects of integrity: (1) location, (2) design, (3) setting, (4) materials, (5) workmanship, (6) feeling, and (7) association.
Properties are nominated to the NRHP by the state historic preservation officer of the state in which the property is located, by the federal preservation officer for properties under federal ownership or control, or by the tribal preservation officer if on tribal lands. Listing in the NRHP provides formal recognition of a property’s historic, architectural, or archaeological significance base d on national standards used by every state. Once a property is listed in the NRHP, it becomes searchable in the NRH P database of research information. Documentation of a property’s historic significance helps encourage preservation of the resource.
State
California Environmental Quality Act
The California Environmental Quality Act (CEQA) requires that all private and public activities not specifically exempted be evaluated for the potential to impact the environment, including effects to historical resources.
Historical resources are recognized as part of the environment under CEQA. It defines historical resources as “any object, building, structure, site, area, or place, which is historically significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California” (Division I, California Public Resources Code, Section 5021.1[b]).
Lead agencies have a responsibility to evaluate historical resources against the California Register of Historical Resources (CRHR) criteria prior to making a finding as to a proposed project’s impacts to historical resources.
Mitigation of adverse impacts is required if the proposed project will cause substantial adverse change. Substantial adverse change include demolition, destruction, relocation, or alteration such that the significance of an historical resource would be impaired. While demolition and destruction are obvious significant impacts, it is more difficult to assess when change, alteration, or relocation crosses the threshold of substantial adverse change. The CEQA Guidelines provide that a project that demolishes or alters those physical chara cteristics of an historical resource that convey its historical significance (i.e., its character -defining features) can be considered to materially impair the resource’s significance.
The CRHR is used in the consideration of historic resources relative to significance for purposes of CEQA. The CRHR includes resources listed in, or formally determined eligible for, some California State Landmarks and Points of Historical Interest. Properties of local significance that have been designated under a local preservation ordinance (local landmarks or landmark districts), or that have been identified in a local historical resources inventory may be eligible for listing in the CRHR and are presum ed to be significant resources for purposes of CEQA unless a preponderance of evidence indicates otherwise.
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Generally, a resource is considered by the lead agency to be historically significant if the resource meets the criteria for listing in the CRHR (California Public Resources Code Section 5024.1; 14 CCR 4852), consisting of the following:
1. It is associated with events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States; or
2. It is associated with the lives of persons important to local, California, or national history; or
3. It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, or possesses high artistic values; or
4. It has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California, or the nation.
A unique archaeological resource, as defined by California Public Resources Code Section 21083.2, may be considered significant under CEQA. If a significant archaeological resource is identified, defined mitigation would be appropriately implemented. As used in this section, “unique archaeological resource” means an archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:
1. Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information.
2. Has a special and particular quality such as being the oldest of its type or the best available example of its type.
3. Is directly associated with a scientifically recognized important prehistoric or historic event or person.
Assembly Bill 52
CEQA was amended in 2014 through Assembly Bill (AB) 52, which created a new category of “tribal cultural resources” (TCRs) that must be considered under CEQA, and applies to all projects that file a Notice of Preparation or notice of negative declaration or mitigated negative declaration on or after July 1, 2015. AB 52 requires lead agencies to provide notice to and begin consultation with California Native American tribes that are traditionall y and culturally affiliated with the geographic area of a project if that tribe has requested, in writing, to be kept informed of projects by the lead agency prior to the determination whether a negative declaration, mitigated negative declaration, or environmental impact report will be prepared. If a tribe requests consultation within 30 days upon receipt of the notice, the lead agency must consult with the tribe. AB 52 also specifies mitigation measures that may be considered to avoid or minimize impacts on TCRs. Specifically, California Public Resources Code Section 21074 provides the following guidance:
(a) Tribal Cultural Resources are either of the following:
(1) Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either of the following:
(A) Included or determined to be eligible for inclusion in the California Register of Cultural Resources.
(B) Included in a local register of cultural resources as defined in subdivision (k) of §5020.1.
(2) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of §5024.1. In applying the criteria set forth in subdivision (c) of §5024.1 for the purposes of this
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paragraph, the lead agency shall consider the significance of the resource to a California Native American tribe.
(b) A cultural landscape that meets the criteria of subdivision (a) is a tribal cultural resource to the extent that the landscape is geographically defined in terms of the size and scope of the landscape.
(c) A historical resource described in Section 21084.1, a unique archaeological resource as defined in subdivision (g) of Section 21083.2, or a “nonunique archeological resource” as defined in subdivision (h) of Section 21083.2 may also be a tribal cultural resource if it conforms with the criteria of subdivision (a).
In the event that Native American human remains or related cultural material are encountered, Section 15064.5(e) of the state CEQA Guidelines (as incorporated from California Public Resources Code Section 5097.98) and Health and Safety Code Section 7050.5 define the subsequent protocol. In the event of the accidental discovery or recognition of any human remains, excavation or other disturbances shall be suspended on the site or any nearby area reasonably suspected to overlie adjacent human remains or related material. Protocol requires that a county- approved coroner be contacted to determine if the remains are of Native American origin. Should the coroner determine the remains to be Native American, the coroner must contact the Native American Heritage Commission (NAHC) within 24 hours. The most likely descendent may make recommendations to the landowner or the person responsible for the excavation work, for means of treating, with appropriate dignity, the human remains and any associated grave goods, as provided in California Public Resources Code Section 5097.98 (14 CCR 15064.5[e]).
California Native American Graves Protection and Repatriation Act The California Native American Graves Protection and Repatriation Act (California Repatriation Act) (25 USC, Chapter 32), enacted in 2001, requires all state agencies and museums that receive state funding and that have possession or control over collectio ns of human remains or cultural items, as defined, to complete an inventory and summary of these remains and items on or before January 1, 2003, with certain exceptions. The California Repatriation Act also provides a process for the identification and rep atriation of these items to the appropriate tribes.
Senate Bill 18
Senate Bill ( SB) 18, approved in 2004, amends the California Civil Code and the California Government Code, requiring cities and counties to contact and consult with California Native American tribes prior to adopting or amending any general plan or specific plan, or desi gnating land as open space in order to preserve or mitigate impacts to specified Native American places, features and objects that are located within the city’s or county’s jurisdiction. SB 18 also requires cities and counties to hold in strict confidence any information about the specific identity, location, character, or use of these resources. In 2005, the California Governor’s Office of Planning and Research published Tribal Consultation Guidelines to guide cities and counties on the process of engaging in consultation in accordance with SB 18 (OPR 2005). NAHC maintains a list of California Native American Tribes with whom cities and counties must consult pursuant to SB 18.
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Local
City of Chula Vista Historic Designation Ordinance
The City of Chula Vista Historic Designation Ordinance (Title 21, Chula Vista Municipal Code (CVMC) Section
21.04.100) (City of Chula Vista 2011a) establishes general standards by which the Historical Significance of a Historical Resource is judged as eligible for designation on the Chula Vista Register:
1. A Resource is at least 45 years old; and
2. A Resource possesses historical Integrity defined under the CVMC §21.04.100 (discussed below) and the resource is determined to have historical significance by meeting at least one of the following criteria:
1. It is associated with an event that is important to prehistory or history on a national, state, regional, or local level.
2. It is associated with a person or persons that have made significant contributions to prehistory or history on a national, state, or local level.
3. It embodies those distinctive characteristics of a style, type, period, or method of construction, or represents the work of a master or important creative individual, and/or possesses high artistic values.
4. It is an outstanding example of a publicly owned Historic Landscape, that represents the work of a master landscape architect, horticulturalist, or landscape designer, or a publicly owned Historical Landscape that has potential to provide important informa tion to the further study of landscape architecture or history.
5. It has yielded or may be likely to yield information important in prehistory or the history of Chula Vista, the state, region, or nation.
Additionally, the designation of an exceptional historical resource may be considered only if:
The Historic Preservation Committee (HPC) considered and makes a recommendation to the Council; and It has been demonstrated through expert technical analysis and verifiable evidence that all of the following findings of fact are made:
a. The resource meets criteria and the findings of fact for designation found in subsections (A)(1) and (A)(2) of this section; and
b. The resource is the best representative sample of its kind or the last of its kind; and c. The resource is an exceptionally important component of the City’s history and loss or impairment of the resource would be detrimental to the City’s heritage; and Four-fifths vote of the Council vote to designate the resource as an exceptional historical resource.
City of Chula Vista Historic Preservation District
According to CVMC Section 21.06.010, the purpose of the Historic Preservation District is “To identify, designate, and preserve existing neighborhoods and Resources grouped either geographically or thematically as defined in
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Chula Vista Municipal Code §21.03.063 and §21.03.131.” National Register Bulletin No. 15 (NPS 1997) defines a district as possessing:
… a significant concentration, linkage, or continuity of sites, buildings, structures, or objects united historically or aesthetically by plan or physical development … The identity of a district results from the interrelationship of its resources, which c an convey a visual sense of the overall historic environment or be an arrangement of historically or functionally related properties.
According to CVMC Section 21.06.050, the eligibility criteria for Historic Preservation Districts are as follows:
▪ Criterion 1: The proposed Historic Preservation District is identified with an event, person, or group that contributed significantly to the City’s prehistory or history. ▪ Criterion 2: Buildings, structures, objects, sites, signs or landscape elements within the proposed Historic Preservation District exemplify a particular architectural style, way of life, or period of development in the city. ▪ Criterion 3: Buildings or structures within the proposed Historic Preservation District are the best remaining examples of an architectural style or are verified as having been designed or constructed by a master architect, designer or builder, and retain integrity.
City of Chula Vista Historic Preservation Program
The City’s Historic Preservation Program establishes a screening process for determining the historical significance of potential historical resources that are 45 years or older, that have not previously been surveyed or designated as historic, and that are proposed for alteration or demolition (City of Chula Vista 2011b). The Historic Preservation Program is intended to be a resource document that will educate and inform the user on the City’s goals, policies, and procedures for preservation of historical resources and may be used for all preservation activities in the City.
The Historic Preservation Program provides the following:
1. Provides user-friendly preservation guides and procedures for both city staff and members of the public.
Establish consistency between historic preservation goals and land-use policies by incorporating a historical significance review process and Certificate of Appropriateness permit process for historical resources into the building permit and discretionary project review process.
Adopt a more detailed Historic Preservation Ordinance that provides clear and easy to follow processes and procedures and complies with the requirements for Certified Local Government (CLG) status.
Attain and maintain CLG status.
Establish process and procedures for the identification and survey of historical resources.
Provide reference and technical assistance for preservation activities.
Utilize the State Historical Building Code.
Encourage the use of the Secretary of the Interior ’s Standards for Treatment of Historical Properties:
Preservation, Rehabilitation, Restoration, and Reconstruction.
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City of Chula Vista General Plan – Environmental Element The Environmental Element of the City of Chula Vista General Plan (Chapter 9, Section 3.1.9) (City of Chula Vista 2005) specifically addresses potential impacts to cultural resources and outlines policies to mitigate negative impacts. The objective and policies protecting cultural and historical resources are outlined as follows:
Objective E-9: Protect Chula Vista’s important cultural resources and support and encourage their accessibility to the public.
Policy E-9.1: Continue to assess and mitigate the potential impacts of private development and public facilities and infrastructure to cultural resources, in accordance with the California Environmental Quality Act.
Policy E-9.2: Support and encourage the accessibility of Chula Vista’s important cultural resources to the public for educational; religious; cultural; scientific; and other purposes, including the establishment of museums and facilities accessible to the public, where such resources can be appropriately studied, exhibited, curated, etc.
Policy E-9.3: Discourage disruption, demolition, and other negative impacts to historic cultural resources.
