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“[DACs] shall be identified based on geographic, socioeconomic, public health, and environmental hazard criteria, and may include, but are not limited to, either of the following:
1. Areas disproportionately affected by environmental pollution and other hazards that can lead to negative public health effects, exposure, or environmental degradation.
2. Areas with concentrations of people that are of low income, high unemployment, low levels of homeownership, high rent burden, sensitive populations, or low levels of educational attainment.”
Low-income thresholds outlined in SB 1000 are household incomes at or below 80% of the state’s median income, or household incomes at or below the Department of Housing and Community Development’s list of state income limits adopted pursuant to Section 500093.
Community Prot
ection (CP) and Community Health and Services Chapter (CHS) Revisions The proposed General Plan text amendment to the Community Protection and Community Health and Services Chapters (Project) consists of the following major components:
Community Protection C hapter
• Updated existing, and introduction of new goals and policies; • An updated Emergency Preparedness and Evacuation Plan; • Updated maps of limited access roads and residential parcels for evacuation routes; • Incorporation of the Escondido Climate Action Plan (E-CAP), Vulnerability Assessment and Adaptation Report, Local and State Responsibility Area Fire Hazard Severity Zone Maps, and Multi-Jurisdictional Hazard Mitigation Plan (MJHMP) by reference.
The Community Protection Chapter includes one (1) new goal and 20 new policies , along with minor text revisions to the existing goals and policies. One (1) goal and four (4) associated policies are related to Climate Adaptation and Resiliency. The 16 other new policies are distributed amongst Soils and Seismicity, Flood Protection, Fire Protection, and Emergency Services. These new goals and policies can be found in Appendix A of this addendum.
Community Health an d Services Chapter
• A comprehensive section on environmental justice including:
o Background and legal context for the incorporation of environmental justice o An analysis of the City’s demographics to identify Disadvantaged Communities (DACs), Environmental Justice Communities (EJCs), and Priority Investment Neighborhoods (PINs);
o Strategies to address the City’s identified EJ needs, including environmental justice goals, policies, and programs;
o Incorporation of the E-CAP by reference.
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Exhibit "E"
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The Community Health and Services Chapter now contains the new Environmental Justice section, which includes two (2) new goals, nine (9) new policies, and 84 new subpolicies. Of these additions, two (2) policies and 20 subpolicies are related to Pollution Reduction, two (2) policies and 16 subpolicies are related to Public Facilities, two (2) policies and 13 subpolicies are related to Food Access, one (1) policy and seven (7) subpolicies are related to Physical Activity, one (1) policy and 13 subpolicies are related to Safe and Sanitary Housing, and one (1) policy and 15 subpolicies are related to Civic Engagement. These new goals and policies can be found in Appendix B of this addendum.
1.2 C alifornia Environmental Quality Act
CEQA requires that state and loca l government agencies consider the environmental consequences of projects over which they have discretionary authority before taking action on those projects (Public Resources Code sections 21000 et seq.). CEQA also requires that each public agency mitigate or avoid, wherever feasible, the significant environmental impacts of a project that it approves or implements. A significant impact is one that would lead to a substantial adverse change in the physical conditions of the environmental areas affected by the project.
An Environmental Impact Report (“ElR”) is an informational document used in state, regional, and local planning and decision -making processes to meet the requirements of CEQA. The ElR for a proposed project must disclose environmental effects that cannot be avoided; growth- inducing effects; effects found not to be significant; and significant cumulative impacts of all past, present and reasonably anticipated future projects. In addition, an EIR must identify potential methods of avoiding or reducing effects (i.e., mitigation measures) and alternatives to the proposed project or program.
1.3 F inal EIR for the 2012 General P lan Update, Downtown Specific Plan Update, and Climate Action Plan
The Final EIR addresses a full range of environmental issues associated with the 20-year planning horizon of the 2012 General Plan (actual horizon year: 2035). The Final EIR was certified on May 23, 2012, by the Escondido City Council (Resolution No. 2012 -53.) A Mitigation Monitoring and Reporting Program (“MMRP”); Findings of Fact including significant and unavoidable air quality, biological resources, noise, vibration, housing, traffic, and utilities impacts; and a Statement of Overriding Considerations were also adopted at the same public hearing.
This Addendum constitutes the fourth addendum to the Final EIR. The first addendum to the Final EIR was prepared for the Downtown Specific Plan Density Transfer Program, which was adopted by City Council Resolution 2019-06 on May 8, 2019. The second addendum to the Final EIR was prepared for the Downtown Specific Plan amendment to address and remove ground-floor retail requirements, which was adopted by City Council Resolution 2021-114 on August 11, 2021. The third addendum to the Final EIR was prepared for the 6th Cycle Housing Element Update of the General Plan, which was adopted by City Council Resolution 2023-31 on August 11, 2021.
Reslution No. 2025-112
Exhibit "E"
368
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1.4 Lead Agency and Discretionary Approvals
This Addendum documents the City’s consideration of the potential e nvironmental impacts resulting from the change in the project by way of the Community Protection and Community Health and Services amendments and explains the City’s decision that a subsequent EIR is not required. The City of Escondido is the lead agency and has approval authority over the Project and changes.
1.5 D ocuments Incorporated by Reference
CEQA Guidelines section 15150 authorizes agencies to incorporate by reference other documents that provide relevant data and analysis into their environ mental documents. The following documents are hereby incorporated by reference within this Addendum, and all of these documents are considered part of the Final EIR:
• Draft Environmental Impact Report – City of Escondido General Plan Update, Specific Plan Update, and Climate Action Plan, Draft Environmental Impact Report, State Clearinghouse #2010071064, prepared for the City of Escondido, by Atkins, dated January 10, 2012. • Final Environmental Impact Report – City of Escondido General Plan Update, Specific Plan Update, and Climate Action Plan, Draft Environmental Impact Report, State Clearinghouse #2010071064, prepared for the City of Escondido, by Atkins, dated April 23, 2012. • First addendum to the previously adopted EIR for 2012 General Plan Update, Downtown Specific Plan Update, and Climate Action Plan, prepared for the City of Escondido, by Harris & Associates, adopted May 8, 2019.
• Second addendum to the previously adopted EIR for 2012 General Plan Update, Downtown Specific Plan Update, and Climate Action Plan, adopted August 11, 2021. • Third addendum to the previously adopted EIR for 2012 General Plan Update, Downtown Specific Plan Update, and Climate Action Plan, adopted August 11, 2021. • Multi-Jurisdictional Hazard Mitigation Plan: City of Escondido Annex, dated 2023. • City of Escondido Climate Action Plan (E-CAP), dated March 2021
1.6 Document Availability
The Office of the City Clerk is the custodian of the administrative record f or the Final EIR. The administrative record is available for public review during normal business hours.
2.0 CEQA REQUIREMENTS
2.1 Use of an Addendum
Section 15160 of the CEQA Guidelines explains that there are several mechanisms and variations in environmental documents that can be tailored to different situations and intended uses of environmental review. These variations, including Subsequent EIRs, Supplemental EIRs, and Reslution No. 2025-112
Exhibit "E"
369
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A d d e n d a , a r e n o t e x c l u s i v e . “ L e a d a g e n c i e s m a y u s e o t h e r v a r i a ti o n s c o n s i s t e n t w i t h t h e guidelines to meet the needs of other circumstances.” (CEQA Guidelines § 15160.) Public Resources Code section 21166 sets the standard to determine whether another EIR should be prepared when an original EIR has been prepared. Section 21166 states:
When an environmental impact report has been prepared for a project pursuant to this division, no subsequent or supplemental environmental impact report shall be required by the lead agency or by any responsible agency, unless one or more of the following events occurs:
(a) Substantial changes are proposed in the project which will require major revisions of the environmental impact report.
(b) Substantial changes occur with respect to the circumstances under which the project is being undertaken which will require major revisions in the environmental impact report. (c) New information, which was not known and could not have been known at the time the environmental impact report was certified as complete, becomes available.
Similarly, CEQA Guidelines Section 15162 states:
(a) When an EIR has been certified or a negative declaration adopted for a project, no subsequent EIR shall be prepared for that project unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more of the following:
(1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;
(2) Substantial changes occur with respect to the circumstances under which the project is undertaken, which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or
(3) New information of substantial importance which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the Negative Declaration was adopted, shows any of the following:
(A) The project will have one or more significant effects not discussed in the previous EIR or negative declaration;
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(B) Significant effects previously examined will be substantially more severe than shown in the previous EIR;
(C) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or
(D) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative. (b) If changes to a project or its circumstances occur or new information becomes available after adoption of a negative declaration, the lead agency shall prepare a subsequent EIR if required under subsection (a). Otherwise, the lead agency shall determine whether to prepare a subsequent negative declaration, an addendum, or no further documentation. (c) Once a project has been approved, the lead agency’s role in project approval is completed, unless further discretionary approval on that project is required. Information appearing after an approval does not require reopening that approval. If after the project is approved, any of the conditions described in subsection (a) occurs, a subsequent EIR or negative declaration shall only be prepared by the public agency which grants the next discretionary approval for the project, if any. In this situation no other Responsible Agency shall grant an approval for the project until the subsequent EIR has been certified or subsequent negative declaration adopted.
(d) A subsequent EIR or subsequent negative declaration shall be given the same notice and public review as required under Section 15087 or Section 15072. A subsequent EIR or negative declaration shall state where the previous document is available and can be reviewed.
Thus, CEQA Guidelines section 15162 clarifies that a subsequent EIR or supplemental EIR is only required when "substantial changes" occur to a project or the circumstances surrounding a project, or "new information" about a project implicates "new significant environmental effects" or a "substantial increase in the severity of previously significant effects." In evaluating whether these thresholds are met, the key is to determine if any circumstances have changed enough to justify repeating a substantial portion of the environmental documentation process. If conditions do not justify a new or suppl emental EIR, but minor additional or technical changes are appropriate to keep the document current and useful, an agency may prepare an addendum. (CEQA Guidelines § 15164).
Specifically, CEQA Guidelines section 15164 states:
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(a) The lead agency or a responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred (b) An addendum to an adopted negative declaration may be prepared if only minor technical changes or additions are necessary or none of the conditions described in Section 15162 calling for the preparation of a subsequent EIR or negative declaration have occurred.
(c) An addendum need not be circulated for public review but can be included in or attached to the final EIR or adopted negative declaration. (d) The decision-making body shall consider the addendum with the final EIR or adopted negative declaration prior to making a decision on the project. (e) A brief explanation of the decision not to prepare a subsequent EIR pursuant to Section 15162 should be included in an addendum to an EIR, the lead agency's required findings on the project, or elsewhere in the record. The explanation m ust be supported by substantial evidence.
2.2 Summary of Analysis and Findings
Based upon the supporting checklist responses (Section 3), other than the minor changes to the Project in reference to map changes and text changes, the environmental effects associated with the changes in the Project do not require additional analysis beyond the analysis previously prepared and distributed in the Final EIR.
Pursuant to CEQA Guidelines section 15164, the City of Escondido finds that only m inor modifications are required and that none of the conditions described in Public Resources Code section 21166 or CEQA Guidelines section 15162 requiring preparation of a subsequent or supplemental EIR have occurred. More specifically, the City of Escond ido has determined all of the following:
• There are no substantial changes to the Project that would require major revisions of the Final EIR due to new significant environmental effects or a substantial increase in the severity of impacts identified in the previous Final EIR. • No substantial changes have occurred in the circumstances under which the project is being undertaken that will require major revisions of the Final EIR to disclose new significant environmental effects or that would result in a substantial increase in the severity of the impacts identified in the Final EIR.
• There is no new information of substantial importance, which was not known at the time that the previous Certified Final EIR for the proposed Project was circulated, indicating that:
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o The Project will not have one or more significant effects not previously discussed in the Certified Final EIR;
o There are no impacts that were determined to be significant in the previous Certified Final EIR that would be substantially more severe. o There are no additional mitigation measures or alternatives to the project that would substantially reduce one or more of the significant effects identified in the previous Certified Final EIR; and
o There are no additional mitigation measures or alternative s which were rejected that are considerably different from those analyzed in the previous Certified Final EIR that would substantially reduce any significant impact identified in the Certified Final EIR.
Reslution No. 2025-112
Exhibit "E"
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3.0 ENVIRONMENTAL ANALYSIS
This section of the Addendum analyzes the potential environmental effects associated with the implementation of the General Plan to update the Community Protection and Community Health and Services Chapters as compared to the environmental analysis provided in the Final EIR. Each environmental topic is organized first to identify the impacts and significance level determinations previously identified in the Final EIR, second to identify the impacts of the Project and whether new or increased severity of significant impacts would occur, and third to evaluate whether the Project would result in substantial changes in the circumstances or new information not previously identified in the Final EIR. This section provides substantial evidence to support the findings and ba sis to prepare the Addendum, which is that the Project would not create substantial changes, or bring to light new information of substantial importance that was not previously examined in the Final EIR, that would trigger the preparation of a subsequent o r supplemental EIR as set forth in CEQA Guidelines sections 15162 and 15163. As such, the Addendum is consistent with the provisions of CEQA Guidelines section 15164 because only minor changes and additions to the Final EIR are necessary to address the project.
The Environmental Impact Report EIR for the City’s General Plan is a program- level (also called “first-tier”) document prepared under CEQA Guidelines section 15168 and 15152. Its purpose is to evaluate, at a broad citywide /program-level scale, the environmental effects of adopting the General Plan’s goals, policies, and land-use diagram. Goals and policies are a jurisdiction’s way of setting forth guidelines to govern future growth and development. Every new development within the City of Escondido will need to be checked against the General Plan goals and policies to ensure consistency. Individual development proposals that come forward after General Plan adoption will be “second -tier” or “project -level” actions that will undergo their own environmental review, which will “tier” from (i.e., incorporate by reference and build on) the program-level analysis in this EIR.
Reslution No. 2025-112
Exhibit "E"
374
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11 | DRAFT Addendum June 2025
3.1 Aesthetics
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More Severe
Significant and
Unmitigated
Impact?
Substantial Change
in Project;
Substantial Change
in Circumstances; or
New Information
Which Could Not
Have Been Known
SEIR
Required?
Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse
effect on a scenic vista? ☒ ☐ ☐ ☐
b) Substantially damage scenic
resources, including, but not
limited to, trees, rock
outcroppings, and historic
buildings within view from a
state scenic highway?
☒ ☐ ☐ ☐
c) 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, would the project
conflict with applicable zoning
and other regulations
governing scenic quality?
☒ ☐ ☐ ☐
d) Create a new source of
substantial light or glare which
would adversely affect day or
nighttime views in the area?
☒ ☐ ☐ ☐
These less than significant impacts were addressed in Section 4.1, Aesthetics, of the Final EIR, on pages 4.1-1 through 4.1-50.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the Reslution No. 2025-112
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City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural an d man -made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire , flood, and hazards protection, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Chapter.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law . The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policie s, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accord ance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
As described in the Final EIR Section 4.1, Aesthetics issues would result in less than significant impacts resulting from the implementation of the Escondido General Plan Update (“GP 2012 Reslution No. 2025-112
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Update”), Downtown Specific Plan Update (“DSP Update”), and the Escondido Climate Action Plan (“E -CAP”). Implementation of the GP 2012 Update, DSP Update, and E -CAP would not obstruct existing views and resources by complying with existing regulations and the proposed GP 2012 Update and DSP Update policies. Implementation of the City’s Grading and Erosion Ordinance and General Plan update policies in the Resource Conservation Chapter would protect views of ridgelines by requiring development to comply with grading design guidelines for development on all steep slopes, requiring slope analyses and visual analyses for development near skyline ridges, and prohibiting development on skyline ridges. Implementation of the GP 2012, DSP Update, and E-CAP , would have the potential to change the existing visual character or quality in some areas of the City, but not degrade it. Development consistent with the GP 2012 Update and DSP Update would be high quality development designed to be compatible with existing adjacent land uses. Additionally, there would not be substantial impacts in regards to lighting or glare, as all new development would be required to comply with the City’s outdoor lighting ordinance. Also, the GP 2012 Update and DSP Update include policies that require new development, including development that would install reflective surfaces as part of the E -CAP implementation, to avoid light and glare impacts, including spillover light and incompatible glare.
