Agenda packet — Escondido City Council, June 10, 2026 (part 2 of 10)

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Item7.

Development Standards - Storm Properties West Valley Parkway Master Plan _____________________________________________________________________________________ City of Escondido Storm Properties West Valley Parkway Master Plan August 2025 Page 6

2.2 DEVELOPMENT STANDARDS
All development standards for this Master Plan are referenced from Figure III-5 of the Downtown Specific Plan. These standards shall govern all development proposed within the Master Plan area.

Table 2 Development Standards
Standard Requirement Additional Information
Maximum Building Heights
and Stories
60’ (up to 4 stories) west of NCTD Rail
line; elsewhere up to 75’ (up to 5
stories)
See Figure III-6 of the Downtown
Specific Plan
Minimum lot Frontage 50’
Front Setback
At right of way or 14’ from ultimate
street curb face, whichever is greater
(Surface Parking and Signs: 5’ from
property line)
Interior Side Setback None (Surface Parking and Signs: 5’ from property line)
Street Side Setback
At right of way or 14’ from ultimate
street curb face, whichever is greater
(Surface Parking and Signs: 5’ from
property line)
Rear Setback None (Surface Parking and Signs: 5’
from property line)
Minimum Lot Size None
Maximum Bldg. Coverage None
Ordinance No. 2026-12
Exhibit "C"

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164
Item7.

Design Guidelines
City of Escondido Storm Properties West Valley Parkway Master Plan August 2025 Page 6
3 DESIGN GUIDELINES
The design guidelines contained herein are meant to conform to and supplement the development standards and design guidelines outlined in the Downtown Specific Plan. The design standards and regulations will help ensure the Plan area is a high-quality project designed to complement and enhance the neighborhood. To create successful communities, project design must embody methods which are flexible enough to meet the changing needs of the consumer market yet must also be visually pleasing products complementary to the surrounding community. For those reasons, the proposed architectural style has been presented for inclusion in the Storm Properties West Valley Parkway Planned Development Area and was chosen based on its historic popularity with homeowners in California and compatibility with the Downtown Specific Plan’s design guidelines as well as the Mercado District’s Overlay Plan.

The following overview offers a brief description of the look and feel for the Storm Properties West Valley Parkway Planned Development architectural style, which could be offered within the Plan area.

3.1 ARCHITECTURAL DESIGN & MATERIALS
As mentioned above, the Modern Spanish/Santa Barbara styles chosen for the property was based on designs popular with homeowners and which has roots in the historic design throughout southern California. The project also incorporates elements from the Mercado Overlay Plan’s “California” architecture theme into the project design. Notable Design features of this style should include the following:
• Predominant gable roof massing with some shed roofing. • Gable end diamond shape faux vent recesses.
• Decorative stucco finial/faux chimneys.
• Decorative stucco shaped eave details.
• Exposed wood truss tails with 2x3 fascia boards.
• 2” recessed ceramic tile surround at entry openings.
• Recessed windows.
• Decorative sloped stucco sills in select locations.
• Decorative stucco pop outs at selected locations.
• Modern “Irving Gill” awnings.
• Decorative stucco shaped corbels at cantilevers.
• Wood (or simulated) trim at bay windows.
• Decorative Spanish paver capped shelves.
• Decorative horizontal metal railings & stucco/metal scupper at decks.

3.2 COLORS
Building color is the unifying component of structures, which creates a sense of variation for the streetscape and builds upon the foundation of the community aesthetic. The design themes utilized Ordinance No. 2026-12
Exhibit "C"

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Item7.

Figure 2 Color Scheme and Bldg. Details
Ordinance No. 2026-12
Exhibit "C"

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Item7.

3.3 LANDSCAPING
Landscaping and hardscaping for the Plan area encapsulates approximately 37,560 SF (0.86-acres) or approximately 25% of the total project area. Landscape categories include common landscape area, onsite pathways, plazas, and private patio spaces. Planting area accounts for approximately 20,200 SF, onsite pathways and plazas total 9,260 SF, and private patio space totals approximately 8,100 Sf. Landscaping should be designed to complement the architecture and should be maintained in a healthy manner. The landscape palette is below for reference.

Figure 3 Plant Palette

3.4 OPEN SPACE
The open space component of the Storm Properties West Valley Parkway development provides recreational amenities, private patio and/or deck space, and landscaping to enhance the living experience for residents and visitors. The inclusion of these guidelines will contribute to a wellbalanced community and ensure open space is designed and implemented in an orderly manner. A noise study was conducted along Centre City Parkway as well as West Valley Parkway and determined that several private patios and recreational open space areas exceeded the City’s noise thresholds. However, provisions within the City’s General Plan allow for City staff to make determinations that some noise impacts to specific areas would be minimal when considering construction elements that were included in the project design. Staff may also reduce the total SF Ordinance No. 2026-12
Exhibit "C"

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167
Item7.

Design Guidelines - Storm Properties West Valley Parkway Master Plan _____________________________________________________________________________________ City of Escondido Storm Properties West Valley Parkway Master Plan August 2025 Page 9
required by the Escondido Municipal code through implementation of a Planned Development and a Master Plan. In this case solid 42” inch stucco walls were incorporated into the private patio open space areas for safety reasons providing benefits to residents that supersede potential noise impacts and providing a public benefit allowing for the reduction in required open space. The remaining areas affected by noise impacts resulted in a loss of approximately 2,536 SF of usable open space areas at the southeast corner of the Planned Development. The resulting “usable” open space now totals 28,200 SF which calculates to approximately 300 SF per dwelling unit. It should be noted that the impacted recreational open space areas at the southeast corner of the project, while not able to be counted toward the “usable” open space total for the project, are still incorporated into the project design, include a solid 42” stucco wall, and are still able to be used by residents but would have less than optimal noise impacts.

3.5 MASSING AND SCALE
Massing and scale provide the visual identity between residential dwelling units and the environment. Those qualities help dictate the placement, size, and form for residential structures within the planning area. As best as possible, building units should be placed to achieve variation in floor plans on each residential street and where they create articulation to avoid a repetitious row of homes along the street view. Incorporation of the following design concepts should be considered for the architecture within the Specific Plan Area:
• Maximum building height shall be 75’.
• Utilize building form elements such as place breaks, roof forms, and changes in materials to articulate individual dwelling units.
• Vertically and horizontally articulate building design for both front and rear elevations. • Avoid long unbroken surfaces on front and rear elevations by providing a change in planes.

3.6 WALLS AND FENCES
Walls, fences, and monuments within the Specific Plan Area are functional boundaries framing outdoor spaces and complementary pieces of landscape design and serve many other purposes. The review of walls and fences shall be an integral part of any site plan, permit, or Site Development Plan review application. Compliance with all wall and fence regulations contained herein shall be required unless otherwise approved by the Planning Director.
• Walls, fences, and monuments may be used to create partitions between private open space, screen the development from roadways, reduce noise from roadways, and enhance the site design.
• Development within the planning areas shall be designed to minimize walls and fences where possible, to support an open community.

Ordinance No. 2026-12
Exhibit "C"

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Item7.