5.4.1.2 Existing Cultural Setting
Prehistoric and Ethnohistoric Periods
Evidence for continued human habitation in the San Diego area spans the past 10,000 years. Various attempts to analyze the variability of archaeological assemblages over this broad period have resulted in the development of several cultural chronologies; s ome of these are based on geological time, most on temporal trends in archaeological assemblages, and others are interpretive reconstructions. Each of these reconstructions details similar trends in portfolio composition. This study uses a common set of ge neral terms to describe chronological trends in assemblage formation: Early Man (pre 8500 BC), Paleo Indian (8500–6000 BC), Early Archaic (6000 BC– AD 0), and Late Prehistoric (AD 0–1769) (Appendix E).
History of San Diego
The history of San Diego can be divided into several distinct periods. The Exploration Period began in 1542 with the landing of Juan Rodriquez Cabrillo, and the Spanish Colonial Period began in 1769 with the colonization of the San Diego area. During this period, the Spanish established missions and forts to control the land and convert the native population. The Mexican Period began in 1821 after Mexico gained independence from Spain and ended with Mexican–American War of 1846 –1848. The Anglo -American Period began with the invasion of California by US troops during the war, and the acquisition of strategic Pacific ports and land was one of the objectives of the war.
The cattle boom of the early 1850s led to the decline of cattle ranching and the expansion o f agriculture. The no fence act allowed for the expansion of unfenced farms crucial in an area where fencing materials were practically unavailable. After World War I, the growth of San Diego Bay as a home base for the Pacific Fleet and the aircraft industry in the 1920s led to the growth of the county as a whole and recreation areas were established in the mountain and desert areas (Appendix E).
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NAHC Sacred Lands File Search and Outreach
BFSA requested an NAHC search of the Sacred Lands File on May 10, 2022, to check for the presence of sacred sites or locations of religious or ceremonial importance within the vicinity of the project, which returned negative results. The NAHC additionally provided a list of Native American tribes and individuals/organizations that might have knowledge of cultural resources in this area.
Following the NAHC response, letters were sent to the NAHC -listed tribal representatives with the intent of requesting information, opinions , or concerns relating to the proposed project impacts. These letters contained a brief description of the planned project, reference maps, and a summary of the NAHC Sacred Lands File search results.
Tribal Consultation
The proposed project is also subject to compliance with AB 52 (California Public Resources Code Section 21074) which requires consideration of impacts to TCRs as part of the CEQA process. AB 52 requires the City, as the lead agency responsible for CEQA compliance for the proposed project, to notify any groups (who have requested notification) of the proposed project who are traditionally or culturally affiliated with the geographic area of the project.
Because AB 52 is a government-to-government process, all records of correspondence related to AB 52 notification and any subsequent consultation are on file with the City. On May 3, 2024, the City sent notification letters pursuant to AB 52 and SB 181 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 responses has been reciprocated. Consultation with Native American tribes is ongoing.
5.4.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to cultural resources and TCRs are based on Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). According to Appendix G, a significant impact related to cultural resources would occur if the project would:
1. Cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5.
2. Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5.
3. Disturb any human remains, including those interred outside of dedicated cemeteries.
According to Appendix G, a significant impact related to TCRs would occur if the project would:
4. Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code § 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
1 SB 18 requires the City to contact and consult with California Native American tribes prior to adopting or amending any gener al plan or specific plan, or designating land as open space in order to preserve or mitigate impacts to specified Native American places, features and objects that are located within the city’s or county’s jurisdiction.
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a. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k). b. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code § 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code § 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.
5.4.3 Impacts
Would the project cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5?
Planning Areas B -1 and B -2 are vacant, and soil is being remediated, as of 2024, per the RWQCB CAO. The warehouse in Planning Area A was also renovated as part of the remediation process required by the RWQCB CAO.
The railroad line that bisects Planning Area A from Planning Areas B -1/B-2, which was originally recorded as SDI - 13,073H in 1993 by Donald Laylander, and would not be impacted by the proposed project. The railroad line, which was constructed in 1888, runs from southern San Diego to Glorieta Bay on Coronado Island. The portion of the alignment located within the project area was delineated as Segment D and c onsists of a 40 -foot-wide, 2.8-mile segment of standard -gauge steel rails affixed to wooden ties by steel plates and spikes. The railroad line has previously been determined not eligible for the NRHP but is eligible and listed in the San Diego Register of Historical Resources (Appendix E) . However, it was determined not to be eligible for listing on the Chula Vista Register or CRHR. The portion of the rail line between Planning Areas A and B -1/B-2 would be left in place and the project would not impact the rail line. Impacts would be less than significant.
Nonetheless, t he 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, an assessment and evaluation o f the resource would be conducted, potentially resulting in the determination that the resource is historical in accordance with the definition outlined in CEQA Guidelines Section 15064.5. As a result, the project has a potential to impact an d thus cause a substantial adverse change in the significance of a yet unknown historical resource. Impacts would be potentially significant and mitigation would be required .
Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5?
As detailed in Appendix E, an archaeological record search was conducted at San Diego State University’s South Coastal Information Center to determine if there were previously recorded archeological resources on or near the subject property. In addition, background research, including a review of a geotechnical report; and an archaeological pedestrian survey were conducted as part of Appendix E to address potential impacts to archaeological resources. The results of the records search did not identify the presence of any previously recorded archaeological sites within the project site . However, 15 recorded resources and 4 historic addresses were identified within 1 mile of the project site (Table 5.4-1).
Given the presence of resources in proximity to the project site, there is potential that buried archeological deposits are present within the boundaries of the project site, which may have been masked by current conditions at the site. Therefore, it is recommended that implementation of a cultural resources monitoring program be conducted
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by an archaeologist and Native American representative during any additional grading activities. Prior to implementation of mitigation, impacts would be potentially significant.
Would the project disturb any human remains, including those interred outside of dedicated cemeteries? No evidence of human remains, including those interred outside of formal cemeteries, was discovered during the records search, literature review, field survey, or site testing and evaluation. Further, the site has never been used as a formal cemetery and it is not anticipated that the project would result in the disturbance of human remains.
However, in the unlikely event that excavation activities during construction inadvertently uncover buried human remains, they would require handling in accordance with existing regulations. In accordance with Section 7050.5 of the California Health and Safety Code, if human remains are found, the County Coroner shall be immediately notified of the discovery. No further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains shall occur until the County Coroner has determined, within 2 working days of notification of the discovery, the appropriate treatment and disposition of the human remains. If the County Coroner determines that the remains are, or are believed to be, Native American, the County Coroner shall notify NAHC in Sacramento within 24 hours. In accordance with California Public Resources Code Section 5097.98, NAHC must immediately notify those persons it believes to be the most likely descendants from the deceased Native American.
The most likely descendants shall complete their inspection within 48 hours of being granted access to the site.
The most likely descendants would then determine, in consultation with the property owner, disposition of the human remains. Prior to mitigation, impacts would be potentially significant.
Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code § 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k).
No previously recorded TCRs were listed in the CRHR or a local register were identified within the proposed project area of potential effects. The railroad line has previously been determined not eligible for the NRHP but is eligible and listed in the San Diego Register of Historical Resources (Appendix E) . However, it was determined not to be eligible for listing on the Chula Vista Register or CRHR. The portion of the rail line between Planning Areas A and B- 1/B-2 would be left in place and the proposed project would not impact the rail line. Therefore, no resources listed or eligible for listing in the CRHR or in a local register would be impacted by the proposed project.
In the event that unanticipated resources are encountered during project implementation, an assessment and evaluation of the resource would be conducted, potentially resulting in the determination that the resource is historical in accordance with the defin ition outlined in CEQA Guidelines Section 15064.5. As a result, the project has the potential to cause a substantial adverse change in the significance of a yet unknown historical resource.
Therefore, impacts would be potentially significant and mitigation would be required.
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A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code § 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code § 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.
AB 52 requires that lead agencies evaluate a project’s potential to impact tribal cultural resources. Such resources include “sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are eligible for inclusion in the California Register of Historical Resources or included in a local register of historical resources.” AB 52 also gives lead agencies the discretion to determine, supported by substantial evidence, whether a resource qualifies as a tribal cultural resource. Also, per AB 52 (specifically , California Public Resources Code Section 21080.3.1), Native American consultation is required upon request by a California Native American tribe that has previously requested that the City provide it with notice of such projects.
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 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 responses has been reciprocated. Consultation with Native American tribes is ongoing.
As discussed under Threshold No. 3, it is not anticipated that the project would result in the disturbance of human remains. However, in the unlikely event that excavation activities during construction inadvertently uncover buried human remains, impacts could occur. Therefore, there is still potential for unknown subsurface TCRs to be present on site. Proposed grading activities have the potential to disturb unknown subsurface TCRs. Therefore, impacts would be potentially significant and mitigation (MM-CUL-1) is required.
5.4.4 Level of Significance prior to Mitigation
Prior to mitigation , the proposed project would have significant impacts associated with historical resources, archaeological resources, human remains, and TCRs.
5.4.5 Mitigation Measures
The following mitigation measure s are recommended to reduce potentially significant impacts to unknown subsurface historical or archaeological resources, human remains, and TCRs within the proposed project site:
MM-CUL-1 Cultural Resources Avoidance and Curation Measures.
A. Prior to beginning construction activities, the project archaeologist and Native American representative shall attend any pertinent preconstruction meetings with the construction manager and/or grading contractor in order to provide recommendations and answer questions relating to the archaeological monitoring program. The project archaeologist shall be familiar with the cultural inventory conducted for the current project and shall be prepared to introduce any pertinent information concerning expectati ons and probabilities of discovery during ground - disturbing activities. Prior to the initiation of construction, the cultural consultant shall acquire all evaluation information and the draft evaluation report, if a report was prepared.
B. Both an archaeological monitor familiar with local resources and a Native American monitor shall be present full time during the initial disturbance of soil with potential to contain cultural
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deposits. All areas of initial project -related subsurface disturbance shall be assumed to have the potential to contain cultural deposits. Monitoring of initial ground disturbance shall not exceed a depth of 5 feet (1.5 meters) unless cultural resources are identified or if, through direct inspection of subsurface exposures by the project Archaeologist, an area is observed to have the potential to support the presence of archaeological deposits at greater depths.
Cultural resources monitoring may be reduced from initial full-time monitoring to periodic spot checks, or discontinued if appropriate, once the project archaeologist determines that there is little or no risk of encountering cultural material.
C. Daily archaeological and Native American monitoring logs shall be prepared. Logs shall include monitor names and affiliations, a description of general activities observed, cultural discoveries, as well as comments or concerns as applicable.
D. In the event of an archaeological discovery, and when requested by the archaeological monitor or Native American monitor, the resident contractor will divert, redirect, or temporarily halt ground disturbing activities in the area of discovery or impacts to allow for preliminary inspection of potentially significant archaeological resources or impacts. The significance of the discovered resources or impacts shall be determined by the archaeologist, in consultation with the City of Chula Vista (City). For significant cultural resources, a Research Design and Data Recovery Program shall be prepared and carried out to mitigate impacts before grading activities in the area of discovery shall be allowed to resume.
E. The project archaeologist shall be responsible for ensuring that all cultural materials collected will be cleaned, catalogued, and curated permanently with an appropriate institution; that a letter of acceptance from the curation institution has been subm itted to the City; that all artifacts are analyzed to identify function and chronology as they relate to the history of the area; that faunal material will be identified as to species; and that specialty studies are completed, as appropriate. The project archaeologist shall make a good-faith effort to ensure that all archaeological material collected through previous work is appropriately curated with any material recovered through construction monitoring.