Therefore, impacts to Aesthetic Issues would be less than significant.
No new goals and policies associated with the Project are related to aesthetics. All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review.
Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Chapter updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discussion, the Project is not expected to result in new or more severe impacts to aesthetics. Refer to the Final EIR for the original environmental analysis for aesthetics.
Reslution No. 2025-112
Exhibit "E"
377
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3.2 Agricultural Resources
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in Circumstances;
or New Information
Which Could Substantial
Change in Project;
Substantial Change in
Circumstances; or New
Information Which Could
Not Have Been Known
SEIR
Required?
Would the project:
a) Convert Prime
Farmland, Unique
Farmland, or Farmland of
Statewide Importance
(Farmland), as shown on
the maps prepared
pursuant to the Farmland
Mapping and Monitoring
Program of the California
Resources Agency, to non-
agricultural use?
☒ ☐ ☐ ☐
b) Conflict with existing
zoning for agricultural use,
or a Williamson Act
contract?
☒ ☐ ☐ ☐
c) Conflict with existing
zoning for, or cause
rezoning of, forest land (as
defined in Public
Resources Code section
12220(g)), timberland (as
defined in Public
Resources Code section
4526), or timberland
zoned Timberland
Production (as defined in
Government Code section
51104(g))?
☒ ☐ ☐ ☐
d) Result in the loss of
forest land or conversion
of forest land to non-
forest use?
☒ ☐ ☐ ☐
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Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in Circumstances;
or New Information
Which Could Substantial
Change in Project;
Substantial Change in
Circumstances; or New
Information Which Could
Not Have Been Known
SEIR
Required?
e) Involve other changes
in the existing
environment which, due
to their location or nature,
could result in conversion
of Farmland, to non-
agricultural use or
conversion of forest land
to non-forest use?
☒ ☐ ☐ ☐
These less than significant impacts were addressed in Section 4.2, Agricultural Resources, of the Final EIR on pages 4.2-1 through 4.2-28.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man- made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Reslution No. 2025-112
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379
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Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaste r preparedness, police services, code compliance, fire, flood, and hazards protection, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Chapter.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities.
This will guide the City’s efforts to
address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Chapter.
Conclusion
As described in the Final EIR Section 4.2, Agricultural Resources issues would result in less than significant impacts resulting from the implementation of the GP 2012 Update, DSP Update, and the E-CAP . Implementation of the GP 2012 Update would result in the potential direct conversion of 1,846 acres of agricultural resources. However, the GP 2012 update provides multiple policies within various elements that promote preservation and encourage agricultural uses within the City. The E-CAP provides reduction measures that encourage agricultural efficiencies. Additionally, zoning designations would be made consistent with the GP land use designations with the adoption of the GP 2012 Update and would not impact any land under an existing Williamson Act Contract. Implementation of the GP 2012 Update policies and smart growth planning strategies would reduce the potential for agricultu ral resources to be converted to non-agricultural uses.
Therefore, impacts to Agricultural Resource issues would be less than significant.
No new goals and policies associated with the Project are related to agricultural resources. All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Chapter Reslution No. 2025-112
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updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discussion, the Project is not expected to result in new or more severe impacts to agricultural resources. Refer to the Final EIR for the original environmental analysis for agricultural resources.
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Exhibit "E"
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3.3 Air Quality
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in Circumstances;
or New Information Which
Could Substantial Change
in Project; Substantial
Change in Circumstances;
or New Information Which
Could Not Have Been
Known
SEIR
Required?
Would the project:
a) Conflict with or
obstruct implementation
of the applicable air
quality plan?
☒ ☐ ☐ ☐
b) 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?
☒ ☐ ☐ ☐
c) Expose sensitive
receptors to substantial
pollutant
concentrations?
☒ ☐ ☐ ☐
d) Result in other
emissions (such as those
leading to odors
adversely affecting a
substantial number of
people?
☒ ☐ ☐ ☐
These impacts were addressed in section 4.3, Air Quality, of the Final EIR on pages 4.3-1 through
4.3-40.
Community Pr otection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final Reslution No. 2025-112
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19 | DRAFT Addendum June 2025
EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man- made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory require ments of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the doc ument would ensure future development is in accordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
Reslution No. 2025-112
Exhibit "E"
383
Item11.
20 | DRAFT Addendum June 2025
As described in the Final EIR Section 4.3, Air Quality, implementation of the GP 2012 Update, DSP Update, and the E-CAP is consistent with the SANDAG projections accounted for in the Regional Air Quality Strategy (“RAQS”) and the State Implementation Plan (“SIP”). Future development would be required to demonstrate compliance with the strategies and measures adopted as part of the RAQS and SIP during the City’s environmental review process, as well as with the requirements of the C ity and/or the San Diego Pollution Control District (“SDAPCD”) to reduce emissions of particulate matter. Therefore, these impacts would be less than significant.
Annual construction emissions and operational emissions associated with future development under the GP 2012 Update would result in significant emissions of volatile organic carbons (“VOCs”), particulate matter 10 (“PM10”), and PM2.5. Realistically, yearly construction emissions for all pollutants may be greater or lower depending on how development is implemented. Future development under the GP 2012 Update would be required to comply with CARB motor vehicle standards, SDAPCD regulations from stationary sources and architectural coatings, and the GP 2012 Update goals and policies. Additionally, the San Diego Air Basin (“SDAB”) is a nonattainment area for the state standards for ozone, PM10, and PM2.5. Therefore, with the implementation of the GP 2012 Update, DSP Update, and E-CAP , there would be a cumulatively considerable impact for these pollutants. Mitigation measures Air-1 and Air-2 would be incorporated to mitigate these effects. While these measures and policies are intended to reduce impacts associated with air quality violations, these measures cannot guarantee that emissions would be reduced to a less than significant level. Therefore, even with the implementation of mitigation, impacts from construction and operation would remain significant and unavoidable under this issue.
Future development consistent with the GP 2012 Update, DSP Update, and E -CAP , would result in potentially significant emissions of diesel particulate matter (“DPM”) and toxic air contaminants (“TACs”). Land development projects are required to comply with AB 2588, SDAPCD RULE 1210, Toxic Air Contaminant Public Health Risks – Public Notification and Risk Reduction, and CARB standards for diesel engines. The GP 2012 Update Air Quality and Climate Protection Element requires future land uses to be sited according to CARB recommendations. However, CARB does not make specific recommendations for certain potential sources of TACS including waste transfer, industrial, medical, and research and development facilities. Incorporation of mitigation measures Air-3 and Air-4 would reduce potential impacts associated with exposure of sensitive receptors to TACs to less than significant under this issue.
While odor sources are present within the GP 2012 Update and DSP Update planning areas, compliance with SDAPCD Rule 51 and the GP Update 2012 would ensure that a substa ntial number of sensitive receptors would not be exposed to objectionable odors. Therefore, impacts would be less than significant under this issue.
The updates to the Community Health and Services Chapter include new goals and policies related to reducing pollution, such as policies 1.1 through 1.2. A s the Project entails policy adoption only and no physical improvements are proposed or programmed as a result of these policies, these changes would not impact air quality. The Project would inform future City actions Reslution No. 2025-112
Exhibit "E"
384
Item11.
21 | DRAFT Addendum June 2025
by guiding them to consider and prioritize decision making that increase air quality and comply with existing regulations seeking to reduce pollution exposure.
All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discussion, the Project is not expected to result in new or more severe impacts to air quality. Refer to the Final EIR for the original environmental analysis for air quality Reslution No. 2025-112
Exhibit "E"
385
Item11.
22 | DRAFT Addendum June 2025
3.4 Biological Resources
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which Could
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which Could
Not Have Been Known
SEIR
Required?
Would the project:
a) 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?
☒ ☐ ☐ ☐
b) 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 US
Fish and Wildlife Service?
☒ ☐ ☐ ☐
c) 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?
☒ ☐ ☐ ☐
Reslution No. 2025-112
Exhibit "E"
386
Item11.
23 | DRAFT Addendum June 2025
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which Could
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which Could
Not Have Been Known
SEIR
Required?
d) 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?
☒ ☐ ☐ ☐
e) Conflict with any local
policies or ordinances
protecting biological
resources, such as a tree
preservation policy or
ordinance?
☒ ☐ ☐ ☐
f) Conflict with the
provisions of an adopted
Habitat Conservation Plan,
Natural Community
Conservation Plan, or other
approved local, regional, or
state habitat conservation
plan?
☒ ☐ ☐ ☐
These significant impacts were addressed in Section 4.4, Biological Resources, of the Final EIR on pages 4.41 through 4.4-40.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the Reslution No. 2025-112
Exhibit "E"
387
Item11.
24 | DRAFT Addendum June 2025
City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man -made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were developed by identifying disadvantaged co mmunities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual dev elopment is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with reduced pollution exposure, increased public facilitie s, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
Reslution No. 2025-112
Exhibit "E"
388
Item11.
25 | DRAFT Addendum June 2025
As described in the Final EIR Section 4.4, Biological Resources, implementation of the GP 2012 Update, DSP Update, and the E -CAP would have the potential to result in direct and indirect impacts to special status plant and wildlife species and their habitats, riparian habitats, sensitive communities, wildlife corridors, and native wildlife nursery sites. Existing federal and state regulations and land use agreements prohibit the take of sensitive species without permitting from wildlife and limit the amount of habitat that can be impacted by new development. The goals an d p o l i c i e s o f t h e G P 2 0 1 2 U p d a t e i n c l u d e d i n t h e R e s o u r c e C o n s e r v a ti o n E l e m e n t , Community Health and Services Element, and Land Use and Community Form Element require projects with the potential to impact sensitive species to prepare a biological survey and mitigate any impacts that would occur. Appropriate mitigation is required to be determined through consultation with the wildlife agencies. The update of the Community Health and Services Chapter associated with the Project would not impact the previousl y approved mitigation.
Compliance with these goals and policies would lessen impacts from the GP 2012 Update, DSP Update, and the E-CAP under these issues; however, a significant cumulative impact still exists for these issues. Adoption of the City’s Multi ple Habitat Conservation Program (“MHCP”) Subarea Plan would establish an implementation program to protect biological resources. Until the City has adopted this plan, these impacts would be cumulatively considerable.
Implementation of the GP 2012 Update, DSP Update, and the E-CAP would have the potential to result in impacts to federal wetlands from future development. However, future development that would potentially impact a wetland would be required to obtain permitting from federal and/or state regulations. Additionally, GP 2012 Update policies included in the Resource Conservation element would ensure impacts would be less than significant under this issue.
Future projects under the GP 2012 Update, DSP Update, and the E -CAP would be required to comply with all applicable sections of the City’s Zoning Ordinance, existing regulations, preservation agreements, and applicable habitat conservation plans and Natural Community C o n s e r v a ti o n P l a n s ( “ N C C P s ” ) a s w e l l a s p o l i c i e s i n t h e G P 2 0 1 2 U p d a t e . T h e r efore, impacts associated with conflicts with local polices and ordinances and habitat conservation plans and NCCPs would be less than significant under these issues.
No new goals and policies associated with the Project are related to biological resources. All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Reslution No. 2025-112
Exhibit "E"
389
Item11.
26 | DRAFT Addendum June 2025
Based on the above discussion, the Project is not expected to result in new or more severe impacts to biological resources. Refer to the Final EIR for the original environmental analysis for biological resources.
Reslution No. 2025-112
Exhibit "E"
390
Item11.
27 | DRAFT Addendum June 2025
3.5 Cultural Resources
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project Includes
New or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial Change
in Circumstances; or New
Information Which Could
Substantial Change in
Project; Substantial Change
in Circumstances; or New
Information Which Could Not
Have Been Known
SEIR
Required?
Would the project:
a) Cause a
substantial adverse
change in the
significance of a
historical resource
pursuant to
§ 15064.5?
☒ ☐ ☐ ☐
b) Cause a
substantial adverse
change in the
significance of an
archaeological
resource pursuant to
§ 15064.5?
☒ ☐ ☐ ☐
c) Disturb any
human remains,
including those
interred outside of
formal cemeteries?
☒ ☐ ☐ ☐
These impacts were addressed in Section 4.5, Cultural and Paleontological Resources, of the Final EIR on pages 4.5-1 through 4.5-48.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community Reslution No. 2025-112
Exhibit "E"
391
Item11.
28 | DRAFT Addendum June 2025
from future unnecessary natural and man- made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no chan ges would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identi fied under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities.
This will guide the City’s efforts to
address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; n o actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
As described in the Final EIR Section 4.5, Cultural and Paleontological Resources, implementation of the GP 2012 Update, DSP Update, and the E-CAP would have potentially significant impacts to historical and archeological resources. Future development projects would have the potential to Reslution No. 2025-112
Exhibit "E"
392
Item11.
29 | DRAFT Addendum June 2025
result in substantial adverse changes to the significance of archeological and historical resources through demolition, destruction, alteration, or structural relocation as well as disturbance of an important archeological site that contains or has the potential to contain information important to history or prehistory. While existing City and County policies and regulations and the GP 2012 Update and DSP Update goals and policies are intended to protect historical and archeological resources, the incorporation of mitigation measures Cul-1, Cul-2, Cul-3, Cul-4, Cul-5, and Cul-6 are necessary to ensure the intended protections are achieved. Therefore, with the inclusion of mitigation, impacts would be less than significant under these issues.
Future development under the GP 2012 Update, DSP Update, and E-CAP would have the potential to damage or destroy paleontological resources in the underlying rock units due to construction- related and earth -disturbing actions. The plan areas range from no potential to moderate potential for paleontological resources meaning it is possible for ground -disturbing activities to destroy fossil-bearing geologic formations. However, existing policies and regulations and the GP 2012 Update goals and policies (i.e. Goal 5 of the Resource Conservation Element and Policy 5.2) would protect unique paleontological resources. Therefore, impacts would be less than significant under this issue.
Implementation of the GP 2012 Update, DSP Update, and the E-CAP would have the potential to disturb human remains, including those located outside of formal cemeteries, due to ground disturbing activities from the development of land. However, compliance with existing federal and state policies and regulations (i.e. Health and Safety Code Section 7050.5 and Public Resources Code 5097.98) would reduce impacts associated with human remains to a level below significant under this issue.
No new goals and policies associated with the Project are related to cultural resources. All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient informati on is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discussion, the Project is not expected to result in new or more severe impacts to cultural resources . Refer to the Final EIR for the original environmental analysis for cultural resources.
Reslution No. 2025-112
Exhibit "E"
393
Item11.
30 | DRAFT Addendum June 2025
3.6 Energy
Potentially
Significant
Impact
Less than
Significant
with Mitigation
Incorporated
Less-than-
Significant
Impact
No
Impact
Would the project:
a) Result in potentially significant environmental
impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
☐ ☐ ☐ ☒
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
☐ ☐ ☐ ☒
This section was not required at the time of the Final EIR in 2012, and as a result , these issues were not addressed.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man- made hazards. This will gu ide the City’s efforts to address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated d isaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Reslution No. 2025-112
Exhibit "E"
394
Item11.