3.6.1 Signage and Monument Design
A monument may be included at the project entry on West Valley Parkway as part of the enhanced project entry features. All signage shall conform with the Downtown Specific Plan and where the Specific Plan is silent Article 66 of the Escondido Zoning Code.
• Building directories are required per applicable building and fire codes. • Monument location must not interfere with line of sight. • One free-standing monument may be allowed at the main entrance on West Valley Parkway.
• Walls or fences up to 42” in height are permitted within the required setbacks to West Valley Parkway.
• Where necessary, design features such as glass partitions or other similar materials may be allowed in areas which may require noise abatement. All other walls and fences shall not exceed six (6) feet in height except a combination wallfence. Decorative pilasters may exceed the maximum height by one (1) foot and shall have a maximum of 50’ of separation. Taller walls or fences for sound attenuation may be allowed upon review and approval of the Planning Director. • Walls, fences, and architectural screening elements shall be compatible with the architectural treatments of the site buildings.
• Onsite walls and walls along Centre City Drive and West Valley Parkway shall be stucco and similar in appearance to the color scheme incorporated in the building color palette.
• Lighting such as bollards or sconces shall be incorporated into the walls along West Valley Parkway and shall act as pedestrian lighting along the that section of frontage.
• No wall, fence, or landscape element shall interfere with intersection visibility, line of sight, or other safety issues.
o Blank walls are prohibited. Where screening or security walls (excluding tubular steel or other “open” fence types) are located within ten (10) feet of public right-of-way, landscaping shall be provided between the wall and the right-of-way to a minimum height of four (4) feet to minimize opportunities for crime and unsafe conditions.
o Approved wall and fence materials include masonry, brick, block with shot blast texture or stucco to match architecture, and tubular steel. Comparable materials are permitted to be subject to approval by the Planning Director. o Tubular steel fencing selected for the area adjacent to the Escondido Creek Trail shall match as close as possible the tubular steel fencing approved by Public Works for adjacent areas.
o Prohibited materials include barbed wire, razor wire, concertina, corrugated metal and plastic, tarps, and electrified wire of any kind or configuration. o All retaining walls are subject to the City of Escondido Municipal Code and Engineering Standards.

Ordinance No. 2026-12
Exhibit "C"

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169
Item7.

Design Guidelines - Storm Properties West Valley Parkway Master Plan _____________________________________________________________________________________ City of Escondido Storm Properties West Valley Parkway Master Plan August 2025 Page 11
• A freestanding monument may have a maximum area of 20 SF and a maximum height of six (6) feet without Planning Commission approval. That area may be increased to 60 SF and up to 20’ in height with Planning Commission approval. • If included, a monument shall be constructed of similar materials and colors as the residential buildings.
• Monument signs shall encroach no more than within five (5) feet of property line adjacent to the street, or as required in the Gateway Transit District, whichever is less. Signs should not create traffic hazards at driveways or corners.
• A monument sign with a solid base shall have a depth of at least 15 inches between its two faces.
• Monument signs shall have a solid base rather than pole supports. • The text, or sign copy, of the monument sign should be limited to the name of the project and the street address.
• Monument signs should be surrounded by two (2) feet of landscaping or landscape planter area measured in all directions.
• The monument sign may have individually illuminated channel letters, or solid individual letters that are back-lit (halo lit). External and indirect lighting, consistent with the Outdoor Lighting Ordinance, is permitted in lieu of individually illuminated letters.

Ordinance No. 2026-12
Exhibit "C"

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EXHIBIT "D"

PROJECT PLANS
PLANNING CASE NOS. PL25-0096/PL25-0097/PL25-0098/PL25-0099 Ordinance No. 2026-12
Exhibit "D"

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171
Item7.

Architecture + Planning
888.456.5849
ktgy.com

CENTRE CITY AND VALLEY
ESCONDIDO, CA # 20240308
ESCONDIDO SITE STORM PROPERTIES, INC. 970 W. 190TH ST., SU. 995 Torrance, CA 90502
Prelim App Updated: 2024-06-19Prelim App Date: 2024-03-18Plot Date:1st Planning Submittal: 2025-03-13 2026-03-12
PL25-0096, Master PlanPL25-0097, Precise PlanPL25-0098, Tentative Subdivision MapPL25-0099, Design Review 2nd Planning Submittal: 2025-08-21 3rd Planning Submittal: 2025-12-17
A0.1 SHEET INDEX
Ordinance No. 2026-12
Exhibit "D"

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Page 22 of 64 ends

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Attachment “1”
CITY of ESCONDIDO
Planning Commission Minutes

May 12, 2026 at 7:00 PM
Council Chambers: 201 North Broadway, Escondido, CA 92025

WELCOME TO YOUR COMMISSION MEETING
We welcome your interest and involvement in the legislative process of Escondido. This agenda includes information about topics coming before the Commission.

CHAIR
Barry Speer

VICE CHAIR
Dustin Steeve

COMMISSIONERS
Marc Correll
Corey Gustafson
Jeff Jester
Carrie Mecaro
Stan Weiler

MINUTES CLERK
Angel Estrada

HOW TO WATCH
The City of Escondido provides one way to watch the Planning Commission meeting:

In Person
201 N. Broadway, Escondido, CA 92025
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ATTACHMENT “1”
CITY of ESCONDIDO
Planning Commission Minutes
Tuesday, May 12, 2026

MINUTES
CALL TO ORDER: 7:00 p.m.

FLAG SALUTE: Chair Speer.

ROLL CALL:

Commissioners Present: Barry Speer, Chair; Dustin Steeve, Vice-Chair; Stan Weiler, Commissioner; Carrie Mecaro, Commissioner; Corey Gustafson, Commissioner.

Commissioners Absent: Jeff Jester, Commissioner; Marc Correll, Commissioner.

City Staff Present: Veronica Morones, Assistant Director of Development Services; Owen Tunnell, Assistant City Engineer; Dare DeLano, Assistant City Attorney; Alex Rangel, Associate Planner; Angel Estrada, Minutes Clerk.

APPROVAL OF MINUTES:

1. April 28, 2026 Meeting Minutes.

Motion to approve meeting minutes.

Motion: Stan Weiler, Commissioner; Second: Dustin Steeve, Vice-Chair.

Motion carried 4-0-1 to approve the meeting minutes.

Ayes: Speer, Steeve, Weiler, Gustafson.

Nays: None.

Abstain: Mecaro.

Absent: Jester, Correll.

WRITTEN-COMMUNICATIONS:

None.

ORAL COMMUNICATIONS:

None.

PUBLIC HEARINGS:

2. PL25-0096/PL25-0097/PL25-0098/PL25-0099: VALLEY PARKWAY & CENTRE CITY PARKWAY 94-UNIT

CONDOMINIUMS
REQUEST: Recommend to the City Council approval of a Tentative Subdivision Map, Planned Development 236
Item7.

ATTACHMENT “1”
CITY of ESCONDIDO
Planning Commission Minutes
Tuesday, May 12, 2026
Permit (Master and Precise), and Design Review Permit to allow the construction of 94 dwelling units(“Project”) on a site with a Downtown Specific Plan (SPA-9) General Plan land use designation and Specific Plan (S-P) zoning designation. The proposed Project includes a Tentative Subdivision Map to merge two lots into one and for the subdivision of air space for 94 “for-sale” condominium units. A Planned Development Permit consisting of a Master and Precise Plan to allow ground-floor residential units within the Downtown Specific Plan area. A Design Review Permit to construct, and for the design of, the multifamily dwelling buildings. The Project also includes necessary on- and off-site improvements, including the demolition of approximately 13,100 square-feet of existing commercial tenant buildings and 30,600 square-feet of self-storage warehouse buildings, as well as appurtenant grading, landscaping, open space, and public street and sidewalk improvements.

APPLICANT: Storm Properties, Inc.