F. If human remains are discovered, work shall halt in that area and procedures set forth in the California Public Resources Code (Section 5097.98) and State Health and Safety Code (Section 7050.5) shall be followed by the archaeological monitor after notification to the County Coroner by the project Archaeologist. If Native American remains are present, the County Coroner shall contact the Native American Heritage Commission to designate a Most Likely Descendant, who shall arrange for the dignified disposition and treatment of the remains.
G. Within 3 months following the completion of monitoring, two copies of a monitoring results report (even if negative) and/or evaluation report, if applicable, that describes the results, analysis, and conclusions of the archaeological monitoring program (with appropriate graphics) shall be submitted to City.
H. For significant archaeological resources encountered during monitoring, the Research Design and Data Recovery Program shall be included as part of the final evaluation monitoring report.
Two copies of the final monitoring report for significant archaeological resources, if required, shall be submitted to the City. This final monitoring report should also incorporate a summary of the evaluation results and analyses previously conducted within the project area.
I. The archaeologist shall be responsible for recording (on the appropriate CA DPR 523 Series forms) any significant or potentially significant resources encountered during the archaeological monitoring program in accordance with Section 106 and the City’s Cultural
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Resources Guidelines, and submittal of such forms to the South Coastal Information Center at San Diego State University with the final monitoring results report.
5.4.6 Level of Significance after Mitigation
Implementation of MM-CUL-1 would reduce potentially significant impacts to archeological resources, human remains, and TCRs to less than significant.
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5.5 Energy
This section describes the existing energy 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 discussion in this section is based on the Air Quality and Greenhouse Gas Emissions Technical Report prepared for the project by Dudek in August 2024. The complete report is contained in Appendix C of this EIR.
5.5.1 Existing Conditions
5.5.1.1 Regulatory Framework
Federal
Federal Energy Policy and Conservation Act and CAFE Standards In 1975, Congress enacted the federal Energy Policy and Conservation Act, which established the first fuel economy standards, known as the Corporate Average Fuel Economy (CAFE) standards, for on-road motor vehicles in the United States. Pursuant to the act, the National Highway Traffic Safety Administration (NHTSA) is responsible for establishing additional vehicle standards. In 2012, new CAFE standards for passenger cars and light trucks were approved for model years 2017 through 2021 (77 FR 62624–63200). Fuel economy is determined based on each manufacturer’s average fuel economy for the fleet of vehicles available for sale in the United States.
Energy Independence and Security Act of 2007
On December 19, 2007, the Energy Independence and Security Act of 2007 (EISA) was signed into law. In addition to setting increased CAFE standards for motor vehicles, the EISA facilitates the reduction of national GHG emissions by requiring the following:
▪ Increasing the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard (RFS) that requires fuel producers to use at least 36 billion gallons of biofuel in 2022. ▪ Prescribing or revising standards affecting regional efficiency for heating and cooling products, procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances. ▪ Requiring approximately 25% greater efficiency for light bulbs by phasing out incandescent light bulbs between 2012 and 2014; requiring approximately 200% greater efficiency for light bulbs, or similar energy savings, by 2020.
▪ While superseded by the U.S. Environmental Protection Agency (EPA) and NHTSA actions described previously, establishing miles per gallon targets for cars and light trucks and directing the NHTSA to establish a fuel economy program for medium-and heavy-duty trucks and create a separate fuel economy standard for trucks.
This federal legislation requires ever -increasing levels of renewable fuels (the RFS) to replace petroleum (EPA 2023). EPA is responsible for developing and implementing regulations to ensure that transportation fuel sold in the United States contains at least a minimum volume of renewable fuel.
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The RFS program was created under the Energy Policy Act and established the first renewable fuel volume mandate in the United States. As required under the Energy Policy Act, the original RFS program required 7.5 billion gallons of renewable fuel to be blended into gasoline by 2012. Under the EISA, the RFS program was expanded in several ways that laid the foundation for achieving significant reductions in GHG emissions from the use of renewable fuels, reducing imported petroleum, and encouraging the develo pment and expansion of the renewable fuels sector in the United States. The updated program is referred to as “RFS2” and includes the following:
▪ The EISA expanded the RFS program to include diesel, in addition to gasoline. ▪ The EISA increased the volume of renewable fuel required to be blended into transportation fuel from 9 billion gallons in 2008 to 36 billion gallons by 2022. ▪ The EISA established new categories of renewable fuel and set separate volume requirements for each one. ▪ The EISA required EPA to apply lifecycle GHG performance threshold standards to ensure that each category of renewable fuel emits fewer GHGs than the petroleum fuel it replaces.
Additional provisions of the EISA address energy savings in government and public institutions, research for alternative energy, additional research in carbon capture, international energy programs, and the creation of green (environmentally beneficial) jobs.
Intermodal Surface Transportation Efficiency Act of 1991 The Intermodal Surface Transportation Efficiency Act (ISTEA) of 1991 promoted the development of intermodal transportation systems to maximize mobility and address national and local interests in air quality and energy.
ISTEA contained factors for metropolitan planning organizations to address in developing transportation plans and programs, including some energy ‐related factors. To meet the new ISTEA requirements, metropolitan planning organizations adopted policies defining the social, economic, energy, a nd environmental values guiding transportation decisions.
Transportation Equity Act for the 21 st Century
The Transportation Equity Act for the 21st Century was signed into law in 1998 and builds on the initiatives established in the ISTEA legislation (previously discussed). The Transportation Equity Act authorizes highway, highway safety, transit, and other efficient surface transportation programs. The act continues the program structure established for highways and transit under ISTEA, such as flexibility in the use of funds, emphasis on measures to improve the environment, and focus on a strong planning process as the foundation of transportation decisions. The Transportation Equity Act also provides for investment in research and its application to maximize the performance of the transportation system through, for example, deployment of intelligent transportation systems to help improve operations and management of transportation systems and vehicle safety.
State
Warren -Alquist Act
The California Legislature passed the Warren -Alquist Act in 1974. The Warren -Alquist Act created the California Energy Commission (CEC). The legislation also incorporated the following three key provisions designed to address the demand side of the energy equation:
▪ It directed the CEC to formulate and adopt the nation’s first energy conservation standards for both buildings constructed and appliances sold in California.
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▪ The act removed the responsibility of electricity demand forecasting from the utilities, which had a financial interest in high demand projections, and transferred it to a more impartial CEC. ▪ The CEC was directed to embark on an ambitious research and development program, with a particular focus on fostering what were characterized as non-conventional energy sources.
State of California Energy Action Plan
The CEC and the California Public Utilities Commission (CPUC) approved the first State of California Energy Action Plan in 2003. The Energy Action P lan established shared goals and specific actions to support that adequate, reliable, and reasonably priced electrical power and natural gas supplies are provided, and identified policies, strategies, and actions that are cost effective and environmentally sound for California’s consumers and taxpayers.
In 2005, CEC and CPUC adopted a second Energy Action Plan to reflect various policy changes and actions of the preceding 2 years.
At the beginning of 2008, CEC and CPUC determined that it was not necessary or productive to prepare a new Energy Action Plan. This determination was based, in part, on a finding that the state’s energy policies have been significantly influenced by the pa ssage of Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006 (discussed below). Rather than produce a new Energy Action Plan, CEC and CPUC prepared an update that examines the state’s ongoing actions in the context of global climate change.
Assembly Bill 32 and S enate Bill 32
In 2006, the State Legislature enacted AB 32, the California Global Warming Solutions Act of 2006. AB 32 requires California to reduce its GHG emissions to 1990 levels by 2020. In 2016, the Legislature enacted Senate Bill (SB) 32, which extended the horizo n year of the state’s codified GHG reduction planning targets from 2020 to 2030, requiring California to reduce its GHG emissions to 40% below 1990 levels by 2030. In accordance with AB 32 and SB 32, the California Air Resources Board (CARB) prepares scopi ng plans to guide the development of statewide policies and regulations for the reduction of GHG emissions. Many of the policy and regulatory concepts identified in the scoping plans focused on increasing energy efficiencies, using renewable resources, and reducing the consumption of petroleum-based fuels (such as gasoline and diesel). As such, the state’s GHG emissions reduction planning framework creates co-benefits for energy-related resources.
Senate Bills 1078 (2002), 107 (2006), X1 -2 (2011), 350 (2015), 100 (2018), SB 1020 (2022) Senate Bill (SB) 1078 established the California Renewable Portfolio Standards (RPS) Program and required that a retail seller of electricity purchase a specified minimum percentage of electricity generated by eligible renewable energy resources as defined in any given year, culminating in a 20% standard by December 31, 2017. These retail sellers include electrical corporations, community choice aggregators, and electric service providers. The bill relatedly required the CEC to certify eligible renewable energy resources, design and implement an accounting system to verify compliance with the RPS by retail sellers, and allocate and award supplemental energy payments to cover above-market costs of renewable energy.
SB 107 (2006) accelerated the RPS established by SB 1078 by requiring that 20% of electricity retail sales be served by renewable energy resources by 2010 (not 2017). Additionally, SB X1-2 (2011) requires all California utilities to generate 33% of their e lectricity from eligible renewable energy resources by 2020. Specifically, SB X1-2 sets a three -stage compliance period: by December 31, 2013, 20% had to come from renewables; by December 31, 2016, 25% had to come from renewables; and by December 31, 2020, 33% will come from renewables.
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SB 350 (2015) expanded the RPS because it requires retail seller and publicly owned utilities to procure 50% of their electricity from eligible renewable energy resources by 2030, with interim goals of 40% by 2024 and 45% by 2027.
SB 100 (2018) accelerated and expanded the standards set forth in SB 350 by 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 qualifying renewable energy sources. SB 100 also 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 by 2045. This bill requires t hat the achievement of 100% zero -carbon electricity resources does not increase the carbon emissions elsewhere in the western grid and that the achievement not be achieved through resource shuffling.
SB 1020 (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
▪ 100% by December 31, 2045
Consequently, utility energy generation from non -renewable resources is expected to be reduced based on implementation of the RPS requirements described above.
California Building Standards
The California Building Standards Code was established in 1978 and serves to enhance and regulate California’s building standards . While not initially promulgated to reduce GHG emissions, Part 6 of Title 24 specifically established Building Energy Efficiency Standards that are designed to ensure that new and existing buildings in California achieve energy efficiency and preserve outdoor and indoor environmental quality. These energy efficiency standards are reviewed every 3 years by the Building Standards Commission and the California Energy Commission (CEC) and revised if necessary ( California Public Resources Code Section 25402[b][1]). The regulations receive input from members of industry, as well as the public, to “reduce the wasteful, uneconomic, inefficient, or unnecessary consumption of energy” ( California Public Resources Code Section 25402). These regulations are carefully scrutinized and analyzed for technological and economic feasibility ( California Public Resources Code Section 25402[d]) and cost effectiveness (California Public Resources Code Section 25402[b][2–3]). 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 current Title 24 standards are the 2022 Title 24 building energy efficiency standards, which became effective January 1, 2023.
In addition to 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), which is commonly referred to as California’s Green Building Standards (CALGreen), 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 requirements), water conservation, material conservation, and interior air quality.
Integrated Energy Policy Report
The CEC is responsible for preparing integrated energy policy reports that identify emerging trends related to energy supply, demand, and conservation; public health and safety; and maintenance of a healthy economy. The
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CEC’s 2021 Integrated Energy Policy Report discusses the state’s policy goals of decarbonizing buildings, ensuring energy reliability, decarbonizing the state’s gas system, the state’s energy demand forecast, and quantifying the benefits of the clean trans portation program (CEC 2022). SB 100 calls for California’s electricity system to become 100% zero -carbon by 2045. CEC, CPUC, and CARB are working together to identify pathways to deeply decarbonize the state’s electricity system in response to SB 100. The aim is to leverage California’s clean electricity system to decarbonize, or remove carbon from, other portions of the state’s energy system. Over time, these policies and trends would serve to beneficially reduce a project’s GHG emissions profile and energy consumption as they are implemented.