31 | DRAFT Addendum June 2025
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to bett er understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
The Project would not r esult in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation. The Project would not c onflict with or obstruct a state or local plan for renewable energy or energy efficiency. The adoption of the Project woul d not result in any chan ges to the environment, and the updated policies contained within the revised Community Health and Services and Community Protection Chapters are intended to reduce impacts to energy use, especially within environmental justice communities.
No new goals and policies associated with the Project are related to energy. All future projects that propose a physical change in the environment associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen a ny environmental impacts, not increase. The potential impacts of any specific future projects that might impact the environment associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA. However, the proposed changes in policies and programs overall will not create significant environmental impacts. Therefore, the Project would not result in impacts with regard to energy.
Reslution No. 2025-112
Exhibit "E"
395
Item11.
32 | DRAFT Addendum June 2025
3.7 Geology and Soils
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which
Could Substantial
Change in Project;
Substantial Change in
Circumstances; or New
Information Which
Could Not Have Been
Known
SEIR
Required?
Would the project:
a) Directly or indirectly
cause potential substantial
adverse effects, including
the risk of loss, injury, or
death involving:
i) 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.
☒ ☐ ☐ ☐
ii) Strong seismic ground
shaking?
☒ ☐ ☐ ☐
iii) Seismic-related
ground failure, including
liquefaction?
☒ ☐ ☐ ☐
iv) Landslides? ☒ ☐ ☐ ☐
b) Result in substantial soil
erosion or the loss of
topsoil?
☒ ☐ ☐ ☐
Reslution No. 2025-112
Exhibit "E"
396
Item11.
33 | DRAFT Addendum June 2025
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which
Could Substantial
Change in Project;
Substantial Change in
Circumstances; or New
Information Which
Could Not Have Been
Known
SEIR
Required?
c) 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?
☒ ☐ ☐ ☐
d) Be located on expansive
soil, as defined in Table 18-
1-B of the Uniform Building
Code (1997), creating
substantial direct or indirect
risks to life or property?
☒ ☐ ☐ ☐
e) Have soils incapable of
adequately supporting the
use of septic tanks or
alternative wastewater
disposal systems where
sewers are not available for
the disposal of wastewater?
☒ ☐ ☐ ☐
f) Directly or indirectly
destroy a unique
paleontological resource or
site or unique geologic
feature?
☒ ☐ ☐ ☐
These less than significant impacts were addressed in Section 4.6, Geology and Soils, of the Final EIR on pages 4.6-1 through 4.6-38.
Community Protection
Reslution No. 2025-112
Exhibit "E"
397
Item11.
34 | DRAFT Addendum June 2025
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man- made hazards. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities.
This will guide the City’s efforts to
address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with reduced pollution exposure, increased public facilities, equitable food Reslution No. 2025-112
Exhibit "E"
398
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35 | DRAFT Addendum June 2025
access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
As described in the Final EIR Section 4.6, Geology and Soils , issues would result in less than significant impacts on geology and soils with the implementation of the GP 2012 Update, the DSP Update, and the E -CAP . The GP 2012 Update would designate land uses that would allow development to occur in areas with geologic hazards such as seismically-induced ground shaking, liquefaction, and landslides as well as impacts to topsoil, expansive soils, and wastewater disposal systems. Impacts from seismically induced fault rupture would not occur due to the lack of active fault traces in the area. Future development would be required to comply with all relevant federal and state regulations and building standards, including Seismic Design Categories E and F structural design requirements identified in the California Building Code (“CBC”) and the National Pollutant Discharge Elimination Sy stem (“NPDES”) to control erosion of unstable soils. The GP 2012 Update also includes multiple policies intended to reduce seismic hazards, soil erosion, landslides, expansive soils, and soils incapable of adequately supporting the use of septic tanks.
Compliance with these regulations and policies would reduce potential impacts to less than significant under these.
The updates to the Community Protection Chapter include new goals and policies related to soils and seismicity, such as policy 7.7. This policy directs the City to coordinate with local and state emergency services departments for earthquake preparedness. A s the Project entails policy adoption only and no physical improvements are proposed or programmed as a result of these policies, these changes would not impact geology and soils. The Project would inform future City actions by guiding them to consider and prioritize decision making that reduce risk associated with geology, soils, and seismicity.
All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discussion, the Project is not expected to result in new or more s evere impacts to geology and soils . Refer to the Final EIR for the original environmental analysis for geology and soils.
Reslution No. 2025-112
Exhibit "E"
399
Item11.
36 | DRAFT Addendum June 2025
3.8 Greenhouse Gas Emissions
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project Includes
New or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial Change
in Circumstances; or New
Information Which Could
Substantial Change in
Project; Substantial Change
in Circumstances; or New
Information Which Could
Not Have Been Known
SEIR
Required?
Would the project:
a) Generate
greenhouse gas
emissions, either
directly or indirectly,
that may have a
significant impact on
the environment?
☒ ☐ ☐ ☐
b) Conflict with any
applicable plan, policy
or regulation of an
agency adopted for
the purpose of
reducing the
emissions of
greenhouse gases?
☒ ☐ ☐ ☐
These less than significant impacts were addressed in Section 4.7, Greenhouse Gas Emissions, of the Final EIR on pages 4.7-1 through 4.7-30.
Community Pr otection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man- made hazards. This will gu ide the City’s efforts to address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would Reslution No. 2025-112
Exhibit "E"
400
Item11.
37 | DRAFT Addendum June 2025
occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated d isaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to bette r understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
As described in the Final EIR Section 4.7, Greenhouse Gas Emissions, issues would result in less than significant impacts from the implementation of the GP 2012 Update, DSP Update, and the E-CAP. Implementation of the GP 2012 Update, DSP Update, and the ECAP would be in compliance with Assembly Bill (“AB”) 32, which sets reduction targets of statewide greenhouse gas (“GHG”) emissions to 1990 levels by 2020 or, as outlined in the AB 32 Scoping Plan, the functional equivalent of 15 percent below current (2005) levels. The GP 2012 Update and E-CAP incorporates GHG-reducing policies and measures that would reduce the City’s emissions by 21% from the 2020 emissions inventory. (The E -CAP was recently amended on March 10, 2021, and the new Reslution No. 2025-112
Exhibit "E"
401
Item11.
38 | DRAFT Addendum June 2025
GHG reductions target is 52% by 2035.) Additionally, future development consistent with the policies of the GP Update 2012 and the reduction measures of the E -CAP , particularly those measures designed to conserve water and reduce energy, would work to reduce the effects of global climate change. Therefore, impacts would be less than significant under these issues.
The updates to t he Community Health and Services Chapter include new goals and policies related to reducing pollution, such as policies 1.1 through 1.2. The updates to the Community Protection Chapter also include new goals and policies relating to climate adaptation and resiliency, such as policy 9.1 which focuses on projecting carbon emissions to prioritize more sustainable future projects. A s the Project entails policy adoption only and no physical improvements are proposed or programmed as a result of these policies , these changes would not impact greenhouse gas emissions. The Project would inform future City actions by guiding them to consider and prioritize decision making that increase air quality and comply with existing regulations seeking to reduce greenhouse gas emissions.
All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discus sion, the Project is not expected to result in new or more severe impacts to greenhouse gas emissions. Refer to the Final EIR for the original environmental analysis for greenhouse gas emissions.
Reslution No. 2025-112
Exhibit "E"
402
Item11.
39 | DRAFT Addendum June 2025
3.9 Hazards and Hazardous Materials
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which Could
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which Could
Not Have Been Known
SEIR
Required?
Would the project:
a) Create a significant
hazard to the public or the
environment through the
routine transport, use, or
disposal of hazardous
materials?
☒ ☐ ☐ ☐
b) Create a significant
hazard to the public or the
environment through
reasonably foreseeable
upset and accident
conditions involving the
release of hazardous
materials into the
environment?
☒ ☐ ☐ ☐
c) Emit hazardous
emissions or handle
hazardous or acutely
hazardous materials,
substances, or waste within
one-quarter mile of an
existing or proposed
school?
☒ ☐ ☐ ☐
Reslution No. 2025-112
Exhibit "E"
403
Item11.
40 | DRAFT Addendum June 2025
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which Could
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which Could
Not Have Been Known
SEIR
Required?
d) Be located on a site
which is included on a list of
hazardous materials sites
compiled pursuant to
Government Code Section
65962.5 and, as a result,
would it create a significant
hazard to the public or the
environment?
☒ ☐ ☐ ☐
e) For a project located
within an airport land use
plan or, where such a plan
has not been adopted,
within two miles of a public
airport or public use
airport, would the project
result in a safety hazard or
excessive noise for people
residing or working in the
project area?
☒ ☐ ☐ ☐
f) Impair implementation of
or physically interfere with
an adopted emergency
response plan or
emergency evacuation
plan?
☒ ☐ ☐ ☐
g) Expose people or
structures, either directly or
indirectly, to a significant
risk of loss, injury or death
involving wildland fires?
☒ ☐ ☐ ☐
Reslution No. 2025-112
Exhibit "E"
404
Item11.
41 | DRAFT Addendum June 2025
These less than significant impacts were addressed in Section 4.8, Hazards and Hazardous Materials, of the Final EIR on pages 4.8-1 through 4.8-54.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man- made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adopti on would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environme ntal justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is Reslution No. 2025-112
Exhibit "E"
405
Item11.
42 | DRAFT Addendum June 2025
proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the doc ument would ensure future development is in accordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
As described in the Final EIR Section 4.8, Hazards and Hazardous Materials, issues would result in less than significant impacts with the implementation of the GP 2012 Update, DSP Update, and the E-CAP . Future businesses, operations, or facilities developed under the GP 2012 Update, DSP Update, and the E-C A P, would involve an increase in the transport, use, and disposal of hazardous waste as well as potential accidental releases of hazardous waste. Additionally, there is potential for hazardous emissions and hazardous materials handling by future development within one - quarter mile of an existing or proposed school as well as human habitation or occupation on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. However, all future development allowable under the proposed land use designations identified in the GP 2012 Update would be required to comply with applicable federal, state, and local regulations related to hazardous materials and wastes. Therefore, impacts would be less than significant under these issues.
Future development with the implementation of the GP 2012 Update, DSP Update, and the ECAP would be predominantly low-density residential land uses or public land/open space within two miles of public or private airports. These land uses have low concentrations of persons, which would reduce the risk of safety hazards for people residing or working in the area. Therefore, significant impacts would not occur under these issues.
The GP 2012 Update, DSP Update, and E -CAP does not include measures that would impair emergency response or evacuation plans. However, it is possible that land uses and development implemented under these plans would require the updating of these emergency response plans.
Compliance with existing regulations and continual updating of emergency response and evacuation plans would prevent implementation of the GP 2012 Update and DSP Update from impairing emergency response and evac uation plans. Impacts would be less than significant under this issue . The update associated with the Community Protection Chapter further incorporates the City’s emergency response and evacuation plans and identifies more comprehensive and existing evacuation routes for the City’s residential parcels. The change primarily consists of updated maps, and as a result would not increase a previously identified impact.
Implementation of the GP 2012 Update and DSP Update would result in land uses that allow residential, commercial, and industrial development in areas that are prone to wildfires due to a majority of the area being susceptible to wildland fires. However, compliance with existing regulations, including the Community Wildfire Protection Plan by the Escondido Fire Department, Reslution No. 2025-112
Exhibit "E"
406
Item11.
43 | DRAFT Addendum June 2025
and implementation of the proposed General Plan Update policies within the Community Protection Chapter would reduce impacts to a level below significant under this issue.
The updates to the Community Protection Chapter include new goals and policies relating to increasing emergency services, and incorporating and following the Local and Multi-Jurisdictional Hazard Mitigation Plan, such as policy 1.15, 1.17, and 9.3. A s the Project entails policy adoption only and no physical improvements are proposed or programmed as a result of these policies , these changes would not impact hazards and hazardous materials . The Project would inform future City actions by guiding them to consider and prioritize decision making that increase safety and comply with existing regulations seeking to reduce hazard exposure.
All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actuall y proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discussion, the Project is not expected to result in new or more severe impacts to hazards and hazardous materials. Refer to the Final EIR for the original environmental analysis for hazards and hazardous materials.
Reslution No. 2025-112
Exhibit "E"
407
Item11.
44 | DRAFT Addendum June 2025
3.10 Hydrology and Water Quality
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in Circumstances;
or New Information
Which Could Substantial
Change in Project;
Substantial Change in
Circumstances; or New
Information Which Could
Not Have Been Known
SEIR
Required?
Would the project:
a) Violate any water
quality standards or
waste discharge
requirements or
otherwise substantially
degrade surface or
groundwater quality?
☒ ☐ ☐ ☐
b) Substantially decrease
groundwater supplies or
interfere substantially
with groundwater
recharge such that the
project may impede
sustainable groundwater
management of the
basin?
☒ ☐ ☐ ☐
c) 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:
☒ ☐ ☐ ☐
i) Result in substantial
erosion or siltation on-
or off-site;
☒ ☐ ☐ ☐
Reslution No. 2025-112
Exhibit "E"
408
Item11.
45 | DRAFT Addendum June 2025
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in Circumstances;
or New Information
Which Could Substantial
Change in Project;
Substantial Change in
Circumstances; or New
Information Which Could
Not Have Been Known
SEIR
Required?
ii) Substantially
increase the rate or
amount of surface
runoff in a manner
which would result in
flooding on- or offsite;
☒ ☐ ☐ ☐
iii) Create or
contribute runoff
water which would
exceed the capacity of
existing or planned
stormwater drainage
systems or provide
substantial additional
sources of polluted
runoff; or
☒ ☐ ☐ ☐
d) In flood hazard,
tsunami, or seiche zones,
risk release of pollutants
due to project
inundation?
☒ ☐ ☐ ☐
e) Conflict with or
obstruct implementation
of a water quality control
plan or sustainable
groundwater
management plan?
☒ ☐ ☐ ☐
These less than significant impacts were addressed in Section 4.9, Hydrology and Water Quality, of the Final EIR on pages 4.9-1 through 4.9-48.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final Reslution No. 2025-112
Exhibit "E"
409
Item11.
46 | DRAFT Addendum June 2025
EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man -made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to thos e topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandat ed regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were de veloped by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in ac cordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
Reslution No. 2025-112
Exhibit "E"
410
Item11.
47 | DRAFT Addendum June 2025
As described in the Final EIR Section 4.9, Hydrology and Water Quality, issues would result in less than significant impacts with the implementation of the GP 2012 Update, DSP Update, and the E- CAP . Construction and operation of future development under th e GP 2012 Update and DSP Update would mandatorily comply with all applicable existing regulations including but not limited to the Clean Water Act, NPDES permit program, Porter-Cologne Water Quality Control Act, San Diego Basin Plan, City of Escondido water quality management plans, as well as policies proposed under the GP 2012 Update in the Resource Conservation Element, Community Protection Element, Mobility and Infrastructure Element, and Land Use Element. The plans would not utilize groundwater for any purpose and would, therefore, not deplete groundwater supplies.
Further, the GP 2012 Update, DSP Updates, and measures identified in the E-CAP would not result in the placement of development in areas that would expose people to hazards associated with inundation by a tsunami, seiches, or mudflows. The update of the Community Protection Chapter associated with the Project would not increase this previously identified impact. Therefore, impacts would be less than significant under these issues.
The updates to the Community Protection Chapter include new goals and policies relating to water flow and flood protection, such as policies 1.7 and 6.1. Additionally, the updates to the Community health and Services Chapter include new goals and policies relating to stormwater infrastructure, such as policies 1.3 and 1.4. As the Project entails policy adoption only and no physical improvements are proposed or programmed as a result of these policies, these changes would not impact hydrology and water quality. The Project would inform future City actions by guiding them to consider and prioritize decision making that increase water quality and comply with existing regulations seeking to provide safe and equitable access to water.