CEQA RECOMMENDATION: Categorical Exemption – CEQA Guidelines Section 15332 (In-Fill Development Projects)
STAFF RECOMMENDATION: Recommend approval to the City Council COMMISSION DISCUSSION:

Commissioner Weiler disclosed that he drove through and briefly walked around the project site and also had a brief discussion with one of the applicant’s representatives.

The Commission discussed the project in detail, with discussion topics including the project’s “missing middle” ownership housing concept and proximity to transit and downtown amenities, the overall architectural design and visual character of the development, opportunities for enhanced façade articulation and color variation, incorporation of additional architectural treatments and roof overhangs, landscaping considerations along Center City Parkway, guest parking management and HOA enforcement, housing density considerations within the Downtown Specific Plan, and potential design review procedures prior to building permit issuance. Brief discussion also occurred with Jay Ahluwalia, President of Storm Properties, Inc., and Jason Simmons with Consultants Collaborative regarding the project vision, higherdensity ownership housing, and long-term residential opportunities within the downtown area.

COMMISSION ACTION:

Motion to Approve Resolution No. 2026-04 as designed with subsequent staff design review before building permit issuance.

Motion: Stan Weiler, Commissioner; Second: Dustin Steeve, Vice-Chair.

Motion Carried 5-0 to approve the resolution.

Ayes: Speer, Steeve, Weiler, Mecaro, Gustafson.

Nays: None.

Abstain: None.

Absent: Jester, Correll.
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ATTACHMENT “1”
CITY of ESCONDIDO
Planning Commission Minutes
Tuesday, May 12, 2026
CURRENT BUSINESS:

None.

ORAL COMMUNICATIONS:

None.

PLANNING COMMISSIONERS:

None.

CITY PLANNER'S REPORT:

Veronica Morones, Assistant Director of Development Services, introduced newly hired City Planner Garrett Smith, who would also be taking over the role of Secretary to the Commission, and announced that the May 26, 2026 Planning Commission meeting would include continued discussion of the Accessory Dwelling Unit Ordinance.

Morones also noted that commissioner briefings for the item were underway and advised that both June Planning Commission meetings were anticipated to occur as scheduled.

ADJOURNMENT
Chair Speer adjourned the meeting at 8:30 p.m.
_______________________________ ______________________________ Veronica Morones, Secretary to the Escondido Angel Estrada, Minutes Clerk Planning Commission
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STAFF REPORT
DATE: May 12, 2026
PL25-0096/PL25-0097/PL25-0098/PL25-0099
PROJECT NUMBER / NAME: PL25-0096/PL25-0097/PL25-0098/PL25-0099: VALLEY PARKWAY & CENTRE CITY PARKWAY 94-UNIT CONDOMINIUMS
REQUEST: Recommend to the City Council approval of a Tentative Subdivision Map, Planned Development Permit with a Downtown Specific Plan (SPA-9) General Plan land use designation and Specific Plan (S-P) zoning designation.

The proposed Project includes a Tentative Subdivision Map to merge two lots into one and for the subdivision of air - ermit consisting of a Master and Precise Plan to allow ground-floor residential units within the Downtown Specific Plan area. A Design Review Permit to construct, and for the design of, the multi-family dwelling buildings. The Project also includes necessary on- and off-site improvements, including the demolition of approximately 13,100 square-feet of existing commercial tenant buildings and 30,600 square-feet of self-storage warehouse buildings, as well as appurtenant grading, landscaping, open space, and public street and sidewalk improvements.

PROPERTY SIZE AND LOCATION: The 3.51-acre Project site
is located on the north side of W. Valley Parkway and the west side of Centre City Parkway, and is addressed at 510 and 520 W. Valley Parkway
229-331-17-00 & 229-331-16-00)
APPLICANT: Storm Properties, Inc.

GENERAL PLAN / ZONING: Downtown Specific Plan (SPA9)
/ Specific Plan Area (S-P)
PRIMARY REPRESENTATIVE: Storm Bird (Storm Properties, Inc.) DISCRETIONARY ACTIONS REQUESTED: Master Development Plan, Precise Development Plan, Tentative Subdivision Map, and Design Review Permit
PREVIOUS ACTIONS: N/A
CEQA RECOMMENDATION: Categorical Exemption CEQA Guidelines Section 15332 (In-Fill Development Projects) STAFF RECOMMENDATION: Recommend approval to the City Council REQUESTED ACTION: Approve Planning Commission Resolution No. 2026-04 CITY COUNCIL HEARING REQUIRED: _X_YES ___NO
(Master and Precise), and Design Review Permit to allow the construction of 94 dwelling units ("Project") on a site space for 94 "for sale" condominium units. A Planned Development P (Assessor's Parcel Number(s):
□
Attachment "2"
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REPORT APPROVALS: Kevin Snyder, Director of Development Services X Veronica Morones, Assistant Director of Development Services CITY 0 f ESCONDIDO

STAFF REPORT
□
Attachment "2"
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BACKGROUND
The Project site is located on the north side of W. Valley Parkway and the west side of Centre City Parkway, and is addressed at 510 and 520 W. Valley Parkway. The Project site is located within Specific Planning Area 9 (Downtown -P) (Attachment 1 - Aerial,
General Plan, and Zoning). The Project site is within the Gateway Transit land use district of the DSP, intended to accommodate employee-intensive commercial and professional services, and high-density residential uses that . The Project site is currently occupied
by an approximately 5,900-square-foot retail building, an approximately 7,180-square-foot multi-tenant commercial building, and four self-storage warehouse buildings totaling approximately 30,600 square feet. All existing structures would be demolished as part of the Project. The Project site is surrounded by a mix of uses, as detailed in Table 1.

Table 1: Surrounding Land Uses
Direction General Plan/Zoning Existing Land Uses
North Light Industrial (LI)/Light Industrial (M-1) Escondido Creek and Trail, and Escondido Fire Station 1 & Training Area
East Downtown Specific Plan (SPA 9)/Specific Plan (S-P) Commercial Shopping Center (across Centre City Parkway)
South Downtown Specific Plan (SPA 9)/Specific Plan (S-P) Commercial Bank, Event Space, Restaurant West Downtown Specific Plan (SPA 9)/Specific Plan (S-P) Senior Housing (Under Construction)

SUMMARY OF REQUEST
On March 31 request for a Tentative
Subdivision Map, Planned Development Permit (Master and Precise Plans; Attachment 2 Master Plan), and Design Review Permit for the construction of a three-story, 94-unit, - 3 - Project Plans).

The Tentative Subdivision Map request to merge the two existing lots into one and allow for individual ownership of the townhome units, is permissible pursuant to Article 49 (Air Space Condominium and Community Apartment Projects) of the , and Chapter 32 (Subdivisions) of the Escondido Municipal Code.

The Gateway Transit land use district of the DSP establishes allowed uses for the district. Pursuant to Figure II-3 (Residential Land Use Matrix) and Figure II-4 (Locations for Residential Land Uses), ground-floor residential units are permitted with a Planned Development Permit pursuant to Article 19 (Planned Developments) of the EZC. A Design Review Permit is required for projects that include new construction of buildings, pursuant to Article 64 (Design Review), section 33-1354 of the EZC. Article 49, Section 33-951(b)(1) further notes that condominium CITY o[ ESCONDIDO

STAFF REPORT
Specific Plan, "DSP") General Plan land use designation, and is zoned Specific Plan (S benefit from the district's proximity to employment and major thoroughfares , 2025, Storm Bird, representing Storm Properties ("Applicant"), submitted a "for sale" townhome project (Attachment
Escondido Zoning Code ("EZC")
□
Attachment "2"
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projects proposed in tandem with a Planned Development Permit do not require a Condominium Permit. Table 2 provide details of the proposed Project.