State Vehicle Standards
In response to the transportation sector accounting for more than half of California’s CO2 emissions, AB 1493 was enacted in 2002. AB 1493 required CARB to set GHG emissions standards for passenger vehicles, light-duty trucks, and other vehicles determined by the state board to be vehicles whose primary use is noncommercial personal transportation in the state. The bill required that CARB set GHG emissions standards for motor vehicles manufactured in 2009 and all subsequent model years. The 2009 –2012 standards resulted in a reduction in approximately 22% of GHG emissions compared to emissions from the 2002 fleet, and the 2013–2016 standards resulted in a reduction of approximately 30%.
In 2012, CARB approved a new emissions -control program for model years 2017 through 2025. The program combines the control of smog, soot, and global -warming gases with requirements for greater numbers of zero - emissions vehicles into a single package of standards called Advanced Clean Cars, detailed below. By 2025, when the rules would be fully implemented, new automobiles would emit 34% fewer global-warming gases and 75% fewer smog-forming emissions.
Although the focus of the state’s vehicle standards is on the reduction of air pollutants and GHG emissions, one co-benefit of implementation of these standards is a reduced demand for petroleum-based fuels.
Advanced Clean Car Program
The Advanced Clean Cars (ACC) I 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 of regulations: the Low-Emission Vehicle (LEV) regulation for criteria air pollutant and GHG emissions and a technology forcing regulation for zero-emission vehicles (ZEV) that contributes to both types of emission reductions. 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 has implemented new emission standards to reduce smog -forming emissions beginning with 2015 model year vehicles. It is estim ated that in 2025 cars will emit 75 percent less smog-forming pollution than the average new car sold in 2015. The ZEV program will act as the focused technology of the ACC I program by requiring manufacturers to produce increasing numbers of ZEVs and plug-in hybrid EVs in the 2018 to 2025 model years.
The ACC II program is currently in development to establish 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. The main objectives of ACC II are:
Maximize criteria and GHG emission reductions through increased stringency and real-world reductions.
Accelerate the transition to ZEVs through both increased stringency of requirements and associated actions to support wide-scale adoption and use.
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An ACC II rulemaking package, which considers technological feasibility, environmental impacts, equity, economic impacts, and consumer impacts, was approved by the Office of Administrative Law on November 30, 2022 . This requires that, by 2035, all new passenger cars, trucks, and sports utility vehicles (SUVs) will be zero emissions by 2035. However, as detailed previously, EPA and NHTSA published the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule, which revokes California’s authority to set its own GHG emissions standards and set ZEV mandates in California. Since California and 22 other states, as well as the District of Columbia and four cities, filed suit against the EPA and a petition for reconsideration of the SAFE Rule, the ACC II rulemaking’s course may vary depending on the results of this ongoing litigation.
Advanced Clean Trucks Program
The purpose of the ACT Regulation (June 2020) is to accelerate the market for zero -emission vehicles 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 2021). Requiring medium - and heavy - duty vehicles to transition to zero -emissions technology will reduce health risks to people living in and vi siting California and is needed to help California meet established near - and long -term air quality and climate mitigation targets. The regulation has two components including (1) a manufacturer sales requirement and (2) a reporting requirement:
Zero-emission truck sales: Manufacturers who certify Class 2b -8 chassis or complete vehicles with combustion engines will be required to sell zero-emission trucks as an increasing percentage of their annual California sales from 2024 to 2035. By 2035, zero-emission truck/chassis sales would need to be 55% of Class 2b – 3 truck sales, 75% of Class 4 – 8 straight truck sales, and 40% of truck tractor sales.
Company and fleet reporting: Large employers including retailers, manufacturers, brokers and others will be required to report information about shipments and shuttle services. Fleet owners, with 50 or more trucks, will be required to report about their ex isting fleet operations. This information will help identify future strategies to ensure that fleets purchase available zero -emission trucks and place them in service where suitable to meet their needs.
Local
San Diego Gas & Electric (SDG&E) Individual Integrated Resource Plan SDG&E’s Conforming Portfolio identifies a need for approximately 700 gigawatt-hours of incremental renewable power in addition to the assumed increases in energy efficiency and behind -the-meter solar, to meet the 2030 planning target (approximately 4% of t he total energy in the portfolio) (SDG&E 202 1). SDG&E’s Conforming Portfolio demonstrates that the utility has reduced its GHG emissions in the early years of the planning period, reflecting its current position in relation to its RPS targets—in 2018, approximately 45% of its energy mix came from delivering renewable resources (compared to an RPS requirement of 29%), it has aggressively adopted energy storage, and does not use coal resources. SDG&E is fully compliant with RPS and long-term contracting requirements. SDG&E continues its efforts to meet resource-specific renewable procurement mandates, as required, but does not expect to procure additional resources for RPS compliance purposes until after 2030.City of Chula Vista Climate Action Plan Since 2000, Chula Vista has been implementing a Climate Action Plan (CAP) to address climate change issues and its impacts on the City. The City’s Climate Action Plan is a group of documents including various GHG emission inventories, the original Carbon D ioxide Reduction Plan (2000), Climate Mitigation Plan (2008), new Climate Adaptation Plan (2011), and Municipal Action (2014). The City’s Increased Energy Efficiency Ordinance, Green
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Building Standards, and Solar Ready Ordinances are products of the Climate Action Plan. Actions and goals of the 2017 CAP relate to energy and water efficient buildings, smart growth and clean transit, zero waste, increased local energy and water resources, leading by example, and community resilience (City of Chula Vista 2017).
Chula Vista Climate Adaptation Strategies – Implementation Plans The Climate Adaptation Strategies – Implementation Plans document developed by the Climate Change Working Group includes 11 strategies to adapt Chula Vista to the potential impacts of global climate change, including energy supply. The strategies to reduce energy demand include cool paving, shade trees, and cool roofs. For each strategy, the plans outline specific implementation components, critic al steps, costs, and timelines. To limit the necessary staffing and funding required to implement the strategies, the plans were also designed to build upon existing municipal efforts rather than create new, stand-alone policies or programs. Initial implementation of all 11 strategies is intended to be phased in over a 3-year period from plan adoption (City of Chula Vista 2011).
City of Chula Vista Green Building Standards
The City of Chula Vista amended Municipal Code Ordinance 15.12 pertaining to green building practices to include residential and non-residential remodels and additions. The Code contains Residential Mandatory Measures and Non-Residential Mandatory Measures and also provides Voluntary Measures that can be used by developers to improve energy efficiency and reduce environmental impacts through design and construction.
San Diego Regional Energy Efficiency Plan/City of Chula Vista Energy Strategy and Action Plan
The San Diego Regional Energy Strategy serves as the energy policy blueprint for the region through 2050. The Regional Energy Strategy provides long-term goals in eleven topic areas: energy efficiency, renewable energy, distributed generation, transportation fuels, land use and transportation planning, border energy issues, and the green economy (SANDAG 2014).
The City has adopted an energy plan to address long-term energy issues and to protect its residents from unreliable energy supply and volatile prices. The plan, called the Chula Vista Energy Strategy and Action Plan, addresses demand side management, energ y efficient and renewable energy outreach programs for businesses and residents, energy acquisition, power generation, and distributed energy resources and legislative actions (City of Chula Vista 2001).
City of Chula Vista Solar Ready Ordinances
CVMC, Section 15.28.015, solar water heater pre -plumbing, and Section 15.24.065, photovoltaic pre -wiring requirements, are referred to as the Solar Ready ordinances. Section 15.28.015 requires all new residential units to include plumbing specifically desi gned to allow the later installation of a system which utilizes solar energy as the primary means of heating domestic potable water. Section 15.24.065 requires all new residential units to include electrical conduit specifically designed to allow the later installation of a photovoltaic system which utilizes solar energy as a means to provide electricity.
City of Chula Vista General Plan
The City of Chula Vista General Plan recognizes that to ensure adequate and reliable energy service, efficient energy efforts throughout the City and transitioning to non -fossil fuel alternatives will help to extend limited supplies,
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reduce the need for expensive new regional power generators and transmission lines, and contribute to Chula Vista’s economic sustainability and regional competitiveness. The General Plan includes objectives in the Public Facilities and Services Element to ensure adequate energy supplies throughout Chula Vista (Objective PFS 22) and in the Environmental Element to promote conservation through the efficient use of energy and through the development of local, non-fossil fuel-based renewable sources of energy (Objective E 7) (City of Chula Vista 2005).
5.5.1.2 Existing Setting
Electricity
According to the U.S. Energy Information Administration (EIA), California used approximately 247,249,865 megawatt-hours of electricity in 2021 (EIA 2022). Electricity usage in California for different land uses varies substantially by the types of uses in a building, type of construction materials used in a building, and the efficiency of all electricity -consuming devices within a building. Due to the state’s energy efficiency building standards and efficiency and conservation programs, California’s electri city use per capita in the residential and commercial sector is lower than any other state except Hawaii (EIA 2023a).
San Diego Gas & Electric (SDG&E) provides electricity to the Project. SDG&E supplies power to 3.6 million people, through 1.4 million electric meters, and across a 4,100 square-mile service area that includes San Diego County and southern Orange County (SDG&E 2021). 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 2023a).
SDG&E receives electric power from a variety of sources. According to the 2022 SDG&E Power Content Label, eligible renewable energy accounts for 44.5% of SDG&E’s overall energy resources, with biomass and biowaste at
2.9%, solar at 28.0%, wind power at 13. 9%, unspecified power1 at 0.8%, and natural gas at 54.4 % (CEC 2023b).
Within San Diego County, annual electricity use in 2022 was approximately 20.2 billion kWh per year (CEC 2023c).
Natural Gas
Natural gas is a combustible mixture of hydrocarbon compounds (primarily methane) used as a fuel source. The majority of the natural gas consumed in California is obtained from sources located outside the state and delivered through high-pressure transmission pipelines. Natural gas provides almost one -third of the state’s total energy requirements and is used in electricity generation, space heating, cooking, water heating, industrial processes, and as a transportation fuel. Natural gas is measured in terms of cubic feet.
According to the EIA, California used approximately 2,092,612 million cubic feet of natural gas in 2021 (EIA 2023b).
The majority of California’s natural gas customers are residential and small commercial customers (core customers). These customers account for approximately 35% of the natural gas delivered by California utilities (CPUC 2021). Large consumers, such as electric generators and industrial customers (noncore customers), account for approximately 65% of the natural gas delivered by California uti lities (CPUC 2021). CPUC regulates California natural gas rates and natural gas services, including in -state transportation over transmission and distribution pipeline systems, storage, procurement, metering, and billing. Most of the natural gas used in Ca lifornia comes from out -of-state natural gas basins. Biogas (e.g., from wastewater treatment facilities or dairy farms) is just
1 Unspecified power is electricity that has been purchased through open market transactions and is not traceable to a specific generation source.
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beginning to be delivered into the gas utility pipeline systems; however, the State has adopted regulations requiring its development to reduce statewide emissions of methane by 40% below 2013 levels by 2030 (CPUC 2022).
SDG&E provides San Diego County and southern Orange County with natural gas service, encompassing approximately 4,100 square miles. Within San Diego County, gas consumption in 2022 was approximately 522 million therms, with 281 million therms for residential use and 241 million therms for non-residential use (CEC 2023b).