All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discussion, the Project is not expected to result in new or more severe impacts to hydrology and water quality . Refer to the Final EIR for the original environmental analysis for hydrology and water quality.
Reslution No. 2025-112
Exhibit "E"
411
Item11.
48 | DRAFT Addendum June 2025
3.11 Land Use
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project Includes
New or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial Change
in Circumstances; or New
Information Which Could
Substantial Change in
Project; Substantial Change
in Circumstances; or New
Information Which Could
Not Have Been Known
SEIR
Required?
Would the project:
a) Physically divide an
established
community?
☒ ☐ ☐ ☐
b) Cause a significant
environmental impact
due to a conflict with
any land use plan,
policy, or regulation
adopted for the
purpose of avoiding or
mitigating an
environmental effect?
☒ ☐ ☐ ☐
These less than significant impacts were addressed in Section 4.10, Land Use, of the Final EIR on pages 4.10-1 through 4.10-38.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man- made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated Reslution No. 2025-112
Exhibit "E"
412
Item11.
49 | DRAFT Addendum June 2025
regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and haza rds protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to bett er understand the unique and disproportionate challenges faced by these communities.
This will guide the City’s efforts to
address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in ac cordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
As described in the Final EIR Section 4.10, Land Use, issues would result in less than significant impacts with the implementation of the GP 2012 Update, DSP Update, and the E -C A P. T h e G P 2012 Update and DSP Update do not propose any new roadways or other specific features that would physically divide an established community. Growth under the GP 2012 Update would be concentrated in 15 designated study areas and would not substantially change physical development patterns in established communities. Development standards in t he GP 2012 Update would ensure that new development would not preclude future development as long as it is consistent with the proposed land use plan. The DSP Update would retain the development Reslution No. 2025-112
Exhibit "E"
413
Item11.
50 | DRAFT Addendum June 2025
standards that ensure compatibility with the character and vision for the downtown area. The GP 2012 Update, DSP Update, and the E-CAP would not conflict with ant HCPs or NCCPs and would comply with regulations set forth in the Resource Conservation Element in the GP 2012 Update.
Therefore, impacts would be less than significant under these issues.
No new goals and policies associated with the Project are related to land use. All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review.
Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and dispariti es, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discussion, the Project is not expected to result in new or more severe impacts to land use. Refer to the Final EIR for the original environmental analysis for land use.
Reslution No. 2025-112
Exhibit "E"
414
Item11.
51 | DRAFT Addendum June 2025
3.12 Mineral Resources
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project Includes
New or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial Change
in Circumstances; or New
Information Which Could
Substantial Change in
Project; Substantial Change
in Circumstances; or New
Information Which Could Not
Have Been Known
SEIR
Required?
Would the project:
a) Result in the loss
of availability of a
known mineral
resource that would
be of value to the
region and the
residents of the
state?
☒ ☐ ☐ ☐
b) Result in the loss
of availability of a
locally important
mineral resource
recovery site
delineated on a local
general plan,
specific plan or
other land use plan?
☒ ☐ ☐ ☐
These less than significant impacts were addressed in Section 4.11, Mineral Resources, of the Final EIR on pages 4.11-1 through 4.11-14.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man- made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Reslution No. 2025-112
Exhibit "E"
415
Item11.
52 | DRAFT Addendum June 2025
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s eff orts to address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
As described in the Final EIR Section 4.11, Mineral Resources, issues would result in less than significant impacts from the implementation of the GP 2012 Update, DSP Update, and the E-C A P.
The existing GP 2012 Update, DSP Update, and E-CAP does not include any goals or policies specifically related to mineral resources or mineral resource extraction. However, if new mineral extraction facilities were to be approved, it would be required to comply with the goals and policies that apply to all development. The existing GP 2012 Update planning area is developed Reslution No. 2025-112
Exhibit "E"
416
Item11.
53 | DRAFT Addendum June 2025
with land uses that limit the availability of mineral resources. Additionally, only a small portion of the planning area has been designated as containing known mineral resources of value. New development proposed near existing extraction facilities would be required to demonstrate compatibility with existing land uses as part of project approval. Therefore, impacts would be less than significant under these issues.
No new goals and policies associated with the Project are related to mineral resources. All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The poten tial impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discussion, the Project is not expected to result in new or more severe impacts to mineral resources. Refer to the Final EIR for the original environmental analysis for mineral resources.
Reslution No. 2025-112
Exhibit "E"
417
Item11.
54 | DRAFT Addendum June 2025
3.13 Noise
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in Circumstances;
or New Information
Which Could Substantial
Change in Project;
Substantial Change in
Circumstances; or New
Information Which Could
Not Have Been Known
SEIR
Required?
Would the project result in:
a) Generation of a
substantial temporary or
permanent increase in
ambient noise levels in the
vicinity of the project in
excess of standards
established in the local
general plan or noise
ordinance, or applicable
standards of other
agencies?
☒ ☐ ☐ ☐
b) Generation of excessive
groundborne vibration or
groundborne noise levels?
☒ ☐ ☐ ☐
c) For a project located
within the vicinity of a
private airstrip or an
airport land use plan or,
where such a plan has not
been adopted, within two
miles of a public airport or
public use airport, would
the project expose people
residing or working in the
project area to excessive
noise levels?
☒ ☐ ☐ ☐
These impacts were addressed in Section 4.12, Noise, of the Final EIR on pages 4.12 -1 through
4.12-54.
Community Protection
Reslution No. 2025-112
Exhibit "E"
418
Item11.
55 | DRAFT Addendum June 2025
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from futu re unnecessary natural and man -made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pert ain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were de veloped by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in ac cordance with reduced pollution exposure, increased public facilities, equitable food Reslution No. 2025-112
Exhibit "E"
419
Item11.
56 | DRAFT Addendum June 2025
access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
As described in the Final EIR Section 4.12, Noise, future development under the GP 2012 Update, DSP Update, and E-CAP would have the potential to expose noise-sensitive land uses (NSLU) and new commercial, office, and industrial land uses to excessive noise levels from existi ng roadway noise and noise related to existing commercial, industrial, and extractive land uses, and the Palomar Energy Center power plant. However, compliance with existing regulations such as the Noise Ordinance, and implementation of the GP 2012 Update’s goals and policies, including Noise Policies 5.1 through 5.4 and the Noise Compatibility Guidelines, would reduce impacts under this issue to less than significant.
Construction of new land uses under the GP 2012 Update, DSP Update, and E-CAP and placement of new development in close proximity to the SPRINTER rail line would have the potential to result in impacts associated with excessive groundborne vibration. This includes significant impacts related to groundborne noise during construction and potential damage to buildings that may be susceptible to vibration damage from construction equipment. The potential also exists for cumulative construction projects to result in combined construction impacts if occurring simultaneously or construction activities in close proximity to the SPRINTER line.
The GP 2012 Update Noise Policy 5.5 requires compliance with the Federal Transit Administration (FTA) vibration criteria for construction that would occur under these plans. However, additional mitigation is necessary to ensure proper setbacks are established. Mitigation measures Noi-1 and Noi-2 would be implemented to reduce direct and cumulative impacts associated with groundborne vibrations, but not to a less than significant level. Impacts would remain significant and unavoidable under this issue.
Future development and redevelopment consistent with the GP 2012 Update, DSP Update, and E-CAP would have the potential to substantially increase ambient noise levels above existing conditions as a result of increases in roadway noise and new operational noise sources. However, implementation of the GP 2012 Update Noise Policy, including Noise Policy 5.6 which requires technical reports be prepared for future development that would have the potential to substantially increase ambient noise levels, the Incremental Noise Impact Standards by the FTA, and the City’s Noise Ordinance would reduce direct impacts related to permanent increases in ambient noise to less than significant under this issue . However, land use development in accordance with these plans would still contribute to cumulative future regional noise increases associated with roadway traffic. Two mitigation measures were identified to fully reduce impacts to below a level of significance but the City determined that these measures were infeasible.
Future development under the GP 2012 Update, DSP Update, and E-CAP would have the potential to result in temporary increases in ambient noise levels due to construction of new land uses and infrastructure. However, existing City policies, the GP 2012 Update goals and Policies, and the Reslution No. 2025-112
Exhibit "E"
420
Item11.
57 | DRAFT Addendum June 2025
City’s Noise Ordinance would reduce impacts to less than significant under this issue . Future development under the GP 2012 Update, DSP Update, and E -CAP wou ld not expose people residing or working in the GP 2012 Update area to excessive noise levels from a nearby public airport or private airstrip. Impacts would be less than significant under this issue.
No new goals and policies associated with the Project are related to noise. All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review.
Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any sp ecific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
The updates to the Community Protection Chapter associated with the Project would not increase these previously identified impacts. Based on the above discussion, the Project is not expected to result in new or more severe impacts to noise. Re fer to the Final EIR for the original environmental analysis for noise.
Reslution No. 2025-112
Exhibit "E"
421
Item11.
58 | DRAFT Addendum June 2025
3.14 Population and Housing
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in Circumstances;
or New Information
Which Could Substantial
Change in Project;
Substantial Change in
Circumstances; or New
Information Which Could
Not Have Been Known
SEIR
Required?
Would the project:
a) Induce substantial
unplanned population
growth in an area, either
directly (for example, by
proposing new homes
and businesses) or
indirectly (for example,
through extension of
roads or other
infrastructure)?
☒ ☐ ☐ ☐
b) Displace substantial
numbers of existing
people or housing,
necessitating the
construction of
replacement housing
elsewhere?
☒ ☐ ☐ ☐
These impacts were addressed in Section 4.13, Population and Housing, of the Final EIR on pages
4.13-1 through 4.13-24.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man- made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Reslution No. 2025-112
Exhibit "E"
422
Item11.
59 | DRAFT Addendum June 2025
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s eff orts to address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
As described in the Final EIR Section 4.13, Population and Housing, implementation of the GP 2012 Update, DSP Update, and E-CAP would directly and indirectly induce population growth that is consistent with forecasted growth for these plan areas. The GP 2012 Update is a comprehensive plan to guide future growth and includes a framework for land use development, as well as goals and policies to prevent unanticipated or inappropriate population growth in the GP and DSP area.
Reslution No. 2025-112
Exhibit "E"
423
Item11.
60 | DRAFT Addendum June 2025
Compliance with the GP 2012 Update policies and regulations would reduce impacts to less than significant under this issue.
Future development under the GP 2012 Update, DSP Update, and the E -CAP would result in the displacement of substantial number of existing h ousing and people, necessitating the construction of replacement housing elsewhere. The GP 2012 Update land uses would displace up to 142 existing residential dwelling units and the GP 2012 Update’s proposed Mobility and Infrastructure Element would have the potential to displace up to 300 businesses and residences.
Mitigation measure Pop-1 would be implemented to mitigate impacts related to the displacement of homes. Despite compliance with existing regulations, implementation of the proposed GP 2012 Update policies, and mitigation measures Pop -1, the project’s direct impact would remain significant and unavoidable.
The updates to the Community Health and Services Chapter include new goals and policies related to increasing safe and equitable housing access, such as policy 1.8. As the Project entails policy adoption only and no physical improvements are proposed or programmed as a result of these policies, these changes would not impact population and housing. The Project would inform future City actions by guiding them to consider and prioritize decision making that increases safe and sanitary housing and complies with existing housing regulations, including the City’s current and certified sixth cycle housing element.
All future projects associated with env ironmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discussion, the Project is not expected to result in new or more severe impacts to population and housing. Refer to the Final EIR for the original environmental analysis for population.
Reslution No. 2025-112
Exhibit "E"
424
Item11.
61 | DRAFT Addendum June 2025
3.15 Public Services
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project Includes
New or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial Change
in Circumstances; or New
Information Which Could
Substantial Change in
Project; Substantial Change
in Circumstances; or New
Information Which Could Not
Have Been Known
SEIR
Required?
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
a) Fire protection? ☒ ☐ ☐ ☐
b) Police protection? ☒ ☐ ☐ ☐
c) Schools? ☒ ☐ ☐ ☐
d) Parks? ☒ ☐ ☐ ☐
e) Other public
facilities? ☒ ☐ ☐ ☐
These less than significant impacts were addressed in Section 4.1, Aesthetics, of the Final EIR, on pages 4.14-1 through 4.14-38.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man -made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated Reslution No. 2025-112
Exhibit "E"
425
Item11.
62 | DRAFT Addendum June 2025
regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities.
This will guide the City’s efforts to
address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual developm ent is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
As described in the Final EIR Section 4.14, Public Services, these issues would result in less than significant impacts resulting from the implementation of the GP 2012 Update, DSP Update, and E-CAP . Implementation of the GP 2012 Update, DSP Update, and E-CAP would not increase the demand for fire protection, police protection, school services, and library services. Development consistent with the GP 2012 Update and DSP Update includes policies that help to minimize deterioration of fire and policy agency response times and school and library services and environmental impacts related to the construction or expansion of additional facilities. Therefore, impacts would be less than significant under these issues. The updates to the Community Protection Chapter associated with the Project would not increase the previously identified impacts.
Reslution No. 2025-112
Exhibit "E"
426
Item11.
63 | DRAFT Addendum June 2025
The updates to the Community Health and Services Chapter include new goals and policies related to increasing safe and equitable public facilities, such as policies 1.2.8, 1.3, and 1.4. As the Project entails policy adoption only and no physical improvements are proposed or programmed as a result of these policies, these changes would not impact public services. The Project would inform future City actions by guiding them to consider and prioritize decision making that increases access to public facilities.
All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discussion, the Project is not expected to result in new or more severe impacts to public services. Refer to the Final EIR for the original environmental analysis for public services.
Reslution No. 2025-112
Exhibit "E"
427
Item11.
64 | DRAFT Addendum June 2025
3.16 Recreation
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project Includes
New or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in Circumstances;
or New Information Which
Could Substantial Change
in Project; Substantial
Change in Circumstances;
or New Information Which
Could Not Have Been
Known
SEIR
Required?
a) Would the project
increase the use of
existing neighborhood
and regional parks or
other recreational
facilities such that
substantial physical
deterioration of the
facility would occur or
be accelerated?
☒ ☐ ☐ ☐
b) Does the project
include recreational
facilities or require the
construction or
expansion of
recreational facilities
which might have an
adverse physical effect
on the environment?
☒ ☐ ☐ ☐
These less than significant impacts were addressed in Section 4.15, Recreation, of the Final EIR on pages 4.15-1 through 4.15-24.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man- made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Reslution No. 2025-112
Exhibit "E"
428
Item11.
65 | DRAFT Addendum June 2025
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policie s, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in ac cordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
As described in the Final EIR Section 4.15, Recreation, issues would result in less than significant impacts resulting from implementing the GP 2012 Update, DSP Update, and E-CAP . As analyzed in the Final EIR, neighborhood and community parks are currently deficient in the City and implementation of the GP 2012 Update, DSP Update, and E -CAP would increase use of existing parks, thereby resulting in accelerated deterioration of recreational facilities. Additionally, the construction or expansion of recreational facilities to address the increased growth, may have an Reslution No. 2025-112
Exhibit "E"
429
Item11.
66 | DRAFT Addendum June 2025
adverse effect on the environment. However, implementation of the proposed General Plan Update policies and Planning Principal and Guideline 1k(1) within the Downtown Specific Plan Update and E-Cap measures would reduce impacts to below a level of significance under these issues. The updates to the Community Health and Services associated with the Project would not increase these previously identified impacts.