Article 19, Section 33-409 requires City Council approval of a new Planned Development Permit request which establishes a Master Development Plan. Article 1 (General Provisions and Definitions), Section 33-16(c) of the EZC states that the concurrent processing of applications shall be reviewed by the highest decision-making body.

Therefore, the Project
a recommendation to the City Council.

Table 2. Supplemental Details of Request
Standard Minimum/Maximum Required Proposed

1. Property Size: None 3.51 gross acres / 3.41 net acres

2. Number of Units: 217 units identified for this site
within the Housing Element
Suitable Sites Inventory*
94 units

3. Unit Size (Article 49):

Studio
1-bedroom
2-bedroom
3-bedroom
Per additional bedroom
600 square feet (sq. ft.)
700 sq. ft.
800 sq. ft.
1,000 sq. ft.
150 sq. ft.

None
None
None
1,354 1,708 sq. ft.
1,744 sq. ft. (4-bedroom)

4. Density: 100 dwelling units per acre (du/ac) 26.9 du/ac

5. Lot Coverage/Floor Area Ratio: None / None 71,148 sq. ft. / 46%

6. Building Height 75 ft. / 5 stories 37 ft. / 3 stories

7. Motor Vehicle Parking: 211 total parking spaces:
188 resident-spaces
(2/unit, 1 of which is covered)
23 guest-spaces (0.25/unit)
204 total parking spaces:
188 resident-spaces
(2/unit, 2 covered - garage parking)
16 guest-spaces (0.17/unit**)

8. Bicycle Parking: N/A 12 total parking spaces through 6 Bike Path

9. Setbacks:

Front Yard 14 ft. from curb or at right-of-way
(whichever is greater)
14 ft. from curb
Rear Yard None 8 ft.

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is subject to final decision by the City Council. The Planning Commission's action is to make -
"Class 2" parking racks adjacent to
□
Attachment "2"
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Standard Minimum/Maximum Required Proposed
Street Side 14 ft. from curb or at right-of-way
(whichever is greater)
5 ft. from right-of-way
Side Yard None 15 ft. from Property Line
5 ft. from Access Easement

10. Open Space/Landscaping: Landscaping: Refer to Article 62 Open Space: 28,200 sq. ft. (300 sq.
ft. / unit)
Landscaping: Compliant with Article
62 Open Space:
28,213 total sq. ft., including:
17,342 sq. ft. common open space
10,871 sq. ft. private open space
(balconies, patios)

11. Trees: Street Trees: 1 tree per 30 linear
feet of frontage (293 ft., or 9 street
trees)
Multi-Family trees:

One per unit, for a total of 94
One per four guest parking spaces, for a total of 4
Street Trees: 9 to be provided
Multi-Family trees:
98 trees provided throughout the
Project site

12. Signage: Downtown Specific Plan, Chapter
VI: Sign Standards
Conceptual only; to be reviewed in
the building permit stage

13. Trash: Trash Enclosures or bins Two trash enclosures

14. Lighting: Article 35 (Outdoor Lighting) of the
EZC
Conceptual only; to be reviewed in
the building permit stage

15. Heating and Ventilation: To be screened Screened

16. Laundry Facilities: Washer/Dryer hook-ups in each unit Provided

17. Private Storage: Minimum 80 cubic ft. per unit
Minimum dimensions of 2 ft.
100 cubic ft. average within each
unit
of this staff report.
** Parking reduction

PROJECT ANALYSIS

1. General Plan Conformance:
a.

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* Remaining units would be submitted to the DSP's Density Credit Pool, as discussed in the "Specific Plan" portion pursuant to AB 2097, discussed in the "Site Design" portion of this staff report.

Housing Element and "No Net Loss"
□
Attachment "2"
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The City is taking steps to encourage, promote, and facilitate the development of housing consistent with regional housing needs, consistent with Government Code section 65584. During the current sixth cycle planning period, the City must accommodate an assigned Regional Housing Needs totaling 9,607 housing units. As of January 1, 2026, the City has reported a total of 1,875 housing units permitted toward meeting RHNA. This includes 403 lower-income units (190 Very-Low and 213 Low), 59 moderate-income units, and 1,413 above moderate-income units. Therefore, 7,677 housing unit remain to be accommodated for through this planning period.

The Housing Element lists properties identified as being suitable to accommodate housing units during the planning cycle. A total capacity of 12,445 units was identified, including 9,463 units on the SSI properties and an additional 2,983 units from Accessory Dwelling Units (ADUs) and Alternative Sites. Therefore, at the adoption of the Housing Element, the City had capacity to provide approximately 23 percent more units than needed.

The Project are forecast to provide 140 lower-income units and 77 above-moderate units, totaling 217 units, as shown in Table 3:

Table 3: SSI Projected Capacity at Project Site
Income Levels Lower Moderate Above
Moderate Totals
Parcel Number 229-331-16-00 103 0 57 160
Parcel Number 229-331-17-00 37 0 20 57
Totals 140 0 77 217
No Net Loss law (Gov. Code § 65863) ensures development opportunities remain available throughout the - and moderate-income
households. The soresidential density than shown in the Housing El In general, jurisdictions cannot approve new housing at significantly lower densities or at different income categories than was projected in the Housing Element without making specific findings and/or identifying other sites that could Since the Project is proposing zero lower-income housing units and 94 above moderate-income housing units, the Project would provide fewer housing units than projected in the Housing Element (Gov. Code § 65863(b)). Therefore, provisions of No Net Loss law apply to the Project. However, as demonstrated in Table 4 below, capacity remains to meet the requirements of Gov. Code § 65583.2 and to accommodate the RHNA pursuant to Gov. Code § 65584, without identifying additional sites to accommodate these units or the Therefore, the City would continue to comply with the provisions of No Net Loss with approval of the Project, as proposed, and the Project Element.

Table 4: Housing Unit Capacity versus Need Analyses
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policies 1.1 and 2.1 of the Housing Element of the General Plan, while accommodating the City's share of ("Gov. Code §")
Allocation ("RHNA")
includes a Suitable Sites Inventory ("SSI") which
parcels are listed on the City's SSI, and
planning period to accommodate a jurisdiction's RHNA, especially for lower called "no net loss" provisions apply when a site is included in the jurisdiction's Housing Element's inventory of sites and is either rezoned to a lower residential density or is approved at a lower ement. (Gov't Code§ 65863(b)).
accommodate these units and affordability levels "lost" as a result of the approval. affordability levels "lost".
would be consistent with the City's Housing
□
Attachment "2"
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Suitable Sites Inventory (SSI) + Alternative Sites Capacity Analysis Income Levels Lower1 Moderate Above
Moderate Totals
Original SSI Capacity +4,557 +1,467 +3,439 +9,463
Original ADU/Alternative Sites Capacity +653 +237 +2,092 +2,983 Original Total Capacity +5,210 +1,704 +5,531 +12,446
Capacity Removed to Date2 -294 -46 -305 -605
Capacity Removed by Project -140 -0 -77 -217
Remaining Capacity with Project +4,776 +1,658 +5,149 +11,578 Regional Housing Needs Allocation (RHNA) Analysis
Income Levels Lower1 Moderate Above
Moderate Totals
Original Total RHNA -3,113 -1,527 -4,967 -9,607
Reported Progress, as of Jan. 1, 2026 +403 +59 +1,413 +1,875 Remaining RHNA -2,688 -1,465 -3,524 -7,677
Capacity vs. Need Analysis
Income Levels Lower1 Moderate Above
Moderate Totals
Remaining Capacity (+) +4,776 +1,658 +5,149 +11,578
Remaining Need (-), as of Jan. 1 2026 -2,688 -1,465 -3,524 -7,677 Total Surplus (+)/Deficit (-) +2,088 +193 +1,625 +3,901 Lower1 Moderate Above
Moderate Average
40% 10% 11% 23%
, as of Jan. 1, 2026 44% 12% 32% 34% 1
Very-Low-Income and Low-Income housing units have been combined for demonstration purposes. 2 SSI Capacity Removed to Date includes both entitled and pending projects for conservative estimates.
b. Land Use and Community Forum
Community Character Policy 1.1:
pattern of higher-intensity development within the downtown area and lower-intensity development in CITY o[ ESCONDIDO