Petroleum
According to the EIA, California used approximately 605 million barrels of petroleum in 2021, with the majority (511 million barrels) used for the transportation sector (EIA 2023c). There are 42 U.S. gallons in a barrel, so this equates to a total daily use of approximately 25.4 billion gallons of petroleum among all sectors and 21.46 billion gallons for the transportation sector. Petroleum usage in California includes petroleum products such as motor gasoline, distillate fuel, liquefied petroleum gases, an d jet fuel. At the federal and state levels, various policies, rules, and regulations have been enacted to improve vehicle fuel efficiency, promote the development and use of alternative fuels, reduce transportation‐source air pollutants and greenhouse gas (GHG) emissions, and reduce vehicle miles traveled (VMT). Section 5.5.1.1 Regulatory Framework discusses in more detail both federal and state regulations that would help increase fuel efficiency of motor vehicles and reduce GHG emissions. Market forces have driven the price of petroleum products steadily upward over time, and technological advances have made use of other energy resources or alternative transportation modes increasingly feasible.
5.5.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to energy are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to energy would occur if the project would:
1. Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation.
2. Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
Approach and Methodology
CalEEMod Version 2022.1 (CAPCOA 2022) was used to estimate the potential project energy consumption during construction and operation. All details specific to construction and operation are discussed in Section 5.2, Air Quality, specifically in Approach and Methodology (Construction Emissions and Operational Emissions), and are also applicable for the estimation of construction-related and operations-related energy consumption.
5.5.3 Impacts
Would the project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? Construction and operational energy use are based on the approach and methodology discussed in Appendix C Air Quality and Greenhouse Gas Emissions Technical Report, specifically Section 2.3.3 and the Approach and Methodology discussed in Section 5.2 Air Quality of this EIR.
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tends to reduce VMT within the region, acting to reduce regional vehicle energy demands. In addition, the project is located within walking distance to the H Street Transit Station and is in a transit priority area and VMT-efficient area.
In compliance with CALGreen, the project would promote the use of bicycles as an alternative mean of transportation by providing short -term and/or long-term bicycle parking accommodations. Facilitating pedestrian and bicycle access for employees would reduce VMT and associ ated energy consumption. As supported by the preceding discussions, project transportation energy consumption would not be considered inefficient, wasteful, or otherwise unnecessary and impacts would be less than significant.
Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency? The project would be subject to and would comply with, at a minimum, the California Building Energy Efficiency Standards (24 CCR Part 6). Part 6 of Title 24 establishes energy efficiency standards for nonresidential buildings constructed in California in order to reduce energy demand and consumption. As such, the project would comply with the California code requirements for energy efficiency.
Part 11 of Title 24 sets forth voluntary and mandatory energy measures that are applicable to the project under CALGreen. CALGreen institutes mandatory minimum environmental performance standards for all ground-up, new construction of commercial, low-rise residential, high-rise residential, state-owned buildings, schools, and hospitals, as well as certain residential and nonresidential additions and alterations . Additionally, energy consumed by the project’s operation is calculated to be comparable to energy consumed by other industrial uses of similar scale and intensity that are constructed and operating in California. On this basis, the project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. This impact would be less than significant.
5.5.4 Level of Significance Prior to Mitigation
Impacts related to energy would be less than significant prior to mitigation.
5.5.5 Mitigation Measures
No mitigation measures are required.
5.5.6 Level of Significance After Mitigation
There are no mitigation measures proposed and impacts would remain less than significant.
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5.6 Geology and Soils
This section describes the existing geological conditions of the project site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the proposed Rohr Wohl Specific Plan Project (proposed project or project). The proposed project will redevelop and repurpose land that has been developed and operated for industrial purposes since about 1941.
The following analysis is based on the Geotechnical Investigation Reports (Geotechnical Report s) prepared by Geocon Inc. The reports are provided as Appendi ces G1 and G2 to this environmental impact report ( EIR). The following analysis is also based on the Paleontological Resources Records Search prepared by the San Diego Natural History Museum and included as Appendix F to this EIR.
5.6.1 Existing Conditions
5.6.1.1 Regulatory Framework
Federal
International Building Code
The International Building Code (IBC) is a model building code developed by the International Code Council that provides the basis for the California Building Code (CBC). The purpose of the IBC is to provide minimum standards for building construction to ensure public safety, health, and welfare. Prior to the creation of the IBC, several different building codes were used; however, by 2000, t he IBC had replaced these previous codes. The IBC is updated every 3 years.
Occupational Safety and Health Administration Regulations The Occupational Safety and Health Administration’s Excavation and Trenching standard, Title 29 of the Code of Federal Regulations, Part 1926.650, covers requirements for excavation and trenching operations. The Occupational Safety and Health Administration requires that all excavations where employees could potentially be exposed to cave-ins be protected by sloping or benching the sides of the excavation, supporting the sides of the excavation, or placing a shield between the side of the excavation and the work area.
Paleontological Resources Preservation Act 2009
The Paleontological Resources Preservation Act (which was enacted within the Omnibus Public Land Management Act of 2009) requires the secretaries of the Interior and Agriculture to manage and protect paleontological resources on federal land using scientific principles and expertise. The Paleontological Resources Preservation Act includes specific provisions addressing management of these resources by the Bureau of Land Management, the National Park Service, the Bureau of Reclamation, the U.S. Fish and Wild life Service, all of the Department of the Interior, and the Forest Service of the Department of Agriculture.
The Paleontological Resources Preservation Act affirms the authority for many of the policies that the federal land- managing agencies already have in place for the management of paleontological resources, such as issuing permits for collecting paleontological resources, curation of paleontological reso urces, and confidentiality of locality data.
The Paleontological Resources Preservation Act only applies to federal lands and does not affect private lands. It
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provides authority for the protection of paleontological resources on federal lands, including criminal and civil penalties for fossil theft and vandalism. As directed by the Paleontological Resources Preservation Act, the federal agencies are in the process of developing regulations, establishing public awareness and education programs, and inventorying and monitoring federal lands.
State
Alquist -Priolo Earthquake Fault Zoning Act
The Alquist-Priolo Earthquake Fault Zoning Act of 1972 (California Public Resources Code Sections 2621 –2630) regulates development and construction of buildings intended for human occupancy to avoid the hazard of surface fault rupture. The act helps define areas where fault rupture is most likely to occur. The act groups faults into categories of active, potentially active and inactive. Historic and Holocene age faults are considered active. Late Quaternary and Quaternary age faults are considered potentially active and pre -Quaternary age faults are considered inactive. These classifications are qualified by the conditions that a fault must be shown to be sufficiently active and well defined by detailed site -specific geologic explorations to determine whether building setbacks should be established. Cities and c ounties affected by the zones must regulate certain development projects within the zones. They must withhold development permits for sites within the zones until geologic investigations demonstrate that the sites are not threatened by surface displacement from future faulting.
California Building Code
State regulations protecting structures from geo -seismic hazards are contained in the California Code of Regulations, Title 24, Part 2 (the CBC). The purpose of the CBC is to establish minimum standards to safeguard the public health, safety, and general w elfare through structural strength, means of egress facilities, and general stability by regulating and controlling the design, construction, quality of materials, use and occupancy, location, and maintenance of all building and structures within its jurisdiction. The CBC is based on the International Building Code published by the International Code Conference. The CBC contains California amendments based on the American Society of Civil Engineers Minimum Design Standards 7 -05, which provides requirements for general structural design and includes means for determining earthquake loads and other loads (such as wind loads) for inclusion into building codes. The provisions of the CBC apply to the construction, alteration, movement, replacement, and demolition of every building or structure, or any appurtenances connected or attached to such buildings or structures throughout California.
California Environmental Quality Act
Paleontological resources are limited, nonrenewable resources of scientific, cultural, and educational value and are afforded protection under state laws and regulations , notably, the California Environmental Quality Act (CEQA) (California Public Resources Code Section 21000 et seq.). This report satisfies project requirements in accordance with CEQA and California Public Resources Code Section 5097.5. This analysis also complies with guidelines and significance criteria specified by the Society of Vertebrate Paleontology (SVP 2010).
Paleontological resources are explicitly afforded protection by CEQA, specifically in Section VII(f) of CEQA Guidelines Appendix G, the Environmental Checklist Form, which addresses the potential for adverse impacts to “unique paleontological resource[s] o r site[s] or … unique geological feature[s]” (14 CCR 15000 et seq.). This provision covers fossils of signal importance—remains of species or genera new to science, for example, or fossils exhibiting features not previously recognized for a given animal gr oup—as well as localities that yield fossils significant in their abundance, diversity, preservation, and so forth. Further, CEQA provides that, generally, a
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resource shall be considered “historically significant” if it has yielded or may be likely to yield information important in prehistory (14 CCR 15064.5 [a][3][D]). Paleontological resources would fall within this category. The California Public Resources C ode, Chapter 1.7, Sections 5097.5 and 30244, also regulates removal of paleontological resources from state lands, defines unauthorized removal of fossil resources as a misdemeanor, and requires mitigation of disturbed sites.
California Geologic al Survey
The California Geologic al Survey (CGS) provides guidance with regard to seismic hazards. CGS’s Special Publication 117 A, Guidelines for Evaluating and Mitigating Seismic Hazards in California (2008), provides guidance for evaluation and mitigation of earthquake -related hazards for projects within designated zones of required investigation.
State Earthquake Protection Law
The State Earthquake Protection Law (California Health and Safety Code 19100 et seq.) requires that structures be designed to resist stresses produced by lateral forces caused by wind and earthquakes. Specific minimum seismic safety and structural design requirements are set forth in the CBC. The CBC requires a site -specific geotechnical study to address seismic issues and identify seismic factors that must be considered in structural design. Because the project site is not located within an Alquist–Priolo Earthquake Fault Zone (City of Chula Vista 2005), no special provisions would be required for project development related to fault rupture.
Seismic Hazards Mapping Act of 1990
The Seismic Hazards Mapping Act of 1990 (SHMA) (California Public Resources Code Section 2690 et seq.) directs CGS to identify and map areas prone to liquefaction, earthquake-induced landslides, and amplified ground shaking.
The purpose of the SHMA is to minimize loss of life and property through the identification, evaluation, and mitigation of seismic hazards.
The SHMA provides a statewide seismic hazard mapping and technical advisory program to assist cities and counties in fulfilling their responsibilities for protecting public health and safety from the effects of strong ground shaking, liquefaction, landslides, other ground failure, and other seismic hazards caused by earthquakes. Mapping and other information generated pursuant to the SHMA is made available to local governments for planning and development purposes. The state requires local governments to in corporate site -specific geotechnical hazard investigations and associated hazard mitigation as part of the local construction permit approval process, and requires the agent for a property seller, or the seller if acting without an agent, to disclose to any prospective buyer if the property is located within a seismic hazard zone. The state geologist is responsible for compiling seismic hazard zone maps. The SHMA specifies that the lead agency for a project may withhold development permits until geologic or soils investigations are conducted for specific sites and mitigation measures are incorporated into plans to reduce hazards associated with seismicity and unstable soils.
Local
City of Chula Vista General Plan – Environmental Element Individual project development proposed on property under City of Chula Vista (City) jurisdiction has requirements similar to IBC and CBC requirements, and must comply with Objective E 14 and its three associated policies (E 14.1, E 14.2, and E 14.3) contained in the Environmental Element of the General Plan (Chapter 9, Section 3.1.10) (City
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of Chula Vista 2005) . Implementation of this objective and policies are intended to reduce potential impacts associated with geological hazards and public safety.
Objective E 14: Minimize the risk of injury, loss of life, and property damage associated with geologic hazards.
Policy E 14.1: To the maximum extent practicable, protect against injury, loss of life, and major property damage through engineering analyses of potential seismic hazards, appropriate engineering design, and the stringent enforcement of all applicable regulations and standards.
Policy E 14.2: Prohibit the subdivision, grading, or development of lands subject to potential geologic hazards in the absence of adequate evidence demonstrating that such development would not be adversely affected by such hazards and would not adversely affect surrounding properties.