The updates to the Community Health and Services Chapter include new goals and policies related to increasing healthy physical activity and access to recreation, such as policies 1.4 and
1.7. As the Project entails policy adoption only and no physical improvements are proposed or programmed as a result of these policies, these changes would not impact recreation. The Project would inform future City actions by guiding them to consider and prioritize decision making that increases access to recreation.
All future projects associated with environmental justic e and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the G eneral Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discussion, the Project is not expected to result in new or more severe impacts to recreation. Refer to the Final EIR for the original environmental analysis for recreation.
Reslution No. 2025-112
Exhibit "E"
430
Item11.
67 | DRAFT Addendum June 2025
3.17 Transportation and Traffic
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project Includes
New or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial Change
in Circumstances; or New
Information Which Could
Substantial Change in
Project; Substantial Change
in Circumstances; or New
Information Which Could
Not Have Been Known
SEIR
Required?
Would the project:
a) Conflict with a
program, plan,
ordinance, or policy
addressing the
circulation system,
including transit,
roadway, bicycle and
pedestrian facilities?
☒ ☐ ☐ ☐
b) Would the project
conflict or be
inconsistent with
CEQA Guidelines
section 15064.3,
subdivision (b)?
☒ ☐ ☐ ☐
c) Substantially
increase hazards due
to a geometric design
feature (e.g., sharp
curves or dangerous
intersections) or
incompatible uses
(e.g., farm
equipment)?
☒ ☐ ☐ ☐
d) Result in
inadequate
emergency access?
☒ ☐ ☐ ☐
These impacts were addressed in Section 4.16, Transportation and Traffic, of the Final EIR on pages 4.16-1 through 4.16-88. However, since the 2012 EIR was adopted, the CEQA guidelines for Transportation and Traffic analysis have been updated. As a result, section 3.17b of this Reslution No. 2025-112
Exhibit "E"
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addendum was not previously analyzed, as the standards for determining significance were changed from using the Level of Service (LOS) metric to Vehicle Miles Traveled (VMT).
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man- made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and i dentified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities.
This will guide the City’s efforts to
address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; n o actual development is Reslution No. 2025-112
Exhibit "E"
432
Item11.
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proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
As described in the Final EIR Section 4.16, issues would result in some less than significant impacts and one would result in significant and unavoidable impacts resulting from the implementation of the GP 2012 Update, DSP Update, and E -C A P. Implementation of the GP 2012 Update, DSP Update, and E-CAP would not result in changes to air traffic patterns, result in increased traffic on roadways with horizontal or vertical curves that are sharper than existing standards, or impair emergency access. In addition, implementation of policies in the DSP Update and E-CAP measures would create provisions for alternative modes of transportation, including multi -modal transit stations, bike lanes, bus stops, trails, and sidewalks. Therefore, impacts would be less than significant under these issues.
Implementation of the GP 2012 Update, DSP Update, and E -CAP would result in 14 deficient roadway segments and seven deficient intersections throughout the proposed project area resulting in a significant direct and cumulative impact. Implementation of the proposed GP 2012 Update and DSP Update po licies and mitigation measures, in addition to compliance with applicable regulations, would reduce nine traffic impacts to a level below significant. However, 11 roadway segment and intersection impacts would remain above a level of significance because mitigation for these impacts has been determined to be infeasible by the City. Therefore, the proposed project would result in significant and unavoidable traffic and level of service (LOS) impacts under this issue.
Consistency with 15064.3, subdivision (b) (u nchecked box in table above). The criteria for significance in the Transportation and Traffic section of the Final EIR in 2012 has since been updated. Where LOS was initially used to determine significance, VMT is the new threshold pursuant to Senate Bill 743 (2013). Although the criteria has changed, the Project would not result in more significant impacts under the new threshold, VMT. The nature of the policies and programs within the Project would not generate new trips or put any additional vehicles on the road. Additionally, the Project itself does not include any land development. Therefore, there would be no conflict with transportation and traffic impacts under VMT thresholds and no impact associated with the adoption of the Project.
The update associated with the Community Protection Chapter further incorporates the City’s emergency response and evacuation plans, and identifies existing comprehensive evacuation routes for the City’s residential parcels. The change primarily consists of updated maps, and a s the Project entails policy adoption only and no physical improvements are proposed or programmed as a result of these policies , these changes would not impact transportation and Reslution No. 2025-112
Exhibit "E"
433
Item11.
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traffic. The Project would inform future City actions by guiding them to consider and prioritize decision making that decrease traffic impacts and improve efficient and sustainable modes of transportation.
All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of the se Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Based on the above discussion, the Project is not expected to result in new or more severe impacts to transportation and traffic. Refer to the Final EIR for the original environmental analysis for transportation and traffic.
Reslution No. 2025-112
Exhibit "E"
434
Item11.
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3.18 Tribal Cultural Resources
Potentially
Significant
Impact
Less than
Significant
with Mitigation
Incorporated
Less-than-
Significant
Impact
No
Impact
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 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 Cultural Native American tribe, and that is:
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), or
☐ ☐ ☐ ☒
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 Section
5024.1. In applying the criteria set forth in
subdivision (c) of Public Resource Code Section
5024.1, the lead agency shall consider the
significance of the resource to a California Native
American tribe.
☐ ☐ ☐ ☒
This section w as not required at the time of the Final EIR in 2012, and as a result was not addressed.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man- made hazards. This will gu ide the City’s efforts to address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
Reslution No. 2025-112
Exhibit "E"
435
Item11.
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The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated d isaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to bette r understand the unique and disproportionate challenges faced by these communities.
This will guide the City’s efforts to
address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
The Project would not cause a substantial adverse change in the significance of a tribal cultural resource as defined in Public Resources Code section 21074 . The adoption of the Project would not result in any changes to the environment, and the updated policies contained within the revised Community Health and Services and Community Protection Elements are intend ed to reduce environmental impacts and impacts to tribal cultural resource, especially within environmental justice communities.
The update to the Community Health and Services Chapter includes a new policy, policy 2.1.15, that is intended to elevate the fair treatment and involvement of Tribal Governments in the decision-making process in Escondido. As the Project entails policy adoption only and no physical improvements are proposed or programmed as a result of these policies , these changes would not impact tribal cultural resources which would trigger subsequent or supplemental review as identified under Sections 15162 and 15163 of the CEQA Guidelines . The Project would inform Reslution No. 2025-112
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future City actions by guiding them to consider and prioritize decision making that includes tribal input and complies with existing regulations, such as A ssembly Bill (AB) 52 and S enate Bill (SB)
18. All future projects that propose a physical change in the environment associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA. However, the proposed changes in policies and programs overall will not create significant environmental impacts to tribal cultural resources.
The City notified all 25 tribes identified by the Native American Heritage Commission (NAHC) for purposes of compliance with SB 18. City staff sent out letters in hard and soft copy form to all 25 tribes in late 2021/early 2022, via certified mail and email, respectively . Mailed letters were generally received between January 2 8, 2022 and February 22, 2022 by various tribes . The City received two requests for consultation under SB 18. The Rincon Band of Luiseno Indians responded to the City’s request on August 9, 2022 and the San Luis Rey Band of Mission Indians responded on March 25, 2022. The City entered into consultations with eac h Tribe beginning in August 2022 and May 2022, respectively.
Consultation may continue through planning commission or city council deliberation on a general plan proposal (State of California Tribal Consultation Guidelines Supplement to General Plan Guidelines, 2005). As of the writing of this Addendum, consultations for purposes of SB 18 are still ongoing and conclusion of consultation efforts pursuant to Government Code section 65352.2 and 65352.4 must occur prior to formal adoption of the Project.
Both the Rincon Band of Luiseno Indians and the San Luis Rey Band of Mission Indians concluded consultation for purposes of SB 18 on July 16, 2025 and September 16, 2025, respectively--prior to the City Council action scheduled for October 1, 2025.
Reslution No. 2025-112
Exhibit "E"
Item11.
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3.19 Utilities and Service Systems
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which
Could Substantial
Change in Project;
Substantial Change in
Circumstances; or New
Information Which
Could Not Have Been
Known
SEIR
Required?
Would the project:
a) Require or result in the
relocation or construction of
new or expanded water,
wastewater treatment or
stormwater drainage, electric
power, natural gas, or
telecommunications facilities
the construction or relocation
of which could cause
significant environmental
effects?
☒ ☐ ☐ ☐
b) Have sufficient water
supplies available to serve the
project and reasonably
foreseeable future
development during normal,
dry and multiple dry years?
☒ ☐ ☐ ☐
c) Result in a determination by
the wastewater treatment
provider which serves or may
serve the project that it has
adequate capacity to serve
the project’s projected
demand in addition to the
provider’s existing
commitments?
☒ ☐ ☐ ☐
Reslution No. 2025-112
Exhibit "E"
438
Item11.
75 | DRAFT Addendum June 2025
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which
Could Substantial
Change in Project;
Substantial Change in
Circumstances; or New
Information Which
Could Not Have Been
Known
SEIR
Required?
d) Generate solid waste in
excess of state or local
standards, or in excess of the
capacity of local
infrastructure, or otherwise
impair the attainment of solid
waste reduction goals?
☒ ☐ ☐ ☐
e) Comply with federal, state,
and local management and
reduction statutes and
regulations related to solid
waste?
☒ ☐ ☐ ☐
These less than significant impacts were addressed in Section 4.17, Utilities and Service Systems, of the Final EIR on pages 4.17-1 through 4.17-58.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from futu re unnecessary natural and man -made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pert ain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated Reslution No. 2025-112
Exhibit "E"
439
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76 | DRAFT Addendum June 2025
regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policie s, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accord ance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
As described in the Final EIR Section 4.17, Utilities and Service Systems, some issues would result in less than significant impacts resulting from the implementation of the GP 2012 Update, DSP Update, and E -C A P. Issues surrounding water supply and landfil l capacity would result in significant and unavoidable impacts resulting from the implementation of the GP 2012 Update, DSP Update, and E -CAP . Implementation of the GP 2012 Update, DSP Update and ECAP could result in the demand for wastewater treatment services to increase at a rate disproportionate to facility capabilities, which would result in a violation in wastewater treatment standards.
However, compliance with existing regulations and implementation of the GP 2012 Update and E-CAP reduction measures would reduce this impact to below a level of significance. Similarly, the implementation of the GP 2012 Update, DSP Update, and E -CAP could have the potential to Reslution No. 2025-112
Exhibit "E"
440
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increase the demand requiring the construction of new or expanded water, wastewater, and stormwater facilities and increase the demand for wastewater treatment services. However, existing regulations and policies in the GP 2012 Update and E -CAP reduction measures would reduce impacts to these facilities and services to levels below significance. Similarly, implementation of the GP 2012 Update, DSP Update, and E -CAP would increase demand for energy, resulting in the need for new or expanded energy facilities to be constructed, which would have the potential to result in significant environmental effects. However, the construction of new energy facilities would be subject to CEQA and/or NEPA and impacts would be mitigated, to the extent feasible. Additionally, multiple GP 2012 Update and E-CAP policies exist that would reduce energy consumption and the need to build new energy facilities. Therefore, impacts associated with energy would be less than significant under these issues.
Implementation of the GP 2012 Update, DSP Update, and E -CAP would result in significant and unavoidable impacts associated with adequate water supplies. Adequate water supply may not be available to serve the proposed project due to projections of water shortages during multiple dry water years by San Diego County Water Authority (“SDCWA”), Vallecitos Water District (“VWD”) and Rincon Del Diablo Water District (“RDD”). Cumulative projects would also result in a significant cumulative impact and the proposed project would contribute to a significant cumulative impact associated with adequate water supplies. Even with compliance with existing regulations, policies contained in the GP 2012 Update policies, E -CAP reduction measures, and mitigation measure Util -1, impacts would remain significant and unavoidable under this issue.
Similarly, the 2012 GP Update, DSP Update, and E-CAP has the potential to be served by a landfill with insufficient capacity to accommodate the solid waste disposal needs of the project.
Compliance with existing regulations and GP 2012 Update policies and E-CAP reduction measures would reduce impacts associated with sufficient landfill capacity, although not to below a level of significance. Mitigation measures have been identified to reduce impacts to a less than significant level; however, the City finds these measures to be infeasible because the y do not meet the project objectives, would prohibit growth, and place undue burden on developers to create additional landfill capacity. Until additional solid waste disposal facilities are permitted and constructed within the San Diego region, the proposed project’s impact would remain significant and unavoidable. Therefore, the 2012 GP Update, DSP Update, and E -CAP would result in significant direct and cumulative impacts under this issue.
The updates to the Community Health and Services Chapter include new goals and policies relating to water access and stormwater infrastructure, such as policies 1.2, 1.3 and 1.4. As the Project entails policy adoption only and no physical improvements are proposed or programmed as a result of these policies , these chang es would not impact utilities and service systems. The Project would inform future City actions by guiding them to consider and prioritize decision making that support service systems infrastructure and comply with existing regulations related to solid waste.
Reslution No. 2025-112
Exhibit "E"
441
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All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Chapter updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improv ed safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
The updates to the Community Pro tection and Community Health and Services Chapters associated with the Project would not increase these previously identified impacts or mitigations.
Based on the above discussion, the Project is not expected to result in new or more severe impacts to utilities and service systems . Refer to the Final EIR for the original environmental analysis for utilities and service systems.
Reslution No. 2025-112
Exhibit "E"
442
Item11.
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3.20 Wildfire
Potentially
Significant
Impact
Less than
Significant
with Mitigation
Incorporated
Less-than-
Significant
Impact
No
Impact
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency
response plan or emergency evacuation plan?
☐ ☐ ☐ ☒
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to, pollutant concentrations from a
wildfire or the uncontrolled spread of a wildfire?
☐ ☐ ☐ ☒
c) Require the installation or maintenance of
associated infrastructure (such as roads, fuel breaks,
emergency water sources, power lines or other
utilities) that may exacerbate fire risk or that may
result in temporary or ongoing impacts to the
environment?
☐ ☐ ☐ ☒
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
☐ ☐ ☐ ☒
This section was not required at the time of the Final EIR in 2012, and as a result was not addressed.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from futu re unnecessary natural and man -made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pert ain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated Reslution No. 2025-112
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443
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regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policie s, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accord ance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
The adoption of the Project would update the Community Protection Chapter to include policies and programs that reduce environmental risks associated with wildfire. The Project would not substantially impair an adopted emergency response plan or emergency evacuation plan . The update associated with the Community Protection Chapter further incorporates the City’s emergency response and evacuation plans, and identifies more comprehensive evacuation routes for the City’s residential parcels. The change primarily consists of updated maps, and as a result would not increase a previously identified impact. The Project would not exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire in that it proposes policy language changes and new direction that seeks to reduce the threat of wildfire within the Project area, as detailed in draft Fire Reslution No. 2025-112
Exhibit "E"
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Protection Policies 2.19 through 2.25. The Project would not r equire the installation o r maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment as the Project entails policy adoption only and no physical improvements are proposed or programmed as a result of these policies. The Project would inform future City actions by guiding them to consider and prioritize decision making that reduces wildfire risk and complies with existing regulations seeking to reduce risk as well. The Community Protection Chapter and the updates associated with this Project are aimed at reducing wildfire risk and pollutant spread. The Project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post -fire slope instability, or drainage changes. The Community Protection Chapter update focuses on policies that reduce exposure to risks associated with wildfire and other hazards.
All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Element updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
However, the proposed changes in policies and programs overall will not create significant wildfire impacts.