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Capacity to Need "Buffer" by Income Category Analysis
Original "Buffer"
Current "Buffer"
New development should serve to reinforce the city's present development □
Attachment "2"
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outlying areas. As a guide toward accomplishing this objective, new development projects shall be at an appropriate density or clustered intensity based upon their compatibility with the majority of the existing surrounding land uses. This policy shall limit density transfers from constrained portions of a property as defined in the land use and open space goals.

The proposed Project includes a residential development in the downtown area which is consistent with the policies outlined in the DSP, as detailed in multiple sections of this staff report. The Project is in close proximity to public transit, existing commercial development, and compatible with similar residential development in the area, including but not limited to Quince St. Apartments, Valley Parkway 55 W. Grand Condominium development. The Project
would be conditioned to participate in the density transfer pool to ensure that the overall buildout of the downtown area can be achieved and the development potential of this site is not lost. For further detail Community Character Policy 1.3: Focus development into areas where land use changes achieve the -term goals. Facilitate development that is consistent with the build out vision for each area through incentive programs and efficient administrative and discretionary approval processes for plot plans, Planned Developments, Area Plans, Specific Plans, and Zoning Overlays.

The proposed Project would include a land use change through the demolition of the existing retail and commercial spaces on site and construction of the residential units. The proposed Project will be consistent with the build-out vision of the DSP, which entails smart growth policies (see Section III(A)(1) of the DSP), in that it encourages additional housing opportunities for people to live in the downtown area. The proposed Project includes required Planned Development Permits to allow for ground-floor residential uses within this area of the DSP. Further residential units would be consistent with the ultimate build out vision of 5,275 units within the DSP in that those unused units for the site would be captured for future use through the density transfer pool.

Community Character Policy 1.5: The city should maintain its single-family residential development pattern, except in locations such as the downtown, along major transportation corridors, and around commercial and public activity centers, where higher densities are more appropriate.

The proposed Project would develop at 26.9 du/ac, in an area adjacent to major transportation corridors.

The Project site is approximately 250 feet east of
terminal, which includes Sprinter service as well as existing and future NCTD bus lines, providing public transit to future residents of the Project. The Project site is immediately adjacent to multiple commercial developments across W. Valley Parkway and Centre City Parkway, providing access to commercial retail centers to the future residents of the Project. Additionally, the Project site is bounded by Centre City Mobility and Infrastructure element as a super major road and collector street, respectively.

Community Character Policy 1.7: Incorporate iconic signage, artwork, landscaping and/or architecture characterized as uniquely Escondido at gateway locations to define a sense of entry and strengthen community identity.

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Condominiums, "The Maple" apartments, and 5
regarding the density transfer program, please see the "Specific Plan" section of this staff report. community's long
the North County Transit District's Escondido transit
Parkway and Valley Parkway, major transportation thoroughfares identified within the General Plan's □
Attachment "2"
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Portions of the Gateway Transit District adjacent to the Mercado District are within a Design Overlay Area.

The proposed Project is located within the Mercado Area Overlay Plan of the DSP, which requires that building materials which would promote this theme. The proposed Project would incorporate these design elements across the Project would aid in defining an inviting transition to Downtown.

Community Character Policy 1.9: Promote development in downtown, at transit stations, and other key districts to accommodate a mix of land uses and configure uses to promote walkability, bicycling, and transit uses, reducing the need for the automobile.

The proposed Project
immediately adjacent to multiple commercial developments, and within walking distance (< 0.5 miles) from the core of the downtown area. Additionally, the Project Path, which borders the Project site to the north and the east. The Project would directly integrate with the bicycle path, connecting through its common area fencing directly to the path along its northern property boundary. The Project
bicycle pathways would encourage future residents to patronize surrounding businesses, and promote nonautomobile transit. c. Mobility and Infrastructure
Pedestrian Network Policy 3.4: Preserve and enhance pedestrian connectivity within existing neighborhoods via the Escondido Creek Trail, sidewalks, and trails, and require a pedestrian network in new developments that provides efficient and well-designed connections to adjacent land uses, commercial districts, schools, and parks.

The proposed Project would improve the sidewalk pathway along W. Valley Parkway along the southern frontage of the Project, ensuring an improved connection between the Project and adjacent land uses. The Project would
common area fencing directly to the path along its northern boundary for residents to access the trail for pedestrian and cycling activity.

Bicycle Network Policy 4.4: Develop bicycle routes and facilities that connect to transit stations, employment and commercial centers, schools, libraries, cultural centers, parks, the Escondido Creek Trail, and other frequently visited destinations throughout the community and region where they do not already exist.

The proposed Project would develop an absent connection for an existing Class IV bicycle path which traverses W. Valley Parkway along the southern frontage of the Project. Additionally, future residents will be the
Project site. This improvement to the bicycle path and connectivity to the creek trail would provide a safe, and further along W. Valley Parkway.

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projects located within its boundaries adhere to architectural planning which incorporates an "early California" theme. Projects are heavily encouraged to utilize colors, architectural design, landscaping, and recommendations as discussed in the "Building Design" portion of this staff report. The integration of these is approximately 250 feet east of the North County Transit District's transit station, is adjacent to the Escondido Creek Trail's Bicycle
's proximity to the core of the downtown area, and accessibility to public transit and directly integrate with the Escondido Creek Trail's Bicycle Path, connecting through its provided direct access to the Escondido Creek Trail's Bicycle Path on the northern boundary of accessible connection for bicyclists traveling to and from the North County Transit District's transit terminal □
Attachment "2"
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d. Community Protection
Noise Policy 5.1: Require development to meet acceptable exterior noise level standards as established in Figure VI-17 and use the future noise contour map (Figure VI-22) as a guide for evaluating the compatibility of new noise-sensitive uses with projected noise levels. epared by Helix Environmental Services, which
includes an in-depth discussion regarding existing noise levels along Centre City Parkway and W. Valley Parkway. Residences and open space areas adjacent to Centre City Parkway and W. Valley Parkway would be mi
noise level range as demonstrated in Figure VI-17 of the Community Protection element. Primary common open space areas of the Project would be set back from these noise contour areas at a sufficient distance as to not be impacted by the noise of the adjacent streets. Additionally, the proposed Project would implement construction measures as described below, under Noise Policy 5.4.

Noise Policy 5.4: Require noise attenuation for new noise-sensitive uses which include residential, daycare facilities, schools, churches, transient lodging, hotels, motels, hospitals, health care facilities, and libraries if the projected interior noise standard of 45 dBA CNEL is exceeded.