Policy E 14.3: Require site -specific geotechnical investigations for proposals within areas subject to potential geologic hazards; and ensure implementation of all measures deemed necessary by the City Engineer and/or Building Official to avoid or adequately mitigate such hazards.
Additionally, the City’s Environmental Element addresses potential impacts to non -renewable paleontological resources and outlines policies to mitigate negative impacts (City of Chula Vista 2005). The objective and policies protecting paleontological resources are outlined below:
Objective E 10: Protect important paleontological resources and support and encourage public education and awareness of such resources.
Policy E 10.1: Continue to assess and mitigate the potential impacts of private development and public facilities and infrastructure to paleontological resources in accordance with the California Environmental Quality Act.
Policy E 10.2: Support and encourage public education and awareness of local paleontological resources, including the establishment of museums and educational opportunities accessible to the public.
5.6.1.2 Existing Geologic and Soils Setting
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.
Geologic Setting
The geology underlying the project site consists of two surficial soil types (undocumented fill and Holocene-age Bay deposits) and two formational units (Old Paralic Deposits and the San Diego Formation) , which are described in more detail below.
Undocumented Fill
Undocumented fill, or late Holocene (less than 4,200 years ago) artificial fill (map unit af), associated with the existing site improvements is present across the majority of the site in depths of about 5 to 10 feet (Kennedy and
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Tan 2008; Cohen et al. 2023; Appendix G1 and G2). The fill generally consists of loose to medium dense, moist to wet, silty sand and possesses an expansion index of 50 or less (“very low” to “low”). The fill located below the groundwater elevation has potential for liquefaction. A zone of debris fill located along the previous shoreline of the bay (the western edge of the property) is composed of concrete and trash debris mixed with soil. The upper portion of the fill is likely unsuitable for the support of the proposed structures or structural fill and would require remedial grading. Remedial grading operations would be limited to the groundwater elevation and/or saturated soil conditions (Appendix G1 and G2).
Bay Deposits
Bay Deposits (bay mud) (mapped as Qmo) are late Holocene in age (less than 4,200 years ago) (Kennedy and Tan 2008; Cohen et al. 2023), exist below the undocumented fill or at-grade to a maximum depth of approximately 15 to 20 feet below ground surface on the western portion of Planning Area B, 20 to 30 feet on the eastern portion of Planning Area B, and 20 to 25 feet on Planning Area A. These deposits, in general, consist of very loose to medium dense, silty and clayey sand and soft, wet to saturated sandy silt and clay. Sandy portions of the Bay Deposits have the potential for liquefaction when subjected to strong ground motion, and the soft muds of the Bay Deposits are subject to consolidation settlement. These materials are considered unsuitable for the support of structures or structural fill in their present condition (Appendix G1 and G2).
Young Alluvial Flood Plain Deposits
Late Pleistocene- to Holocene-age (less than approximately 129,000 years old) young alluvial flood plain deposits (mapped as Qya) underlie the northern and eastern portions of the project site at the surface (Kennedy and Tan 2008; Cohen et al. 2023). These deposits generally consist of unconsolidated sandy, silty, or clay-bearing alluvium deposited by the action of recently active streams. These deposits are assigned a low paleontological sensitivity based on their relatively young geologic age and lack of recorded fossil collection localities. However, these deposits may be underlain in the relatively shallow subsurface by a geologic unit with high paleontological sensitivity (i.e., the Bay Point Formation=Old Paralic Deposits) (Appendix F).
Old Paralic Deposits
The late to middle Pleistocene (129,000 to 774,000 years ago) Old Paralic Deposits (mapped as Qop), and correlative with Kennedy’s (1975) Bay Point Formation, exist below the undocumented fill, Bay Deposits, and/or young alluvial flood plain deposits across the project site (Kennedy and Tan 2008; Kennedy 1975; Cohen et al. 2023). The Old Paralic Deposits generally consist of medium dense to very dense sand layers interbedded with stiff clay and silt layers that are considered suitable for the support of the proposed structures (Appendix G1 and G2). However, it is not expected that Old Paralic Deposits would be encountered during the construction of the planned improvements unless at depth . If these deposits are encountered, at depth, they would have high paleontological sensitivity.
The San Diego Natural History Museum has five recorded fossil collection localities from the Bay Point Formation (i.e., Old Paralic Deposits) within a 1-mile radius of the project site. All five localities were documented at significant depths below the surface (between 90 and 282 feet below mean sea level) during drilling, and the assignment of these localities to the Bay Point Formation is tentative (Appendix F). The localities produced trace fossil borings, as well as fossil remains of marine invertebrates (e.g., bryozoans, sea urchins, clams, scallops, oysters, jingle shells, snails, barnacles, decapods), marine vertebrates (e.g., sharks and bony fish), and terrestrial vertebrates (e.g., rodents). More broadly, the Bay Point Formation has been assigned a high paleontological sensitivity for the diverse
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and well-preserved fossils of marine invertebrates and marine vertebrates that have been recovered from these deposits (Appendix F).
San Diego Formation
The early Pleistocene to late Pliocene (approximately 1.8 million years ago [mya] to 3.6 mya) San Diego Formation typically consists of dense to very silty, to clayey sandstone and siltstone . The top of the San Diego Formation is approximately 150 to 160 feet deep and is not expected to be encountered during the construction of the planned improvements. Although not mentioned in the records search , the San Diego Formation is known to have a h igh paleontological sensitivity and has yielded numerous important paleontological resources, specifically Pliocene (approximately 2.58 mya to 5.33 mya) marine invertebrates and vertebrates, elsewhere in southwestern San Diego County (Deméré 1982, 1983; County of San Diego 2009; Cohen et al. 2023).
Expansive Soil
Expansive soils contain minerals, such as clay, that are capable of absorbing water and expanding, and losing water and shrinking. As discussed in the Geotechnical Reports, the project site contains soils that are both non-expansive and expansive; however, the majority of the soil encountered possesses a “very low” to “low” expansion potential.
Liquefaction
Liquefaction typically occurs when a site is located in a zone with seismic activity, on-site soils are cohesionless or silt/clay with low plasticity , groundwater is encountered within 50 feet of the surface, and soil densities are less than about 70% of the maximum dry densities. The Geotechnical Reports state that the surficial soil at the site is generally loose/soft and considered to possess a potential for liquefaction below the groundwater elevation. Lateral spreading occurs when liquefiable soil is in the vicinity of a free face such as a slope. The lateral spreading potential in the liquefiable soil below the groundwater table is not considered an adverse impact due to the relatively flat topography of the site and distance to the San Diego Bay from the site (Appendices G1 and G2). The City of Chula Vista General Plan’s Environmental Element identifies the project site to be in a Liquefaction Hazard Area. These are areas with shallow groundwater tables and poorly consolidated granular sediments potentially subject to hazards associated with seismically induced liquefaction (City of Chula Vista 2005).
Storm Surge, Tsunamis, and Seiches
Storm surges are large ocean waves that sweep across coastal areas when storms make landfall. Storm surges can cause inundation, severe erosion, and backwater flooding along the waterfront. The site is located approximately 800 feet from San Diego Bay, is at an elevation of about 10 feet or greater above mean sea level (amsl) and is protected from ocean waves by the Silver Strand to the west. Based on historic and predicated wave heights and runout lengths, the proposed site elevation with neighboring topographic features is likely sufficient to mitigate the risk; therefore, the potential of storm surges affecting the site is low (Appendices G1 and G2).
A tsunami is a series of long period waves generated in the ocean by a sudden displacement of large volumes of water. Historically, tsunami wave heights have ranged up to 3.7 feet in the San Diego area. Wave heights and run- up elevations from tsunamis along the San Diego Coast have historically fallen within the normal range of the tides.
The Multi -Jurisdictional Hazard Mitigation Plan (County of San Diego 2017) maps zones of possible tsunami inundation for coastal areas throughout the county. The site is n ot included within one of these high -risk hazard areas. Therefore, the risk of a tsunami hazard at the site is low (Appendices G1 and G2).
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A seiche is a run -up of water within a lake or embayment triggered by fault - or landslide -induced ground displacement. Based on historic and predicated wave heights and runout lengths, the proposed site elevation is sufficient to mitigate the risk; therefore, the potential for seiches to impact the site is low (Appendices G1 and G2).
Groundwater Seepage
Groundwater depths in the vicinity of the site range from approximately 8 to 20 feet below the existing ground surface (approximately 1 to 7 feet amsl) in Planning Area A, and 5 to 8 feet below the existing ground surface (approximately 2 to 5 feet amsl) in Planning Area B. The groundwater is considered brackish due to the proximity of the site to the San Diego Bay and the Pacific Ocean. The soil about 2 to 3 feet above the groundwater elevation may be saturated. Several groundwater monitoring wells exist on and adjacent to the property. The groundwater elevations and seepage conditions are expected to fluctuate due to tidal influences , seasonal precipitation, irrigation, land uses, and other factors.
Slope
Steep slope areas are classified as areas with slopes of 25° or steeper. Such areas are prone to hazards such as slope instability, debris flow, rock falls, erosion, and slope creep . The City does not designate the project site as being in a steep slope area (City of Chula Vista 2005). The Geotechnical Reports identify the project site topography as relatively flat (Appendices G1 and G2).
Faulting and Seismicity
An active fault is defined by CGS as a fault showing evidence of activity roughly within the last 11,000 years (Holocene time). The site is not underlain by active, potentially active, or inactive faults and is not located within a State of California Earthquake Fault Zone. Regionally, the site is located in the Peninsular Ranges geomorphic province. The province is bounded by the San Jacinto Fault Zone on the east. Dominant geologic structural features of the province are northwest- to west-northwest-trending folds and faults, such as the nearby Rose Canyon Fault Zone. Within the coastal plain on San Diego County is a relatively stable block that is dissected by relatively few faults, consisting of the potentially active La Nacion Fault Zone and the active Rose Canyon Fault Zone. Due to the absence of active faults at the subject site, the potential for ground rupture is considered very low.
Landslides
The Geotechnical Report s found no evidence of landslide deposits on the project site , and the City does not designate the site as being in a Landslide Hazard Area.
5.6.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to geology and soils are based on Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). According to Appendix G, a significant impact related to geology and soils would occur if the project would:
1. Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
a. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map, issued by the State Geologist for the area or based on other substantial evidence of a known fault. Refer to Division of Mines and Geology Special Publication 42.
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b. Strong seismic ground shaking.
c. Seismic-related ground failure, including liquefaction. d. Landslides.
2. Result in substantial soil erosion or the loss of topsoil.
3. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse.
4. Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property.
5. Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water.
6. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.
5.6.3 Impacts
Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
Rupture of a known earthquake fault, as delineated on the most recent Alquist -Priolo Earthquake Fault Zoning Map, issued by the State Geologist for the area based on other substantial evidence of as known fault? Refer to Division of Mines and Geology Special Publication 42.
An “active fault” is defined by CGS as a fault showing evidence for activity within the last 11,000 years. According to the Geotechnical Reports, the project site is not located on any known active, potentially active, or inactive fault traces or within a State of California Earthquake Special Study Zone or Alquist -Priolo Zone. Additionally, the Geotechnical Reports concluded that no active, potentially active, or inactive faults are present underlying or trending toward the site (Appendices G1 and G2). However, as discussed in Section 5.6.1, Existing Conditions, the Newport–Inglewood and Rose Canyon Fault Zones are located on the San Diego County Coastal Plain. The Newport– Inglewood and Rose Canyon Fault Zones are the nearest known active faults and are the dominant source of potential ground motion. Nonetheless, the proposed project would be constructed in accordance with the City’s Grading Ordinance, current seismi c design specifications, current CBC standards, and other regulatory requirements, which would reduce the potential for risks related to seismic events. Therefore, since development would not be located within an Alquist -Priolo Zone, and would be in compliance with applicable regulatory requirements, impacts associated with the rupture of a known earthquake fault would be less than significant.