Reslution No. 2025-112
Exhibit "E"
445
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3.21 Mandatory Findings of Significance
Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which
Could Substantial
Change in Project;
Substantial Change in
Circumstances; or New
Information Which
Could Not Have Been
Known
SEIR
Required?
a) Does the project have the
potential to substantially
degrade the quality of the
environment, substantially
reduce the habitat of a fish
or wildlife species, cause a
fish or wildlife population to
drop below self-sustaining
levels, threaten to eliminate
a plant or animal community,
substantially reduce the
number, or restrict the range
of a rare or endangered plant
or animal or eliminate
important examples of the
major periods of California
history or prehistory?
☒ ☐ ☐ ☐
b) Does the project have
impacts that are individually
limited, but cumulatively
considerable? ("Cumulatively
considerable" means that
the incremental effects of a
project are considerable
when viewed in connection
with the effects of past
projects, the effects of other
current projects, and the
effects of probable future
projects)?
☒ ☐ ☐ ☐
Reslution No. 2025-112
Exhibit "E"
446
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Issues Areas that
are Consistent
with Previous
Environmental
Document
Project
Includes New
or More
Severe
Significant and
Unmitigated
Impact?
Substantial Change in
Project; Substantial
Change in
Circumstances; or New
Information Which
Could Substantial
Change in Project;
Substantial Change in
Circumstances; or New
Information Which
Could Not Have Been
Known
SEIR
Required?
c) Does the project have
environmental effects which
will cause substantial
adverse effects on human
beings, either directly or
indirectly?
☒ ☐ ☐ ☐
This section was not addressed in the Final EIR of 2012.
Community Protection
The Project seeks to amend the Community Protection Chapter portion of the General Plan to meet the statutory requirements of Safety Element Law, as it was described previously in the Final EIR. The update to the Community Protection Chapter to integrate certain safety policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. These goals, policies, and objectives were developed by identifying potential environmental hazards and improvement areas to better equip the City with the tools to protect the community from future unnecessary natural and man- made hazards . T h i s w i l l g u i d e t h e C i t y ’ s e ff o r t s t o address issues related to public health, social equity, and environmental justice.
Changes incorporated into the goals and policies of the Community Protection Chapter pertain only to those topics which relate to Government Code section 65302(g) and no changes would occur to the portion of the Community Protection Chapter that serves as the City’s Noise Element.
Those changes to the Community Protection Chapter are based on the state mandated regulations outlined within Section 1.1 of this Addendum and identified under section 65302(g)(1-5).
The Community Protection Chapter Update is a policy document and its adopti on would not, in itself, produce environmental impacts. It consists of a safety program that was updated to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Protection Chapter Update. However, implementation of the programs contained in the document would ensure future development is in accordance with updated disaster Reslution No. 2025-112
Exhibit "E"
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84 | DRAFT Addendum June 2025
preparedness, police services, code compliance, fire, flood, and hazards protection, noise exposure, soils and seismic impacts, and climate adaptation and resiliency measures contained in the Element.
Community Health and Services
The Project seeks to amend the Community Health and Services Chapter portion of the General Plan to meet the statutory requirements of Environmental Justice Law. The update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, identifies issues and needs anticipated to be of ongoing concern to people in the City. Environme ntal justice goals, policies, and objectives were developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities.
This will guide the City’s efforts to
address issues related to public health, social equity, and environmental justice.
The Community Health and Services Chapter Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of an environmental justice program that was created to reflect current conditions and legal requirements; no actual development is proposed as part of the Community Health and Services Chapter Update. However, implementation of the programs contained in the doc ument would ensure future development is in accordance with reduced pollution exposure, increased public facilities, equitable food access, increased s afe and sanitary homes, increased physical activity , and inclusive civic engagement measures contained in the Element.
Conclusion
The Final EIR analyzes the Project and its impacts related to the environment. All updates to the Community Protection and the Community Health and Services Chapters include policies and programs aimed at making the city safer for the population and reducing environmental hazards.
Project changes do not result in new impacts or a sub stantial increase in the severity of a previously identified impact, as described above. Standard conditions and mitigation measures identified in the Final EIR that reduce impacts to a less than significant level still apply to the project.
All future projects associated with environmental justice and safety would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review. Both proposed General Plan updates are associated with the reduction of environmental hazards, damage, and disparities, and as such the adoption of these Chapter updates would lessen any environmental impacts, not increase. The potential impacts of any specific future projects associated with improved safety or environmental justice programs underneath the General Plan would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.
Reslution No. 2025-112
Exhibit "E"
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85 | DRAFT Addendum June 2025
4.0 CONCLUSION
4.1 Rationale for the Addendum
The Addendum to the Final EIR finds that the impacts resulting from implementation of the 2012 GP Update, DSP Update, and E -CAP remain the same, aside from the Project’s proposed modification, and the mitigation measures would remain unchanged and are still valid and enforceable. No considerably different mitigation measures or feasible alternatives have been identified. The Addendum finds that the previously identified impacts and mitigation measures, as described in the Final EIR, are still applicable to the General Plan. Therefore, the Final EIR, as certified, remains adequate and complete. The Project can be approved as an activity covered within the scope of the Final EIR. No circumstances exist calling for the preparation of a subsequent or supplemental EIR pursuant to CEQA Guidelines sections 15162 and 15163.
4.2 F indings from the Addendum
There are no substantial changes to the circumstances under which the proposed Project is undertaken that would require major revisions to the Final EI R. There is no new information of substantial importance that was not known or could not have been known at the time the Final EIR was certified that shows the proposed Project would have significant effects not discussed previously; a substantial increase in severity of a previously identified significant impact; mitigation measures or alternatives previously found infeasible that would now be feasible and would substantially reduce one or more significant effects; or mitigation measures or alternatives that are considerably different from those analyzed in the Final EIR that would substantially reduce one or more significant effects on the environment. Environmental effects associated with the Project were evaluated in the Final EIR. The Project would not result in new or more severe impacts beyond those addressed in the Final EIR, and would not meet any other standards for requiring further environmental review under CEQA Guidelines sections 15162 and 15163. No further analysis is required.
Reslution No. 2025-112
Exhibit "E"
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STAFF REPORT
October 1, 2025
File Number 0800-40
SUBJECT
BATTERY ENERGY STORAGE SYSTEMS WITHIN THE CITY OF ESCONDIDO
DEPARTMENT
Development Services Department and Fire Department
RECOMMENDATION
Request the City Council adopt Ordinance No. 2025 -06 extending Urgency Ordinance No. 2024 -12R (“Urgency Ordinance”) prohibiting new commercial Battery Energy Storage Systems within the City of Escondido. The proposal also includes adoption of the environmental determination prepared for the project.
Staff Recommendation: Approval (Development Services: Christopher W. McKinney, Deputy City Manager)
Presenter: Veronica Morones, City Planner
ESSENTIAL SERVICE – Yes, Land Use/Development
COUNCIL PRIORITY – Improve Public Safety
FISCAL ANALYSIS
Returning to the City Council with a proposed extension of the Urgency Ordinance has minimal fiscal impacts associated with staff time . Fiscal impacts associated with any potential stymied BESS development due to the Urgency Ordinance are unknown at this time.
PREVIOUS ACTION
On August 28, 2024, the City Council adopted Resolution No. 2024 -113 ex pressing its position and recommendations on Battery Energy Storage Systems (“BESS”) projects in and adjacent to the City of Escondido.
On October 9, 2024, the City Council adopted, with modification, Ordinance No. 2024 -12R, an Interim Urgency Ordinance prohibiting new commercial BESS within the City of Escondido (“City”) for 45-days. 450
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On November 20, 2024, the City Council adopted Ordinance No. 2024-14R, extending Urgency Ordinance No. 2024-12R for up to 10 months and 15 days so as to provide staff with additional time to study potential impacts of commercial BESS facilities.
On May 7, 2025, the City Council approved the motion to sustain the Urgency Ordinance until the item comes back to the City Council when a cap on the total number of BESS projects has been established by the County; incorporate San Diego County guidelines regarding BESS outlined in Staff Recommendation 3 (May 7, 2025 Staff Report); establish minimum workforce safety standards for all BESS projects 70 Kilowatt Hours and above including: installation, assembly, testing, commissioning, maintenance, repair, retrofitting and decommissioning in the CFC update; require certified electricians for all electrical work who hold a C-10 license; and require minimum of 15 percent (%) of onsite certified electricians performing electrical work hold and ESAMTAC certification.
BACKGROUND
Prior Action
On October 9, 2024, the City Council adopted, with modification, Ordinance No. 2024 -12R, pursuant to Government Code 65858(a), approving a 45-day prohibition on new commercial BESS within the City. On November 20, 2024, the City Council adopted, with modification, Ordinance No. 2024-14R, extending the October 9th adopted ordinance for up to an additional 10 months and 15 days. Together, both ordinances are referred to throughout this report as the “Urgency Ordinance”. On May 7, 2025, the City Council directed staff to keep the Urgency Ordinance in place thereby prohibiting new BESS facilities within the City (refer to Attachment “1” for background on the Urgency Ordinance’s applicability). Pursuant to Government Code 65858, establishment of the initial urgency ordinance allowed for a 45-day prohibition, and subsequently allows for a 10-month and 15-day extension of the Urgency Ordinance, which is set to expire on October 5, 2025.
Extension of Urgency Ordinance
The City Council may choose to extend the Urgency Ordinance up to an additional 12-months (Gov. Code section 65868) beyond the original 10-month and 15-day extension. City Council adoption of Ordinance 2025-06 would extend the Urgency Ordinance for a default period of 12-months, thus setting an expiration date of October 5, 2026, unless otherwise motioned for a timeframe less than 12-months.
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Prior Direction
At the May 7, 2025 City Council meeting, the City Council directed staff to conduct the following:
Council Direction Response
Return when a cap on the total number of battery
energy storage system (BESS) projects has been
established by the County.
As of drafting this staff report, the County has not
yet identified or established any cap or maximum
for BESS projects within the County.
Incorporate into the forthcoming Fire Code (CFC)
update the San Diego County guidelines regarding
BESS outlined in S taff Recommendation 3 of the
May 7, 2025 staff report.
The City’s Fire Department continues to work on
an update to Chapter 11 (Fire Prevention and
Protection) for purposes of compliance with State
law. Staff anticipates little to no issues at this time associated with integrating the County’s BESS
Guidelines. City staff anticipate a CFC ordinance
update before the City Council before end 2025.
Establish minimum workforce safety standards for
all BESS projects 70 Kilowatt Hours and above
including: instal lation, assembly, testing,
commissioning, maintenance, repair, retrofitting
and decommissioning in the CFC update.
City staff continue to research and review
workforce minimums in other jurisdictions. Based
on the stringent timeline for adopting an updated
CFC before January 1, 2026, at this time City staff
anticipate bringing forward a subsequent action
for City Council on workforce minimums.
Require certified electricians for all electrical work
who hold a C -10 license and require minimum of
15% of onsite certified electricians performing
electrical work hold and ESAMTAC certification.
ORDINANCES
a) Ordinance No. 2025-06
b) Ordinance No. 2025-06—Exhibit “A”—10-Day Report
ATTACHMENTS
a) Attachment “1” – May 7, 2025 , November 20, 2024, and October 9, 2024 Council Staff Reports (hyper linked)
b) Attachment “2” - Adopted Urgency Ordinance 2024-12R
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ORDINANCE NO. 2025-06
AN INTERIM ORDINANCE OF THE CITY COUNCIL OF THE
CITY OF ESCONDIDO, CALIFORNIA, EXTENDING
URGENCY ORDINANCE 2024 -12R PROHIBITING NEW
COMMERCIAL BATTERY ENERGY STORAGE SYSTEMS
WITHIN THE CITY OF ESCONDIDO, ADOPTED AS AN
URGENCY MEASURE, AND FINDING THE ACTION TO BE
EXEMPT FROM CEQA
WHEREAS, the City of Escondido, California, (“City”) is a municipal corporation, duly organized under the constitution and laws of the State of California; and WHEREAS, in general, a Battery Energy Storage Systems ("BESS") facility collects energy from the grid, stores it, and then discharges that energy later to provide electricity or other grid services when needed, typically at times of high demand; and
WHEREAS, Escondido Energy Center, LLC ("Applicant") is proposing to construct a BESS facility on land currently owned by Escondido Energy Center, LLC located at 1968 Don Lee Place (Assessor’s Parcel No.: 228-381-74-00); and
WHEREAS, on February 7, 2024 , Applicant filed a land use development application (Planning Case No. PL24 -0037), constituting a request for Major Plot Plan to establish a 50-megawatt (MW) BESS facility comprised of 31 lithium-ion battery storage enclosures (“Project”). The proposed Project is located within the General Industrial (M -2) zoning designation. Article 26 of the Escondido Zoning Ordinance (Chapter 33 of the Escondido Municipal Code) permits for a wide -range of activities, including those considered “heavy” or “intensive” o utside storage needs, heavier equipment, and operational characteristics that require the least restrictive design standards. The General Industrial zoning 453
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designation specifically allows for power plants, oil refineries and bulk stations, transmission fac ilities, and uses involving hazardous chemicals and waste, all of which are similar in intensity of a BESS; and WHEREAS, a BESS within the General Industrial zone would be permitted via the Major Plot Plan review process as outlined and pursuant to Article 61 (Administration and Enforcement), Division 8 (Plot Plans) of Chapter 33 (Zoning) of the Escondido Municipal Code; and WHEREAS, the City's current Zoning Regulations do not contain criteria specifically for BESS facilities; and
WHEREAS, in 2022, the Governor signed into law Assembly Bill 205 ("AB 205"), which expands the California Energy Commission's ("CEC") powerplant siting authority, previously limited to thermal powerplants, to certain renewable energy facilities, including energy storage systems (as defined in Pub.
Util. Code section 2835) that are capable of storing 200 Megawatt-hours or more of electrical energy; and WHEREAS, pursuant to AB 205 (as codified at Pub. Res. Code Division 15, Chapter 6.2), an applicant proposing to build a qualifying energy facility may file an "opt in application for certification" at the CEC and the CEC's permitting authority over the proposed project is "in lieu of any permit, certificate, or similar document required by a state, local, or regional agency, or federal agency, to the extent permitted by federal law, for those facilities"; and
WHEREAS, in reviewing so-called opt-in projects, the CEC functions as the Lead Agency for purposes of California Environmental Quality Act ("CEQA") review. In certifying an opt-in project, the CEC must make certain findings; and
WHEREAS, whether or not an Applicant's proposed project requires local entitlement approvals, there remain significant public safety-related concerns that must be analyzed prior to any BESS project 454
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moving forward within Escondido, whether at the 1968 Don Lee Place site or elsewhere in the community; and
WHEREAS, there have been several recent fires at BESS facilities in and around the City as well as throughout California and nationwide. BESS facilities that use lithium-ion batteries create particularly unique fire and explosion hazards. Lithium -ion batteries are inherently safe and stable but certain conditions elevate the risk of fire such as impacts, puncture, or mechanical damage, overcharging, overheating, and short circuits. The site for the pending application is within 700 feet of established residential uses located with the County; and
WHEREAS, on August 28, 2024, the City Council adopted Resolution No. 2024 -113, which is incorporated herein as though set forth in full, outlining the Council’s concerns with the proliferation of BESS projects in and around the City of Escondido, including negative economic impacts inconsistent with the City’s adopted 2023 to 2028 Comprehensive E conomic Development Strategy and potential public health and safety risks associated with the ignition of fires, including “thermal runaways,” from these facilities; and
WHEREAS, on September 5, 2024, at approximately 12:09 p.m., the Escondido Fire Department responded to a fire at a 30 MW San Diego Gas and Electric (“SDG&E”) BESS facility located at 571 Enterprise Street within the City of Escondido (“Incident”). The Inci dent entailed an active fire of a Lithium-Ion battery bank used for the purposes of energy storage. Due to specific hazards resulting from the burning of Lithium -Ion batteries, the City deployed a defensive strategy focused on protecting adjacent structure s containing additional batteries and implemented evacuations of the surrounding area. Mandatory evacuations resulting from the Incident included an area approximately one square mile for approximately 48-hours. Certain Escondido Unified School District schools and facilities shut down as a result of the fire as well. Responders from the Escondido Fire Department and Police Departments, as 455
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well as the San Diego County Hazardous Materials Division, Health Departments, and SDG&E monitored the site, including water and air sampling for public health and safety; and WHEREAS, on October 7, 2023, the Governor of California signed into law Senate Bill 38 ("SB 38"), which amends California Public Utilities Code Section 761.3 to address safety concerns with BESS projects.