The proposed Project would incorporate noise attenuation for all dwelling units within the development, to include common practices such as dual-pane windows, HVAC unit use, and California Building Code requirements for construction which would reduce the interior noise levels perceived to below 45 dBA CNEL (Attachment 5 Condition of Approval E.4).
e. Resource Conservation
Cultural Resources Policy 5.4: Recognize the sensitivity of locally significant cultural resources and the need for more detailed assessments throughout the environmental review process.

The Project site is located adjacent to the Escondido Creek Trail, which is noted as generally sensitive for the potential for cultural resources and Tribal Cultural Resources. Due to this proximity, the Project site contains soil material which has been deposited by river flow), which may possess the potential for buried cultural resources.

The Applicant provided a supplemental memorandum prepared by Helix Environmental Services discussing the potential for cultural resources to be found at the property. The memorandum concludes that while the area is generally sensitive for cultural resources and Tribal Cultural Resources, no resources as defined by CEQA have been identified within the Project area, the Project is not anticipated to affect any historical resources, and there are no unusual circumstances present on the Project site that would indicate development would result in any significant impacts on cultural resources. To further ensure that any potential impacts to tribal cultural resources that may exist on the Project site are protected to the maximum possible extent, Condition of Approval E.6 will be implemented for the Project as recommended

2. Specific Plan Conformance:

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The Applicant provided a "Class 32" memorandum, pr
nimally affected by the existing traffic noise in this area, and fall within the "Conditionally Acceptable" , Exhibit "E" -
fill soils of younger "alluvial" deposits (
by the Applicant's counsel and Helix Environmental Services. □
Attachment "2"
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The Project site is located within the Gateway Transit land use district of the DSP. The Gateway Transit District is intended to accommodate a variety of uses, including high-density residential uses in areas that benefit from jor thoroughfares, the Escondido Creek Trail, and the Escondido Transit Center. Developments facing Valley Parkway should consider the high visibility of the location and contribute to the positive image of the City and Downtown. An essential component of the DSP is encouraging a wide-range of housing choices that meet the various needs of the Escondido community.

The Gateway Transit District permits multifamily development, including ground-floor residential development subject to a Planned Development Permit in accordance with Article 19 of the EZC, with a permitted density of 100 du/ac pursuant to Figure II-5 of the DSP. While there are no minimum densities specified in the DSP, prescribed residential densities within the greater DSP area range from 45 to 100 du/ac. The Applicant proposes 94 dwelling units, which equates to approximately 26.9 du/ac. For reference, the General Plan and Zoning Code recognize densities above 24 du/ac as Very High.

Further, the DSP is designed to accommodate up to 5,275 residential units. The DSP established a Density Transfer Program to allow projects which are foregoing density on a site to transfer unused units into the DSP Density Credit Pool so as to retain the potential maximum buildout for the specific plan area. This transfer is facilitated through a deed restriction recorded on the property, to demonstrate the development rights are severed from the lot. The proposed Project would provide 94 units (26.9 du/ac), whereas 351 units are permitted (100 du/ac). Draft Condition of Approval No. E.3 would require participation in the Density Transfer Program, capturing those 257 unused units and placing them into the DSP Density Credit Pool, to be accessed at a future time within the specific plan area. Compliance with the Density Transfer Program ensures overall buildout of 5,275 units within the DSP is achieved, and no residential units are lost over time.

Chapter III of the DSP provides design guidelines for projects within the specific plan area, including multiple measures for applicants to incorporate as part of their design. These policies and intensity, vehicle activity, and strategies to incorporate urban design solutions to increase the quality of projects within the specific plan. The proposed Project
against these policies, and incorporates design features to promote the urban and pedestrian nature of the report. Further, as detailed in Table 2 Supplemental Details of R the Project complies with all development standards within the DSP, and conforms to the requirements of the Specific Plan.

3. Master Plan Development:

The Project pursuant to Article 19 (Planned Development (P-D) Zone), Section 33-408 of the EZC. The Master Plan document provides detail for the overall project, such as project layout, density, land uses, common area, open space, proposed development standards, and architectural design.

Included within the Master Plan is provisions for the
for the future residents of the development. Home Occupations are permitted within the Downtown Specific Plan, in conjunction with an approved residential project. Requests for home occupation permits would be administered pursuant to Article 44 (Home Occupations) of the EZC and Chapter 16, Business Licenses.

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the DSP's proximity to employment and ma
and "Smart Growth Policies"
guidelines are provided to develop Downtown Escondido's urban atmosphere, inviting increased pedestrian City's Staff Development Committee thoroughly reviewed the Downtown Specific Plan. These elements are further described in the "Building Design" portion of this staff II equest", includes the submittal of a "Master Plan" document,
accessory use of "Major" and "Minor'' home occupations
□
Attachment "2"
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Staff has reviewed the complete Master Plan document, and found it to be in conformance with all development standards proposed within the DSP, EZC, and General Plan as applicable. The complete Project Master Plan is included as Attachment 2 of this staff report.

4. Climate Action Plan Consistency:
proposed Project exceeds
-family housing consisting of over 55 units. If a project exceeds the screening thresholds established by the CAP, then an applicant may demonstrate consistency with the CAP by incorporating applicable Greenhouse Gas Emission reduction measures outlined in the CAP applicable measures are incorporated within the draft conditions of approval (Attachment 5 - Conditions of Approval E.2.a through E.2.d).

5. Site Design
a. Grading, topography, retaining walls, and fencing:

The Project site is relatively flat, and has an average elevation of 644 ft. across the site. The finished floors for the buildings range from 644.25 ft. to 646.34 ft., indicating very minor changes to the topography of the site. All residential units fronting W. Valley Parkway would incorporate 42 in. patio screening walls to provide exterior private patio space and separation from the public right-of-way. The northern and eastern boundaries of the site abut portions of the Escondido Creek Trail Bike Path and would have 6-foot-tall tubular steel fencing to match the design of intended Trail fencing improvements. The fencing would be further enhanced with 6-foot vertical hedges on the private property side of the fence, to provide additional screening for the proposed Project.
b. Project Access and Circulation:

The Project site currently takes access from W. Valley Parkway via two access driveways. The proposed Project would eliminate one of these existing driveways. The remaining driveway would be improved, providing primary access to the Project site. Access to the garage spaces of the westernmost buildings would be provided along a shared alley.

The modifications proposed to the existing driveways provide for additional buildable area for the Project, as the reduction of access points provides for less drive aisle requirements throughout the Project site.

Additionally, the consolidation of the primary access points to the Project will allow for a primary, celebrated entryway to the Project, and simplifies access from Valley Parkway. c. Building Orientation:

The buildings of the proposed Project are mostly oriented inward, with several of the building front facades that front W.

Valley Parkway are oriented towards the street, establishing a connection to the pedestrian pathway along its frontage, and promoting the residential use of the Project. Portions of the buildings that do not face W.