Strong seismic ground shaking?
Earthquakes that might occur on the Newport–Inglewood and Rose Canyon Fault Zones or other faults within the Southern California and northern Baja California area are potential generators of significant ground motion at the site. As previously discussed, the Newport–Inglewood and Rose Canyon Fault Zones are the nearest known active faults and are the dominant source of potential ground motion. In the event of a major earthquake on any of the active faults within the Southern California and northern Baja California region, the project site, as with other sites in the general vicinity, could be subject to moderate to severe ground shaking. However, the proposed project would be constructed in accordance with the City’s Grading Ordinance, current seismic design specifications, current CBC standards, and other regulatory requirements, which would reduce the potential for risks related to seismic events.
Therefore, impacts associated with strong seismic ground shaking would be less than significant.
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Seismic-related ground failure, including liquefaction? As discussed in the Geotechnical Reports, the site may be subject to geologic hazards, including moderate to strong seismic shaking, liquefaction, seismically induced settlement, and consolidation settlement. However, soil or geologic conditions at the site are not considered adverse to proposed improvements, assuming they are designed to accommodate typical potential geologic hazards. Remedial grading shall be required for areas with expansive soils (refer to Section 5.6.3[1][d] for further details). However, seismically induced settlement may occur whether the potential for liquefaction exists or not. Although there is potential for seismic -related ground failure to occur, compliance with the City’s Grading Ordinance, current seismic design specifications, current CBC standards, and other regulatory requirements would ensure that impacts associated with seismic-related ground failure, including liquefaction, would be less than significant.
Landslides?
As discussed in Section 5.6.1.2, the City’s General Plan does not designate the project site as an area susceptible to landslides. Additionally, the Geotechnical Reports do not indicate an impact relating to landslides. The project site does not contain slopes susceptible to landslides and is not located within a seismic hazard zone; therefore, the potential for earthquake-induced landslides is considered low. Therefore, impacts associated with landslides would be less than significant.
Would the project result in substantial soil erosion or the loss of topsoil? Construction Impacts
Excavation and ground-disturbing activities during construction of the proposed project could potentially leave loose soil exposed to the erosive forces of rainfall and high winds, which increase the potential for soil erosion and loss of topsoil. As discussed in Section 5.9 of this EIR, Hydrology and Water Quality, construction of the project would result in more than 1 acre of land disturbance; therefore, the project will be required to prepare and implement a site-specific stormwater pollution prevention plan (SWPPP) in accordance with the State Water Resources Control Board Order No. 2009-0008-DWQ National Pollutant Discharge Elimination System General Permit No. CAS00002 (Construction General Permit), amended by Order No. 2010-0014-DWQ and Order No. 2012-0006-DWQ. Conditions of these existing regulations would include adherence to sediment and stormwater pollutant control best management practices (BMPs), effluent monitoring and compliance, post-construction-period requirements, worker training, and various other measures designed to minimize potential for soil erosion and loss of topsoil.
Furthermore, earth -disturbing activities associated with construction would be temporary. Therefore, with construction activities being temporary and with compliance with the Construction General Permit and BMPs outlined in the SWPPP, impacts related to soil erosion and the loss of topsoil would be less than significant.
Operational Impacts
The site is currently developed with several industrial buildings. During operation, the project would introduce new infrastructure, resulting in more impervious area to the site. As such, the proposed area to be developed would be graded and paved, greatly reducing the possibility for soil erosion or loss of topsoil compared to current conditions.
However, introducing m ore impervious area would result in more surface runoff, which could lead to more soil erosion and loss of topsoil. On-site runoff is collected and transported by concrete gutters into storm drains located along the western property line of Planning Areas B-1 and B-2. Proper surface drainage for groundwater elevations
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of 6 feet amsl would be incorporated into design and construction operations. Additionally, a stormwater quality management plan (SWQMP) has been prepared for the project and is provided in Appendix I to this EIR. The SWQMP has been prepared consistent with the requirements of the City’s BMP Design Manual (City of Chula Vista 2022) and with the requirements of San Diego RWQCB Order No. R9-2013-0001 (Regional MS4 Permit).
The SWQMP prepared for the proposed project specifies site design BMPs that would be implemented to minimize soil erosion and loss of topsoil. Site-design BMPs include conserving natural areas, soils, and vegetation; minimizing impervious areas; and minimizing soil compaction. Therefore, with implementation of the SWPPP and incorporation of the BMPs described in the SWQMP, impacts associated with substantial erosion or siltation on or off site would be less than significant.
Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? The geology of the project site consists of two surficial soil types (undocumented fill and Holocene-age Bay deposits) and two formational units (Old Paralic Deposits and the San Diego Formation ). The project site is underlain by compressible surficial deposits that are likely unsuitable for the support of the proposed structures or structural fill and would require remedial grading.
The proposed project site is not located on any known active, potentially active, or inactive fault traces, although cracking or lateral spreading of the ground surface as a result of nearby seismic events is possible (Appendices G1 and G2). Surface ground cracking or lateral spreading related to shaking from distant events is not considered a significant hazard because the potential for liquefaction and seismically induced settlement occurring within the project site is considered to be ve ry low due to the dense nature of the formational materials and the lack of a shallow groundwater condition (Appendices G1 and G2).
Recommendations identified in the project’s Geotechnical Reports (Appendices G1 and G2) to reduce the potential hazards due to liquefaction can be accomplished by the densification or removal of the potentially liquefiable soil or the use of foundation systems that still provide acceptable structural support , should liquefaction occur. Soil densification would be accomplished by compaction grouting, vibrocompaction, soil mixing, and deep dynamic compaction (among others). Deep foundation systems would be used to transmit structural loads to bearing depths below the liquefiable zones and may consist of driven piles or drilled piles. Deep foundations are designed to mitigate damage to the structures supported on the piles; however, they do not generally reduce the potential for damage to underground utilities and peripheral site improvements. The effects of differential settlement between ridged structures and attached settlement -sensitive surface improvements can be mitigated by designing the utilities to accommodate differential movement at the connections. Additionally, proper surface drainage would be necessary. Groundwater elevations of 6 feet amsl would be incorporated into design and construction operations.
Groundwater would be a factor in development in liquefaction remediation, deep foundation design and construction, grading operations, and utility installation (Appendices G1 and G2).
Therefore, compliance with existing regulations and recommendations of the Geotechnical Report s would ensure that the proposed project would have less-than-significant impacts associated with unstable geologic units.
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Would the project be located on expansive soil, as defined in Table 18 -1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? As discussed in Section 5.6.1.2, the project site contains soil that present characteristics considered to be both expansive and non -expansive. Most of the soils encountered possessed a very low to low expansion potential (Expansion Indexes of 50 or less ). The project would be required to incorporate recommendations of the Geotechnical Reports, in accordance with CBC standards regarding slab and structural design criteria (refer to Appendices G1 and G2 for further details). Per the Geotechnical Reports, soil with an Expansion Index greater than 50 should not be used as backfill material behind retaining walls. Additionally, expansion joins should be used to reduce unsightly shrinkage cracking. Limiting the slump of the concrete through proper concrete placement and curing and by the placement of crack control joints at periodic intervals—in particular, where re-entrant slab corners occur—should reduce and/or control the occurrence of concrete shrinkage cracks from expansive soils. Therefore, with adherence to current CBC standards and the recommendations of the Geotechni cal Report s, impacts associated with expansive soil would be less than significant.
Would the project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? The proposed project would not include septic tanks or other alternative wastewater treatment methods.
Wastewater from the project site would be conveyed by the City’s local 12-inch main sewer line located in G Street.
Therefore, implementation of the proposed project would result in no impact associated with soils incapable of supporting septic systems or alternative wastewater treatment methods.
Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? According to Appendix F, due to the high paleontological sensitivity of the Bay Point and San Diego Formations in San Diego County, as well as the presence of fossil localities in the vicinity of the project site, construction of the proposed project has the potential to uncover paleontological resources. Any proposed excavation activities that extend deep enough to encounter previously undisturbed deposits of these geologic units (i.e., below the depth of artificial fill, young alluvial flood plain deposit s, or any previously disturbed sediments present within the project site) have the potential to impact the paleontological resources preserved therein. Therefore, impacts would be potentially significant and mitigation (Mitigation Measure [MM] GEO-1, Paleontological Resources Impact Mitigation Plan) would be required.
5.6.4 Level of Significance prior to Mitigation
Due to the potential for construction of the proposed project to impact paleontological resources, impacts prior to mitigation would be potentially significant.
5.6.5 Mitigation Measures
The following mitigation measure would be required in order to avoid or reduce potentially significant impacts to paleontological resources:
MM-GEO-1 Paleontological Resources Impact Mitigation Plan. Prior to commencement of any grading activity on site, the applicant shall retain a qualified paleontologist per the 2010 Society of Vertebrate Paleontology guidelines. The paleontologist shall prepare a Paleontological Resources
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Impact Mitigation Program (PRIMP) for the project. The PRIMP shall be consistent with the 2010 SVP guidelines and should outline requirements for preconstruction meeting attendance and worker environmental awareness training, where monitoring is required within the proposed project site based on construction plans and/or geotechnical reports, procedures for adequate paleontological monitoring and discoveries treatment, and paleontological methods (including sediment sampling for microvertebrate fossils), reporting, and collections management. The PRIMP shall also include a statement that any fossil lab or curation costs (if necessary due to fossil recovery) are the responsibility of the project proponent/applicant. The qualified paleontologist shall attend the preconstruction meeting and a qualified paleontological monitor shall be on site during any proposed excavation activities that extend deep enough to encounter previously undisturbed deposits of the Bay Point and San Diego Formations. In the event that paleontological resources (e.g., fossils) are unearthed during excavation, the paleontological monitor will temporarily halt and/or divert grading activity to allow recovery of paleontological resources. The area of discovery will be roped off with a 50-foot-radius buffer. Once documentation and collection of the find is completed, the paleontological monitor will remove the rope and allow grading to recommence in the area of the find.
5.6.6 Level of Significance after Mitigation
With implementation of the proposed mitigation in Section 5.6.5 , impacts relating to geology, soils, and paleontological resources would be less than significant.
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5.7 Greenhouse Gas Emissions
This section describes the existing greenhouse gas (GHG) 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 discussion in this section is based on the Air Quality and Greenhouse Gas Emissions Technical Report prepared for the project by August 2024. The complete report is contained in Appendix C of this environmental impact report.
5.7.1 Existing Conditions
5.7.1.1 Regulatory Framework
Federal
Massachusetts v. EPA
Massachusetts v. EPA. In Massachusetts v. EPA (April 2007), the U.S. Supreme Court directed the U.S. Environmental Protection Agency (EPA) administrator to determine whether GHG emissions from new motor vehicles cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to make a reasoned decision. In December 20 b09, the administrator signed a final rule with the following two distinct findings regarding GHGs under Section 202(a) of the federal Clean Air Act:
▪ The administrator found that elevated concentrations of GHGs— carbon dioxide (CO 2), methane (CH 4), nitrous oxide (N2O), ozone (O3), water vapor, hydrofluorocarbons (HFCs), hydrochlorofluorocarbons (HCFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6) —in the atmosphere threaten the public health and welfare of current and future generations. This is the “endangerment finding.” ▪ The administrator further found the combined emissions of GHGs —CO2, CH 4, N 2O, and H FCs—from new motor vehicles and new motor vehicle engines contribute to the GHG air pollution that endangers public health and welfare. This is the “cause or contribute finding.” These two findings were necessary to establish the foundation for regulation of GHGs from new motor vehicles as air pollutants under the Clean Air Act.