SB 38 requires every BESS facility in California to establish an emergency response and emergency action plan for the facility to protect surrounding residents, neighboring properties, emergency responders, and the environment. The BESS facility owner or operator must coordinate with local emergency management agencies, unified program agencies, and local first responders to develop the plan, and submit the plan to the county and the city where the facility is located; and WHEREAS, given the fairly new technology, lack of long -term study of the performance and risk associated with these facilities, as well as the ever -increasing megawatt capacity of these projects, the City of Escondido has not had an adequate o pportunity to undertake a comprehensive study of the developing technologies and designs such that it can publish appropriate development guidelines for these projects to ensure the public’s welfare and safety; and WHEREAS, California Government Code Section 65858 provides that, without following the procedures otherwise required prior to the adoption of a zoning ordinance, an urgency measure in the form of an interim ordinance may be adopted by a four-fifths vote of the City Council to protect the public from a current and immediate threat to the public health, safety, or welfare resulting from a contemplated zoning proposal; and
WHEREAS, Government Code Section 65868 further provides that such an urgency measure shall be effective for only 45 days following its adoption, but may be extended beyond the initial 45-day period, 456
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following compliance with that Section, for an additional 10 months and 15 days and subsequently for an additional 12 months; and
WHEREAS, at its October 9, 2024, City Council meeting, staff's findings demonstrated that the potential for development of new commercial BESS facilities within the City without adequate land use policies and standards in place to implement SB 38 and to prevent potentially catastrophic interference with nearby communities presents a current and immediate threat to the public's safety and welfare, and the approval of use permits, building permits, or other applicable entitlements for such uses would threaten public safety and welfare; and
WHEREAS, at its October 9, 2024 meeting, the City Council voted to approve an Interim Ordinance prohibiting new commercial battery energy storage systems within the City, unless a use permit was approved prior to October 9, 2024, based upon a need for the immediate pres ervation of the public health, safety, and welfare as set forth herein, for an initial period of forty -five days while City staff researched and selected the best recommended course of action to address the safety-related concerns regarding BESS facilities ("Urgency Ordinance No. 2024-12R"); and WHEREAS, the temporary prohibition on BESS facilities associated with Urgency Ordiannce No. 2024-12R was scheduled to expire on November 23, 2024; and WHEREAS, at its November 20, 2024 meeting, the City Council voted to approve Ordinance 2024- 14 which grants an extension of Urgency Ordinance 2024-12R for 10-months and 15-days; and WHEREAS, at its May 7, 2025 meeting, the City Council received a request for direction from City staff regarding next steps for BESS regulation development. The City Council provided direction, including to maintain Urgency Ordinance 2024-12R; and
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WHEREAS, Urgency Ordinance 2024-12R is set to expire on October 5, 2025, 10 -months and 15- days from the November 20, 2024 meeting; and
WHEREAS, City staff issued a written report to the City Council on the progress of its study along with measures taken to alleviate the condition that led to the adoption of Urgency Ordinance No. 2024 - 12R; and
WHEREAS, City staff is still in the process of conducting research to understand the impacts of BESS facilities and uses on community welfare and explore potential amendments to the City's Municipal Code and General Plan in relation to BESS facilities, including but not limited to review, evaluation, and comment on the San Diego County BESS Best Practices – Policy Recommendations for Battery Energy Storage Systems Projects Report which is being developed by the County; and WHEREAS, City staff remains concerned that the absence of adequate land use policies and standards to address BESS facilities, including those necessary to implement SB 38 and prevent potentially catastrophic impacts to nearby residents and environmental resources, poses a current and immediate threat to the public's safety and welfare; and
WHEREAS, in light of the significant safety risks associated with BESS facilities, City staff seeks additional time to further investigate these issues, formulate recommendations for City Council consideration, and explore adjustments to the City’s Fire Code to mitigate the safety risks associated with BESS facilities.
NOW, THEREFORE, the City Council of the City of Escondido does ordain as follows:
SECTION 1. The recitals above are each incorporated by reference and adopted as findings by the City Council.
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SECTION 2. This Interim Ordinance is not subject to the CEQA (Public Resources Code §21000, et seq.) pursuant to CEQA Guidelines (Cal. Code Regs., tit. 14, §15000 et seq.) Section 15060(c)(2) [activity will not result in a direct or reasonably foreseeable indirect physical change in the environment]. Here, this Interim Ordinance is merely extending the current prohibition on certain projects from proceeding for a period of time during which the City will study the potential development. As a result, this In terim Ordinance will not result in a direct or reasonably foreseeable indirect physical change in the environment. Further, the 10 -Day Report, attached to this Ordinance as Exhibit “A”, merely describes actions previously taken to alleviate the conditions which led to the adoption of Urgency Ordinance No. 2024-12R.
Alternatively, this Interim Ordinance is exempt from CEQA under CEQA Guidelines Sections 15061(b)(3) [it can be seen with certainty that there is no possibility the activity in question may have a significant effect on the environment], and, in the alternative, 15307 [Class 7 categorical exemption for regulatory activity to assure the protection of natural resources], and, in the alternative, 15308 [Class 8 categorical exemption for regulatory ac tivity to assure the protection of the environment]. Here, this Interim Ordinance will extend the current prohibition on certain projects from being able to proceed for a period of time during which the City will study the potential development. This activ ity is meant to assure the protection of the environment and natural resources by studying the hazards associated with BESS facilities, such as unique fire and explosion hazards, for potential development of zoning regulations for BESS facilities. Currentl y, there are no commercial BESS facilities in the city. This Project merely preserves the status quo. Further, the 10 -Day Report merely describes actions previously taken to alleviate the conditions which led to the adoption of Urgency Ordinance No. 2024-12R.
Alternatively, this Interim Ordinance is exempt from CEQA pursuant to Public Resources Code Section 21080(b)(4) and CEQA Guidelines Section 15269(c) because it prevents a clear and imminent 459
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danger that requires immediate action to prevent or mitigate t he loss of, or damage to, life, health, property, and essential public services. Here, this Interim Ordinance will extend the current prohibition on certain projects from being able to proceed for a period of time during which the City will study the potential development. This activity is meant to prevent or mitigate the loss of, or damage to, life, health, property, and essential public services by studying the hazards associated with BESS facilities, such as unique fire and explosion hazards, for potential development of zoning regulations for BESS facilities.
SECTION 3. This Interim Ordinance is urgently needed for the immediate preservation of the public health, safety, and welfare based on the findings of this Interim Ordinance and corresponding action report. This Interim Ordinance shall take effect immediately upon adoption.
SECTION 4. Urgency Ordinance No. 2024-12R is hereby extended for twelve months, unless earlier repealed by the City Council or extended in accordance with the provisions set fort h in California Government Code Section 65858.
SECTION 5. No use permit, variance, building permit, business license, or any other entitlement for use shall be approved or issued for the establishment, construction, or operation of a commercial BESS facility for any location or property within the City of Escondido, unless a use permit was approved prior to October 9, 2024, authorizing the establishment, construction, and operation of the commercial BESS facility, in which case the commercial BESS facility may continue in operation as approved but may not be replaced or modified in any manner that would require revision or amendment to the use permit under the City's Zoning Regulations. As used in this ordinance, the term "commercial" means the use of a BESS facility to provide electricity to third parties, for consideration. 460
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SECTION 6. The penalties for land use violations that are prescribed in Sections 33-1310 through 33-1313 of the Escondido Municipal Code shall apply to violations of the provisions of th is Interim Ordinance.
SECTION 7. If any provision of this ordinance or its application to any person or circumstance is held to be invalid, such invalidity has no effect on the other provisions or applications of the ordinance that can be given effect without the invalid provision or application, and to this extent, the provisions of this resolution are severable. The City Council declares that it would have adopted this resolution irrespective of the invalidity of any portion thereof.
SECTION 8. The City Council hereby directs staff to prepare, execute, and file with the County of San Diego Clerk a notice of exemption within five working days of the adoption of this Ordinance.
SECTION 9. This extension Ordinance is intended to supplement, not to duplicate o r contradict, applicable state and federal law and shall be interpreted in light of that intent.
SECTION 10. Unless further extended by City Council, this extension Ordinance shall remain in effect until close of business on October 5, 2026.
SECTION 11. SEPARABILITY. If any section, subsection sentence, clause, phrase or portion of this Ordinance is held invalid or unconstitutional for any reason by any court of competent jurisdiction, such portion shall be deemed a separate, distinct and independent provision and such holding shall not affect the validity of the remaining portions.
SECTION 12. Pursuant to Government Code Sections 36934 and 36937(b), this Ordinance shall be effective immediately upon its adoption.
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SECTION 13. The City Clerk is hereby directed to certify to the immediate passage of this Ordinance and to cause the same or a summary to be published one time within 15 days of its passage in a newspaper of general circulation for the City of Escondido.
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10-DAY REPORT REGARDI NG MEASURES TAKEN TO ALLEVIATE
CONDITIONS WHICH LED TO ADOPTION OF URGENCY ORDINANCE NO. 2024-12R ESTABLISHING A TEMPORARY PROHIBITION ON NEW
COMMERCIAL BATTERY ENERGY STORAGE SYSTEMS WITHIN THE CITY
OF ESCONDIDO
I. Background
At its October 9, 2024, meeting, the City Council of the City of Escondido ("City") adopted an urgency interim ordinance establishing a temporary prohibition on new commercial battery energy storage systems ("BESS") within the City's boundaries ("Urgency Ordinance No. 2024-12R"). More specifically, Urgency Ordinance No. 2024-12R prohibits any use permit, variance, building permit, business license, or any other entitlement for use from being approved or issued for the establishment, construction, or operation of a commercial BESS facility for any location or property within the City, unless a use permit was approved prior to October 9, 2024, authorizing the establishment, construction, and operation of the commercial BESS facility, in which case the commercial BESS facility could continue in operation as approved but cannot be replaced or modified in a manner that would require revision or amendment to the use permit under the City's Zoning Regulations.
An interim ordinance takes immediate effect upon adoption and expires forty- five days after adoption, unless extended at a later date after notice and a public hearing for up to an additional ten months and fifteen days, and subsequently for an additional twelve months. (Government Code Section 65868(a).) Urgency Ordinance No. 2024-12 took effect on October 9, 2024, and will expire on November 23, 2024. Government Code Section 65858(d) requires that at least ten days prior to the expiration of an interim ordinance or any extension, the City Council must issue a written report describing the measures taken to alleviate the condition(s) which led to the adoption of the ordinance.
II. Measures Taken Since the Adoption of the Interim Ordinance As City staff's findings demonstrate, Urgency Ordinance No. 2024-12R was enacted in order
to preserve public health, safety, and general welfare of City residents, firefighters, and
emergency responders during emergency
operations, based on, among other things
, the hazards of fire, explosion, or dangerous
conditions in new and existing BESS facilities and negative economic impacts inconsistent with the City’s adopted 2023 to 2028 Comprehensive Economic Development Strategy.
To alleviate the conditions that led to the adoption of Urgency Ordinance No. 2024-12R, the City
has taken the following steps since adoption:
1) City s taff have taken preliminary steps to study and consider the hazards associated with commercial BESS facilities, land use development policies, and standards relating to commercial BESS facilities to evaluate the potential development of such facilities within the City.
Ordinance No. 2025-06
Exhibit "A"
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2) In collaboration with the City Attorney's office, City staff have explored amendments to the City's G
eneral Plan and Zoning Regulations aimed at
enhancing public safety and mitigating the potentially catastrophic impacts of new commercial BESS facilities in th
e City and nearby communities in order
to accomplish t
he goals of Urgency Ordinanc e No. 2024-1 2R. This
includes
research into what other c ities in California are doing in order to enhance safety standards
and environmental safeguards regarding
commercial BESS facilities and identify effective legislative frameworks that could be adapted to local ne eds.
• City staff have found at least one city within the state has adopted an “Energy Storage Facility” or
dinance (City of Beaumont, Ordinance No.
1142), prohibiting energy storage facilities in all zones except their industrial zone; adopting definitions for jargon associated with BESS facilities; and adopting use standards for s
uch facilities; and
• City staff continue to review contemporary literature on BESS facilities as they relate to zoning ordinances, including but not limited to the U.S.
Department of Energy’s technical report Energy Storage in Local Zoning Ordinances dated October 2023.
(https://www.pnnl.gov/main/publications/external/technical_reports/ PNNL-
34462.pdf);
3) City
staff have engaged with interested parties likely to be affected by a commercial BESS facility prohibition
to collect their concerns and unique
insights that will guide the development of specific regulations and mitigation strategies addressing
both community safety and the impact of commercial
BESS facilities within the City of Escondido.
4) Recognizing the distinct safety risks associated with commercial BESS facilities, including but not limited to fire and environmental risks, City staff have taken preliminary steps toward an in-depth review of existing emergency response procedures to enhance emergency preparedness for potential incidents at these sites. Such steps include rev iew, evaluation, and comment on the San Diego County
BESS Best Practices – Policy Recommendations for
Battery Energy Storage Systems Projects which is currently being developed by the County. City staff have also taken preliminary steps toward identifying environmental sensitive
watercourses that could be impacted by BESS facility
proximity.
Ill. Conclusion
The City has not concluded its research and thus has not yet taken any action at this time regarding the form of any permanent regulations pertaining to the establishment or use of commercial BESS facilities. As a result, an extension of urgency Ordinance No. 2024-12R is recommended to allow the City the time to effectively study and consider land use development policies and standards related to commercial BESS facilities
that should be added to the City's General
Plan and Zoning Regulations.