Valley Parkway or Centre City Parkway, but are adjacent to those streets, would incorporate articulated CITY o[ ESCONDIDO

STAFF REPORT
The Applicant prepared a Climate Action Plan ("CAP") Consistency Checklist, as the the CAP's identified threshold established for multi
City's
checklist. The Applicant's CAP Consistency Checklist identifies the applicable reduction measures, and all facing one another. As encouraged by the DSP's "Building Orientation Policy," the buildings □
Attachment "2"
250
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architecture and balconies, overlooking the public right-of-way while providing pedestrian scale to the environment, as encouraged by the specific plan.
d. Open Space and Landscaping:

The DSP requires new developments to provide 300 sq. ft. of open space per dwelling unit. Based on this requirement, the proposed Project would require 28,200 sq. ft. of open space (94 dwelling units x. 300 sq. ft.). The DSP allows for open space requirements to be met through private patios/decks that are directly accessible from the unit and maintain a minimum size of proposed Project meets the requirement for open
space through a combination of private and common areas, providing a total of approximately 28,213 sq. ft. of open space area. For additional detailed information, refer to Table 2 The DSP refers to Article 62 (Water Efficient Landscape Regulations) of the EZC for landscaping requirements, which include the required number of street trees (1 tree per 30 linear feet of street frontage), and a requirement for one tree per dwelling unit. Additionally, the Climate Action Plan checklist requires an additional tree per 4 guest parking spaces. Cumulatively, the proposed Project would require 98 trees on-site, as shown on the Project plans under Attachment 3 (Conceptual Landscaping Plans). The proposed Project mmon space areas would additionally incorporate various landscape features such as benches, paseo walkways, and canopy tree coverage.
e. Parking:

The DSP requires off-street parking based on the number of bedrooms in each dwelling unit. For three or more bedrooms, two off-street resident parking spaces are required, one of which must be covered. Up to 25 percent of the units may accommodate parking through tandem spaces. In addition, 0.25 off-street guest parking spaces are required per unit. Under the requirements of the DSP, the Project would be required to provide 188 resident parking spaces, including 94 covered spaces and with no more than 24 units providing tandem parking, and 23 guest parking spaces, for a total of 211 parking spaces. However, the Applicant invoked California Assembly Bill (AB) 2097, which prohibits public agencies from imposing minimum automobile parking requirements on a development project located within a half-mile of a major transit stop. The Project
terminal to the west.

The proposed Project would provide 188 off-street resident parking spaces within attached, two-car garages, two spaces per unit. Of the 94 units, 24 would accommodate required parking through tandem parking garages. Further, the Project proposes 16 guest parking spaces, for a total of 204 parking spaces.

6. Building Design:

The Project site is located within the Mercado Design Overlay Area, which encourages colors, architecture, proposed Project would incorporate
architectural design inspired by Architect Irving Gill, presenting an interpretation of the Spanish Santa Barbara style.

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5' in all directions, and/or through common open
space areas that are a minimum 10' in all directions. The "Supplemental Details of
Request".
'sco
site is approximately 250 feet away from the North County Transit District's transit landscaping, and materials suggestive of an "Early California" theme. The □
Attachment "2"
251
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a. Building Height, Mass, and Scale:

The building height is consistent with the requirements of the Downtown Specific Plan, in that the proposed Project proposed Project includes buildings
designed to be approximately 37 ories) in height. The scale and massing of the proposed buildings is consistent with surrounding existing developments, such as the residential development adjacent to the western boundary of the Project, with construction abutting the majority of the Valley Parkway frontage along the required setback. The proposed Project
planes, which provide vertical articulation to reduce the visual massing of the structures. Therefore, the proposed massing and scale of the Project would not be out of character with the development of the downtown area.
b. Residential Floor Plans:

The proposed Project includes a variety of floor plans, consisting of three- and four-bedroom models, and up to four different plan options. Requirements of residential floor plans pursuant to the EZC and DSP include the need for 80 cubic feet of storage area, as well as washer and dryer hook ups. Each floor plan demonstrates the required amount of storage for each unit (approximately 100 cubic feet within the garage area), which would not impede on the required parking space dimensions for each vehicle. The proposed floor plans include washer and dryer hook ups within the units. c. Building Materials:

The proposed Project includes a mix of decorative stucco, clay tile roofing, wood and metal decorative railing elements, ceramic tile detail, and various other decorative elements. The combination of traditional and modern materials would provide a modern interpretation of the California theme, as well as provide a modern interpretation which would give the Project its own distinct identity within the specific plan area. Any potential future changes to the design elements of the Project would require approval of materials equal to or better than what is proposed. Minor changes may be approved by the Director of Development Services, as identified in Condition of Approval No. A.4.c.

FISCAL ANALYSIS
The Applicant has paid all fees required for the processing of the various planning applications. The Applicant would be responsible for the payment of applicable Development Impact Fees at the time of building permit issuance.

ENVIRONMENTIAL ANALYSIS
Pursuant to Section 15332 (InGuidelines, the proposed Project is categorically exempt from further environmental review in that the Project - proposed Project is consistent with the applicable general plan designation, and all applicable general plan policies as well as applicable zoning designation and regulations, as detailed in the analysis section above. The Project site has no within t -1 through 3-3.

The proposed Project can be adequately served by all required utilities and public services, as determined by the CITY o[ ESCONDIDO

STAFF REPORT
does not exceed the 75' (S stories) maximum height limit. The '(3 st
's architectural design includes elements that vary facade "Early II
Fill Development Projects) of the California Environmental Quality Act ("CEQA") involves development of town home "for sale units" on a property that is less than five acres. The value as habitat for endangered, rare, or threatened species, and is considered "urban/developed" as denoted he City of Escondido's Multiple Habitat Conservation Program draft Subarea Plan, Figures 3 □
Attachment "2"
252
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n through the Staff Development Committee review process. The proposed Project would not result in any significant effects relating to traffic, noise, air quality, or water quality, in that the Project is an in-fill development project located within an urbanized area of the City, and no substantial evidence has been provided indicating that the Project would have significant effects on the environment. The Applicant has provided the following memorandums to justify the Class 32 Exemption request, which have been fully reviewed by City staff to be in compliance with all CEQA requirements for the proposed Project: - Class 32 Memorandum, prepared by Helix Environmental Planning Services, dated August 21, 2025. - Traffic Scoping Agreement, prepared by Linscott, Law & Greenspan Engineers, dated August 7, 2025. - Preliminary Stormwater Quality Management, prepared by SWS Engineering Inc., dated August 12, 2025.

Furthermore, the proposed Project does not trigger any of the exceptions to the use of an exemption as detailed in Section 15300.2 The application of this exemption is further discussed in the Notice of Exemption (Attachment 4 - Notice of Exemption).

PUBLIC INPUT
As required by Article 61 (Administration and Enforcement), Section 33-1300 of the EZC, the public hearing for the proposed Project was noticed in the Escondido Times Advocate on April 30, 2026, and notices mailed on April 27, 2026 to approximately 44 properties within a 500-foot radius of the Project site. As of the date of the publication of this staff report, City staff have not received any public comments.

CONCLUSION AND RECOMMENDATION
The proposed Project includes a Tentative Subdivision Map, Planned Development Permit (Master and Precise), and - area. The Project would introduce new housing opportunities in an urban area of the City. As discussed throughout this staff report, the Project complies with the requirements of the Escondido Zoning Code, Downtown Specific Based on the analysis contained in this staff report, and as presented by City staff during the public hearing, Planning staff recommend that the Planning Commission adopt Resolution No. 2026-04, recommending approval of the Project to the City Council, subject to the draft Conditions of Approval.

Motion as recommended by City staff: Adopt Resolution No. 2026-04, recommending that the City Council approve the Project, as conditioned.