Energy Independence and Security Act
The Energy Independence and Security Act of 2007 (December 2007), among other key measures, would do the following, which would aid in the reduction of national GHG emissions (EPA 2007):
▪ Increase the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard requiring fuel producers to use at least 36 billion gallons of biofuel in 2022. ▪ Set a target of 35 miles per gallon for the combined fleet of cars and light trucks by model year 2020 and direct National Highway Traffic Safety Administration (NHTSA) to establish a fuel economy program for medium- and heavy-duty trucks and create a separate fuel economy standard for work trucks. ▪ Prescribe or revise standards affecting regional efficiency for heating and cooling products and procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances.
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Federal Vehicle Standards
In response to a U.S. Supreme Court ruling, the Bush Administration issued Executive Order (EO) 13432 in 2007 directing the EPA, the Department of Transportation, and the Department of Energy to establish regulations that reduce GHG emissions from motor vehicles, non-road vehicles, and non-road engines by 2008. In 2009, the NHTSA issued a final rule regulating fuel efficiency and GHG emissions from cars and light-duty trucks for model year 2011, and in 2010, the EPA and NHTSA issued a final rule regulating cars and light-duty trucks for model years 2012 – 2016 (75 FR 25324–25728).
In 2010, President Barack Obama issued a memorandum directing the Department of Transportation, Department of Energy, EPA, and NHTSA to establish additional standards regarding fuel efficiency and GHG reduction, clean fuels, and advanced vehicle infrastruc ture. In response to this directive, the EPA and NHTSA proposed stringent, coordinated federal GHG and fuel economy standards for model years 2017 –2025 light -duty vehicles. The proposed standards projected to achieve 163 grams per mile of CO 2 by model year 2025 on an average industry fleet-wide basis, which is equivalent to 54.5 miles per gallon if this level were achieved solely through fuel efficiency.
The final rule was adopted in 2012 for model years 2017–2021 (77 FR 62624–63200). On January 12, 2017, the EPA finalized its decision to maintain the current GHG emissions standards for model years 2022–2025 cars and light trucks (EPA 2022).
In addition to the regulations applicable to cars and light-duty trucks described above, in 2011, the EPA and NHTSA announced fuel economy and GHG standards for medium- and heavy-duty trucks for model years 2014–2018 (76 FR 57106–57513). The standards for CO2 emissions and fuel consumption are tailored to three main vehicle categories: combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles. According to the EPA, this regulatory program will reduce GHG emissions and fuel consumption for the affected vehicles by 6%–23% over the 2010 baselines.
In August 2016, the EPA and NHTSA announced the adoption of the phase two program related to the fuel economy and GHG standards for medium- and heavy-duty trucks. The phase two program will apply to vehicles with model year 2018 through 2027 for certain tr ailers, and model years 2021 through 2027 for semi -trucks, large pickup trucks, vans, and all types and sizes of buses and work trucks. The final standards are expected to lower CO2 emissions by approximately 1.1 billion metric ton (MT) and reduce oil consumption by up to 2 billion barrels over the lifetime of the vehicles sold under the program (EPA and NHTSA 2016).
In August 2018, the EPA and NHTSA proposed to amend certain fuel economy and GHG standards for passenger cars and light trucks and establish new standards for model years 2021 through 2026. Compared to maintaining the post-2020 standards in place at the ti me, the 2018 proposal would increase U.S. fuel consumption by about half a million barrels per day (2% –3% of total daily consumption, according to the Energy Information Administration) and would impact the global climate by 3/1000th of 1°C by 2100. California and other states have stated their intent to challenge federal actions that would delay or eliminate GHG reduction measures, and have committed to cooperating with other countries to implement global climate change initiatives.
In 2019, the EPA and NHTSA published the Safer Affordable Fuel -Efficient Vehicles Rule Part One: One National Program (SAFE -1), which revoked California’s authority to set its own GHG emissions standards and set zero - emission vehicle (ZEV) mandates in Cali fornia. In March 2020, Part Two was issued which set CO2 emissions standards and corporate average fuel economy standards for passenger vehicles and light -duty trucks for model years 2021 through 2026. In response to EO 13990, on December 21, 2021, NHTSA finalized the corporate average fuel economy Preemption rulemaking to withdraw its portions of the Part One Rule. The final rule concluded that the
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Part One Rule overstepped the agency’s legal authority and established overly broad prohibitions that did not account for a variety of important state and local interests.
Then, in March 2022, NHTSA established new fuel economy standards that would require an industry-wide fleet average of approximately 49 miles per gallon for passenger cars and light trucks in model year 2026, by increasing fuel efficiency by 8% annually for model years 2024 and 2025, and 10% annually for model year 2026.
Inflation Reduction Act of 2022
The Inflation Reduction Act was signed into law by President Biden in August 2022. The bill includes specific investment in energy and climate reform and is projected to reduce GHG emissions within the U.S. by 40% as compared to 2005 levels by 2030. The bi ll allocates funds to boost renewable energy infrastructure (e.g., solar panels and wind turbines), includes tax credits for the purchase of electric vehicles (EVs), and includes measures that will make homes more energy efficient.
State
The statewide GHG emissions regulatory framework is summarized below by category: state climate change targets, building energy, renewable energy and energy procurement, mobile sources, solid waste, water, and other state regulations and goals. The following text describes EOs, legislation, regulations, and other plans and policies that would directly or indirectly reduce GHG emissions and/or address climate change issues.
State Climate Change Targets
EO S-3-05
EO S-3-05 (June 2005) established the following statewide goals: GHG emissions should be reduced to 2000 levels by 2010, GHG emissions should be reduced to 1990 levels by 2020, and GHG emissions should be reduced to 80% below 1990 levels by 2050.
EO S-3-05 also directed the California EPA to report biannually on progress made toward meeting the GHG targets and the impacts to California due to global warming, including impacts to water supply, public health, agriculture, the coastline, and forestry. The Climate Action Team was formed, which subsequently issued reports from 2006 to 2010.
Assembly Bill (AB) 32. In furtherance of the goals established in EO S-3-05, the legislature enacted AB 32 (Núñez and Pavley). The bill is referred to as the California Global Warming Solutions Act of 2006 (September 27, 2006). AB 32 provided initial direction on creating a comprehensive multiyear program to limit California’s GHG emissions at 1990 levels by 2020 and initiate the transformations required to achieve the state’s long-range climate objectives.
EO B-30-15. EO B-30-15 (April 2015) identified an interim GHG reduction target in support of targets previously identified under EO S-3-05 and AB 32. EO B-30-15 set an interim target goal of reducing statewide GHG emissions to 40% below 1990 levels by 2030 to keep California on its trajectory toward meeting or exceeding the l ong-term goal of reducing statewide GHG emissions to 80% below 1990 levels by 2050, as set forth in EO S-3-05. To facilitate achievement of this goal, EO B-30-15 calls for an update to the California Air Resources Board’s (CARB’s) Scoping Plan to express the 2030 target in terms of million metric tons ( MMT) carbon dioxide equivalent (CO2e). The executive order also calls for state agencies to continue to develop and implement GHG emission s reduction programs in support of the reduction targets. Sector-specific agencies in transportation, energy, water, and forestry were required to prepare GHG reduction plans by September 2015, followed by a report on action taken in relation
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to these plans in June 2016. EO B-30-15 does not require local agencies to take any action to meet the new interim GHG reduction target.
Senate Bill (SB) 32 and AB 197. SB 32 and AB 197 (enacted in 2016) are companion bills that set a new statewide GHG reduction targets, make changes to CARB’s membership and increase legislative oversight of CARB’s climate change-based activities, and expand dissemination of GHG and other air-quality-related emissions data to enhance transparency and accountability. More specifically, SB 32 codified the 2030 emissions reduction goal of EO B-30-15 by requiring CARB to ensure that statewide GHG emissions are reduced to 40% below 1990 levels by 2030. AB 197 established the Joint Legislative Committee on Climate Change Policies, consisting of at least three members of the Senate and three members of the Assembly to provide ongoing oversight over implementation of the state’s climate policies. AB 197 also added two members of the Legislature to CARB as nonvoting members; requires CARB to make available and update (at least annually via its website) emissions data for GHGs, criteria air pollutants, and toxic air contaminants (TACs) from reporting facilities; and requires CARB to identify specific information for GHG emissions reduction measures when updating the Scoping Plan.
EO B-55-18. EO B-55-18 (September 2018) establishes a statewide policy for the state to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net-negative emissions thereafter. The goal is an addition to the existing statewide targets of reducing the state’s GHG emissions. CARB will work with relevant state agencies to ensure that future scoping plans identify and recommend measures to achieve the c arbon neutrality goal.
AB 1279. The Legislature enacted AB 1279, the California Climate Crisis Act, in September 2022. The bill declares the policy of the state to achieve net zero GHG emissions as soon as possible, but no later than 2045, and achieve and maintain net negative GHG emissions thereafter. Additionally, the bill requires that by 2045, statewide anthropogenic GHG emissions be reduced to at least 85% below 1990 levels. Although AB 1279 establishes an overall policy to achieve net zero greenhouse gas emissions as soon as possible, but no later than 2045, recognizing the need to implement carbon dioxide removal and carbon capture, utilization and storage technologies, the Legislature established a sp ecific target of 85% below 1990 levels by 2045 for anthropogenic GHG emissions.
Therefore, the net zero target does not directly apply to development projects, but the 2045 target of 85% below 1990 levels represents the reductions required to contribute to accomplishing the State’s overall net zero policy.
California Air Resources Board’s Climate Change Scoping Plan. One specific requirement of AB 32 was for CARB to prepare a scoping plan for achieving the maximum technologically feasible and cost -effective GHG emission reductions by 2020 (Health and Safety Code Section 38561[a]), and to update the plan at least once every 5 years.
In 2008, CARB approved the first scoping plan. The Climate Change Scoping Plan: A Framework for Change (Scoping Plan) included a mix of recommended strategies that combined direct regulations, market-based approaches, voluntary measures, policies, and other emission reduction programs calculated to meet the 2020 statewide GHG emissions limit and initiate the transformations needed to achieve the st ate’s long-range climate objectives. The key elements of the Scoping Plan include the following (CARB 2008a):
Expanding and strengthening existing energy efficiency programs, as well as building and appliance standards.
Achieving a statewide renewable energy mix of 33%.
Developing a California cap-and-trade program that links with other Western Climate Initiative partner programs to create a regional market system and caps sources contributing 85% of California’s GHG emissions.
Establishing targets for transportation -related GHG emissions for regions throughout California, and pursuing policies and incentives to achieve those targets.
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Adopting and implementing measures pursuant to existing state laws and policies, including California’s clean car standards, goods movement measures, and the Low Carbon Fuel Standard (17 CCR 95480 et seq.).
Creating targeted fees, including a public goods charge on water use, fees on high global warming potential (GWP) gases, and a fee to fund the administrative costs of the State of California’s long-term commitment to AB 32 implementation.
The Scoping Plan also identified local governments as essential partners in achieving California’s goals to reduce GHG emissions because they have broad influence and, in some cases, exclusive authority over activities that contribute to significant direct and indirect GHG emissions through their planning and permitting processes, local ordinances, outreach and education efforts, and municipal operations. Specifically, the Scoping Plan encouraged local governments to adopt a reduction goal for municipal operations, and for community emissions to reduce GHGs by approximately 15% from then levels (2008) by 2020. Many local governments developed community-scale local GHG reduction plans based on this Scoping Plan recommendation.
In 2014, CARB approved the first update to the Scoping Plan. The First Update to the Climate Change Scoping Plan:
Building on the Framework (First Update) defined the state’s GHG emission reduction priorities for the next 5 years, and laid the groundwork t o start the transition to the post -2020 goals set forth in EO S -3-05 and EO B -16-2012.