- 2
Ordinance No. 2025-06
Exhibit "A"
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Attachment “1”
Prior Staff Reports
PLANNING CASE NO. PL24-0308
Due to the number of pages of Attachment “1”, links have been provided for review of the following items:
1. May 7, 2025 Staff Report
a. https://mccmeetings.blob.core.usgovcloudapi.net/escondidca-pubu/MEET- Packet-cebe365a4a2b4915810bfba3cdede537.pdf
2. November 20, 2024 Staff Report
a. https://mccmeetings.blob.core.usgovcloudapi.net/escondidca-pubu/MEET- Packet-6188ffd97a61404380295fb8b37f307c.pdf
3. October 9, 2024 Staff Report
a. https://mccmeetings.blob.core.usgovcloudapi.net/escondidca-pubu/MEET- Packet-1fe945b5e1eb427b9ef616d9261c6f25.pdf
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ORDINANCE NO. 2024-12R
AN INTERIM ORDINANCE OF THE CITY COUNCIL OF THE
CITY OF ESCONDIDO PROHIBITING NEW
COMMERCIAL BATTERY ENERGY STORAGE SYSTEMS
WITHIN THE CITY OF ESCONDIDO, ADOPTED AS AN
URGENCY MEASURE; AND FINDING THE ACTION TO
BE EXEMPT FROM CEQA
WHEREAS, the City of Escondido, California, (“City”) is a municipal corporation, duly organized under the constitution and laws of the State of California; and WHEREAS, in general, a Bat tery Energy Storage Systems ("BESS") facility collects energy from the grid, stores it, and then discharges that energy later to provide electricity or other grid services when needed, typically at times of high demand; and
WHEREAS, Escondido Energy Center, LLC ("Applicant") is proposing to construct a BESS facility on land currently owned by Escondido Energy Center, LLC located at 1968 Don Lee Place (Assessor’s Parcel No.: 228-381-74-00); and
WHEREAS, on February 7, 2024, Applicant filed a land use development application (Planning Case No. PL24-0037), constituting a request for Major Plot Plan to establish a 50-megawatt (MW) BESS facility comprised of 31 lithium-ion battery storage enclosures. The proposed project is located within the General Industrial (M-2) zoning designation. Article 26 of the Escondido Zoning Ordinance (Chapter 33 of the Escondido Municipal Code) permits for a wide-range of activities, including those considered “heavy” or “intensive” outside storage needs, heavier equipment, and operational characteristics that require the least restrictive design standards. The General Industrial zoning designation specifically allows for power plants, oil refineries and bulk stations, transmission facilities, and uses involvin g hazardous chemicals and waste, all of which are similar in intensity of a BESS; and Docusign Envelope ID: D7832190-E455-4693-9B86-4895595419DA Attachment "2"
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WHEREAS, a BESS within the General Industrial zone would be permitted via the Major Plot Plan review process as outlined and pursuant to Article 61 (Administration and Enforcement), Division 8 (Plot Plans) of Chapter 33 (Zoning) of the Escondido Municipal Code; and WHEREAS, the City's current Zoning Regulations do not contain criteria specifically for BESS facilities; and
WHEREAS, in 2022, the Governor signed into law Assembly Bill 205 ("AB 205"), which expands the California Energy Commission's ("CEC") powerplant siting authority previously limited to thermal powerplants-to certain renewable energy facilities, including energy storage systems (as defined in Pub. Util. Code section 2835) that are capable of storing 200 Megawatt -hours or more of electrical energy; and
WHEREAS, pursuant to AB 205 (as codified at Pub. Res. Code Division 15, Chapter 6.2), an applicant proposing to build a qualifying energy facility may file an "opt in application for certification" at the CEC and the CEC's permitting authority over the proposed project is "in lieu of any permit, certificate, or similar document required by a state, local, or regional agency, or federal agency, to the extent permitted by federal law, for those facilities"; and WHEREAS, in reviewing so-called opt-in projects, the CEC functions as the Lead Agency for purposes of California Environmental Quality Act ("CEQA") review. In certifying an opt-in project, the CEC must make certain findings; and
WHEREAS, whether or not an Applicant's proposed project requires local entitlement approvals, there remain significant public safety-related concerns that must be analyzed prior to any BESS project moving forward within Escondido, whether at the 1968 Don Lee Place site or elsewhere in the community; and
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WHEREAS, there have been several recent fires at BESS facilities in and around the City as well as throughout California and nationwide. BESS facilities that use lithium-ion batteries create particularly unique fire and explosion hazards. Lithium-ion batteries are considered inherently safe and stable but certain conditions elevate the risk of fire such as impacts, puncture, or mechanical damage, overcharging, overheating, and short circuits. The site for the pending application is within 700 feet of established residential uses located with the County; and WHEREAS, on August 28, 2024, the City Counc il adopted Resolution No. 2024 -113, which is incorporated herein as though set forth in full, outlining the Council’s concerns with the proliferation of BESS projects in and around the City of Escondido, includ ing negative economic impacts inconsistent with the City’s adopted 2023 to 2028 Comprehensive Economic Development Strategy and potential public health and safety risks associated with the ignition of fires , including “thermal runaways,” from these facilities; and
WHEREAS, on September 5, 2024 , at appr oximately 12:09 p.m., the Escondido Fire Department responded to a fire at a 30 MW San Diego Gas and Electric (“SDG&E”) BESS facility located at 571 Enterprise Street within the City of Escondido (“incident”). The incident entailed an active fire of a Lithium -Ion battery bank used for the purposes of energy storage. Due to specific hazards resulting from the burning of Lithium -Ion batteries, the City deployed a defensive strategy focused on protecting adjacent structures containing addi tional batteries and implemented evacuations of the surrounding area. Mandatory evacuations resulting from the incident included an area approximately one square mile for approximately 48 -hours. Certain Escondido Unified School District schools and facilities shut down as a result of the fire as well. Responders from the Escondido Fire Department and Police Departments, as well as the San Diego County Hazardous Materials Division, Health Departments, and SDG&E monitored the site, including water and air s ampling for Docusign Envelope ID: D7832190-E455-4693-9B86-4895595419DA Attachment "2"
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public health and safety; and
WHEREAS, on October 7, 2023, the Governor of California signed into law Senate Bill 38 ("SB 38"), which amends California Public Utilities Code Section 761.3 to address safety concerns with BESS projects.
SB 38 requires every BESS facility in California to establish an emergency response and emergency action plan for the facility to protect surrounding residents, neighboring properties, emergency responders, and t he environment. The BESS facility owner or operator must coordinate with local emergency management agencies, unified program agencies, and local first responders to develop the plan, and submit the plan to the county and the city where the facility is located; and WHEREAS, given the fairly new technology, lack of long -term study of the performance and risk associated with these facilities, as well as the ever-increasing megawatt capacity of these projects, the City of Escondido has not had an adequate opportunity to undertake a comprehensive study of the developing technologies and designs such that it can publish appropriate development guidelines for these projects to ensure the public’s welfare and safety; and WHEREAS, California Government Code Section 65858 provides that, without following the procedures otherwise required prior to the adoption of a zoning ordinance, an urgency measure in the form of an interim ordinance may be adopted by a four-fifths vote of the City Council to protect the public from a current and immediate threat to the public health, safety, or welfare resulting from a contemplated zoning proposal. Government Code Section 65868 further provides that such an urgency measure shall be effective for only 45 days following its adoption, but may be extended beyond the initial 45-day period, following compliance with that Section, for an additional 10 months and 15 days and subsequently for an additional 12 months; and
WHEREAS, the potential for development of new commercial BESS facilities within the City of Docusign Envelope ID: D7832190-E455-4693-9B86-4895595419DA Attachment "2"
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Escondido without adequate land use policies and standards in place to implement SB 38 and to prevent potentially catastrophic interference with nearby communities presents a current and immediate threat to the public's safety and welfare, and the approval of use permits, building permits, or other applicable entitlements for such uses would result in that threat to public safety and welfare; and
WHEREAS, while this interim ordinance is in effect, the City intends to study and consider land use development policies and standards related to BESS facilities that should be added to the City's General Plan and Zoning Regulations and minimum workforce standards and develop an emergency response plan; and
WHEREAS, the City Council has the authority under Government Code Sections 36934 and 36937(b) to adopt an ordinance that takes effect immediately if it is an ordinance for the immediate preservation of the public peace, health or safety, contains a declaration of the facts constituting the urgency, and is passed by a four-fifths vote of the City Council; and WHEREAS, the City finds it is necessary for the City Council to adopt this Interim Ordinance as an Urgency Ordinance, as set forth in the above recitals, which are incorporated herein by reference, and pursuant to the powers under Government Co de Sections 36934 and 36937 (b), for the immediate preservation of the public health and safety.
NOW, THEREFORE, t he City Council of the City of Escondido, California, DOES HEREBY ORDAIN as follows:
SECTION 1. The recitals above are each incorporated by reference and adopted as findings by the City Council.
SECTION 2. This Interim Ordinance is not subject to CEQA (Public Resources Code §21000, et seq.) pursuant to CEQA Guidelines (Cal. Code Regs., tit. 14, §15000 et seq.) Section 15060(c)(2) as the Docusign Envelope ID: D7832190-E455-4693-9B86-4895595419DA Attachment "2"
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activity will not result in a direct or reasonably foreseeable indirect physical change in the environment. Here, the Interim Ordinance will prohibit certain projects from proceeding for a period of time during which the City will study the potential development. As a result, this Interim Ordinance will not result in a direct or reasonably foreseeable indirect physical change in the environment.
Alternatively, this Interim Ordinance is exempt from CEQA pursuant to Public Resources Code Section 21080(b)(4) and CEQA Guidelines Section 15269(c) because it prevents a clear and imminent danger that requires immediate action to prevent or mitigate the loss of, or damage to, life, health, property, and essential public services. Here, the Interim Ordinance will prohibit certain projects from proceeding for a period of time during which the City will study the potential development. This activity is meant to prevent or mitigate the loss of, or damage to, life, health, property, and essential public services by studying the hazards associated with BESS facilities, such as unique fire and explosion hazards, for potential development of zoning regulations for BESS facilities.
SECTION 3. From and after the date of enactment of the Interim Ordinance, no use permit, variance, building permit, business license, or any other entitlement for use shall be approved or issued for the establishment, construction, or operation of a commercial BESS facility for any location or property within the City of Escondido, unless a use permit was approved prior to October 9, 2024, authorizing the establishment, construction, and operation of the commercial BESS facility, in which case the commercial BESS facility may continue in operation as approved but may not be replaced or modified in any manner that would require revision or amendment to the use permit under the City's Zoning Regulations. As used in this Interim Ordinance, the term "commercial" means the use of a BESS facility to provide electricity to third parties, for consideration.
SECTION 4. This Interim Ordinance is urgently needed for the immediate preservation of the public health, safety, and welfare based on the findings herein. It shall take effect immediately upon Docusign Envelope ID: D7832190-E455-4693-9B86-4895595419DA Attachment "2"
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adoption and shall be of no further force and effect 45 days following the date of its adoption, unless earlier repealed by the City Council or extended in accordance with the provisions set forth in California Government Code Section 65858.
SECTION 5. The penalties for land use violations that are prescribed in Sections 33-1310 through 33-1313 of the Municipal Code shall apply to violations of the provisions of this Interim Ordinance.
SECTION 6. If any provision of this Interim Ordinance or its application to any person or circumstance is held to be invalid, such invalidity has no effect on the other provisions or applications of the Interim Ordinance that can be given effect without the invalid provision or application, and to this extent, the provisions of this ordinance are severable. The City Council declares that it would have adopted this resolution irrespective of the invalidity of any portion thereof.
SECTION 7. The City Council hereby directs staff to prepare, execute, and file with the County of San Diego Clerk a Notice of Exemption within five (5) working days of the adoption of this Interim Ordinance.
SECTION 8. This Interim Ordinance is intended to supplement, not to duplicate or contradict, applicable state and federal law and shall be interpreted in light of that intent.
SECTION 9. Unless extended by City Council, this Interim Ordinance shall remain in effect until close of business on November 23, 2024.
SECTION 10. SEPARABILITY. If any section, subsection sentence, clause, phrase or portion of this Ordinance is held invalid or unconstitutional for any reason by any court of competent jurisdiction, such portion shall be deemed a separate, distinct and independent provision and such holding shall not affect the validity of the remaining portions.
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SECTION 11. Pursuant to Government Code Section s 36934 and 36937(b), this Ordinance shall be effective immediately upon its adoption.
SECTION 12. The City Clerk is hereby directed to certify to the immediate passage of this Interim Ordinance and to cause the same or a summary to be published one time within 15 days of its passage in a newspaper of general circulation for the City of Escondido.
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PASSED, ADOPTED AND APPROVED by the City Council of the City of Escondido at a regular meeting thereof this 9th day of October, 2024 by the following vote to wit:
AYES : Councilmembers: C. GARCIA, J. GARCIA, MARTINEZ, MORASCO, WHITE NOES : Councilmembers: NONE
ABSENT : Councilmembers: NONE
APPROVED:
DANE WHITE, Mayor of the
City of Escondido, California
ATTEST:
ZACK BECK, City Clerk of the
City of Escondido, California
*****
STATE OF CALIFORNIA )
COUNTY OF SAN DIEGO : ss.
CITY OF ESCONDIDO )
I, Zack Beck, City Clerk of the City of Escondido, hereby certify that the foregoing ORDINANCE NO. 2024-12R passed at a regular meeting of the City Council of the City of Escondido held on the 9th day of October, 2024.
ZACK BECK, City Clerk of the
City of Escondido, California
ORDINANCE NO. 2024-12R
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KEY-
CONSENT CALENDAR CURRENT BUSINESS
PUBLIC HEARING WORKSHOP PROCLAMATION
10/8/2025 - NO MEETING
10/15/2025
PROCLAMATION: Fire Prevention Awareness Week
PROCLAMATION: Manufacturing Month 2025
CONSENT CALENDAR - (C. MCKINNEY) - AWARD CONTRACT FOR CONSTRUCTION OF PICKLEBALL COURTS AT MOUNTAIN VIEW PARK CONSENT CALENDAR - (C. MCKINNEY) - BID AWARD FOR THE CLEAN CA ENTRY MONUMENT SIGN PROJECT CONSENT CALENDAR - (J.PERPETUA) - 2026 HOLIDAY SCHEDULE - It is requested that City Council adopt Resolution No. 25-114, the 2026 City Recognized Holidays.
CONSENT CALENDAR - (R. VAN DE HEY) - MASTER SERVICE AGREEMENT WITH AZTECA SYSTEMS, LLC, FOR THE PURCHASE OF THE CITYWORKS SOFTWARE, AND SERVICE AND SUPPORT.
CONSENT CALENDAR - (K. MORGAN) - CONTINUING REPAIR OF THE EMERGENCY REPAIR OF THE ESCONDIDO TRUNK SEWER MAIN - Request the City Council adopt Resolution No. 2025-127 declaring that pursuant to the terms of Section 22050 of the California Public Contract Code, the City Council finds there is a need to continue the emergency repair of the Escondido Trunk Sewer Main. The resolution, which must be passed by four-fifths vote, also declares that public interest and necessity demand the immediate expenditure to safeguard life, health, or property.
CONSENT CALENDAR - (C. MCKINNEY) - AWARD CONTRACT TO ESCONDIDO EDUCATION COMPACT FOR RENTAL & UTILITY ASSISTANCE PROGRAM- it is requested that the City Council adopt Resolution No. 25-128 authorizing the Mayor, on behalf of the City, to execute a subrecipient agreement with Escondido Education COMPACT, in the amount of $1,660,000 in Community Development Block Grant CARES Act funding, for rental and utility assistance.
PUBLIC HEARING - (C. MCKINNEY) - PL23-0129 - ISKCON OF ESCONDIDO KRISHNA TEMPLE AND RESIDENTIAL SUBDIVISION CURRENT BUSINESS - (C. MCKINNEY) - HOME UPDATE
CURRENT BUSINESS - (C. MCKINNEY) - AWARD CONTRACT FOR DESIGN SERVICES TO SCHMIDT DESIGN GROUP FOR RYAN PARK ADDITIONAL BALLFIELDS,
LIGHTING, AND PARKING LOT DESIGN
CURRENT BUSINESS - (C. MCKINNEY) - LEGISLATIVE REVIEW OF ASSEMBLY BILL 130 AND SENATE BILL 131 CURRENT BUSINESS - (J. TENGER) - ADOPTION OF THE UPDATED 2025 COMMUNITY WILDFIRE PREVENTION PLAN - It is requested the City Council approve Resolution 25-112 adopting the updated Community Wildfire Prevention Plan.
CURRENT BUSINESS - (J. SCHOENECK) - ECONOMIC DEVELOPMENT DEPARTMENT COMPREHENSIVE ECONOMIC DEVELOPMENT STRATEGY (CEDS) UPDATE CURRENT BUSINESS - (C. HOLMES) - FISCAL YEAR 2024/25 FINANCIAL STATUS REPORT AND BUDGET ADJUSTMENT REQUEST – Request the City Council receive and file the financial report for FY2024/25 and adopt budget adjustments to amend the FY2025/26 operating budget.
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