ATTACHMENTS

1. General Plan Map, Zoning Map, and Aerial Map

2. Project Master Plan

3. Project Plan Set
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City's Utilities Engineering Divisio
Design Review Permit to facilitate the construction of 94 "for sale" dwelling units in the Downtown Specific Plan Plan, and with several General Plan policies included in the City's 2012 General Plan. □
Attachment "2"
253
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4. Draft Notice of Exemption

5. Draft Planning Commission Resolution No. 2026-04 including Exhibits A, B, C, D, and E a. - Legal Description
b. - Project Master Plan
c. C - Project Plan Set
d. E D - Findings of Fact/Factors to be Considered
e. E - Conditions of Approval
CITY 0 f ESCONDIDO

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Exhibit "A"
Exhibit "B"
Exhibit" "
xhibit" "
Exhibit" "
□
Attachment "2"
254
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Attachment “3”

DRAFT NOTICE OF EXEMPTION
PLANNING CASE NOS. PL25-0096/PL25-0097/PL25-0098/PL25-0099

CITY OF ESCONDIDO

PLANNING SERVICES
201 NORTH BROADWAY
ESCONDIDO, CA 92025-2798
(760) 839-4671

NOTICE OF EXEMPTION
To: Assessor/Recorder/County Clerk
Attn: Fish and Wildlife Notices
1600 Pacific Hwy, Room 260
San Diego, CA 92101
MS: A-33
From: City of Escondido
Development Services Department
Planning Services
201 North Broadway
Escondido, CA 92025
Project Title/Case No: PL25-0096/PL25-0097/PL25-0098/PL25-0099: VALLEY PARKWAY & CENTRE CITY PARKWAY 94-UNIT CONDOMINIUMS
Project Location - Specific: The 3.51-acre project site is located on the north side of W. Valley Parkway and the west side of Centre City Parkway, and is addressed as 510 and 520 W. Valley Pkwy. (Assessor’s Parcel Number(s):
229-331-16-00 & 229-331-17-00)
Project Location - City: Escondido Project Location - County: San Diego Description of Project: Approval of a project within the Downtown Specific Plan (SPA-9) General Plan land use designation and Specific Plan (S-P) zone consisting of a Tentative Subdivision Map, Planned Development Permit (Master and Precise), and Design Review Permit to permit the construction of 94 dwelling units (“Project”). The proposed Project includes a Tentative Subdivision Map to merge two lots into one, and to allow for the subdivision of air space for the purpose of 94 condominium units. A Planned Development Permit consisting of a Master and Precise Plan for ground-floor residential units within the Downtown Specific Plan area. A Design Review Permit is required for the construction of the multi-family dwelling structures. The Project also includes necessary on- and off-site improvements, including the demolition of approximately 13,100 square-feet of existing commercial tenant buildings and 30,600 square-feet of self-storage warehouse buildings, as well as appurtenant grading, landscaping, open space, and public street and sidewalk improvements.

Name of Public Agency Approving Project: City of Escondido Name of Person or Agency Carrying Out Project:

Name: Storm Bird, Storm Properties, Inc. Telephone: 310-986-2439 Address: 970 W. 190th St., Ste. 995, Torrance, CA 90502 Private entity School district Local public Agency State agency Other special district Exempt Status: The project is categorically exempt pursuant to CEQA Guidelines section 15332 (“In-Fill Development Projects”).

Reasons why project is exempt: The proposed Project is categorically exempt pursuant to CEQA Guidelines Section 15332 (“In-Fill Development Projects”), in that the proposed Project complies with the exemption criteria necessary to be exempt from further environmental review as detailed below:

Exemption Criteria: Justification
(a) The project is consistent
with the applicable general plan
designation and all applicable
general plan policies as well as
The project site has a General Plan land use designation of SPA 9 and is zoned S-P. Within the Downtown Specific Plan, the project site is within the Gateway Transit District, which is identified for high-density mixed-use development. The Downtown Specific Plan designates the site for residential development with up to 100 dwelling units per acre (du/ac). The project would provide 94 multi-family units on a 3.5-acre site, which results in a density of 26.9 du/ac, and would be 255 Item7.

Attachment “3”
Updated: 4/15/2026
with applicable zoning
designation and regulations.
consistent with the General Plan land use designation and density for the site.

The City’s zoning code allows ground-floor residential development on the project site with the project’s Planned Development Permit. The project does not propose to amend the General Plan designation or zoning for the project site, and the project would be consistent with the General Plan and zoning development designations. Therefore, the project, as currently proposed, is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations, and thereby meets criterion a.
(b) The proposed development
occurs within city limits on a
project site of no more than five
acres substantially surrounded
by urban uses.

The project site encompasses 3.5 acres located within the city limits of the incorporated City of Escondido. Urban uses are defined under PRC Section 21072 as including “any residential, commercial, public institutional, transit or transportation passenger facility, or retail use, or any combination of those uses.” The project site is adjacent to or separated by only a public right-of-way or floodwater channel from urban uses. Land uses surrounding the project site include a senior housing facility (currently under construction) and the Escondido Transit Center to the west; Escondido Fire Department Station 1 and light industrial uses to the north; and commercial uses to the east and south.

Therefore, the proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses, and thereby meets criterion b.
(c) The project site has no
value, as habitat for
endangered, rare or threatened
species.

The project site is entirely developed with six buildings, paved areas, and ornamental landscaping. Landscaping on the project site consists of low-lying shrubs and 21 trees, which do not provide habitat suitable for endangered, rare, or threatened species. The project is surrounded by urban development and does not serve as a wildlife corridor. The Escondido Creek flood channel north of the project site is comprised entirely of concrete and does not contain any vegetation or natural resources that could provide habitat for endangered, rare, or threatened species. Consequently, the project site has no value as habitat for endangered, rare, or threatened species, and thereby meets criterion c. (d) Approval of the project
would not result in any
significant effects relating to
traffic, noise, air quality, or
water quality.

An initial assessment of impacts related to traffic, noise, air quality, and water quality has been prepared to evaluate the potential effects of the project. Based on supporting sources and project-specific studies, the project, as currently proposed, is not anticipated to result in significant effects related to traffic, noise, air quality, or water quality, thereby meeting criterion d. (e) The site can be adequately
served by all required utilities
and public services.

The project is proposed for a site where development has previously been served by public utilities and services. Therefore, connections to existing water, wastewater, stormwater, electric, and telecommunications services are available at the project site. The City confirmed the presence of existing City public sewer and water facilities in the project vicinity that would adequately serve the project site in a will-serve letter dated June 24, 2025 (City 2025). The project is not anticipated to require increased capacities for water or sewage service.

No substantial increase in the amount of impervious area on-site would occur and the amount and locations of stormwater runoff would be consistent with the existing condition. Two modular wetlands systems along the project’s northern boundary would catch, treat, and release project runoff into the adjacent Escondido Creek. A catch basin along the project’s western boundary would capture additional project runoff. Existing electric and telecommunication connections at the project site serve the existing buildings and infrastructure providing these utilities would be adequate to serve the project. The construction of residential units on the project site would result in an incremental increase in the demand for public services, including fire protection, police protection, 256
Item7.

Attachment “3”
Updated: 4/15/2026
schools, parks, and other public facilities. As the project is consistent with General Plan, and therefore the population projections for the City, the increased demand for these facilities is anticipated by the City and would be accommodated by the City through payment of development impact fees.

Connections to existing utilities and existing public services would adequately serve the project site and the project would not require new utilities or services to be provided by the City or other public utility agency. The project therefore would meet criterion e.

Further, the Project also does not trigger any exceptions to categorical exemptions identified in CEQA Guidelines section 15300.2. in that:
- Location. The proposed Project is not pursuing a Class 3, 4, 5, 6, or 11 Categorial Exemption; therefore, this exception is not applicable to the project.
- Cumulative Impact. The proposed Project will not result in a cumulative impact from successive projects of the same type in the same place, over time, as the project is consistent with the General Plan policies which were addressed in the General Plan Final EIR. Furthermore, the project is consistent with the Downtown Specific Plan’s development standards for the property, and will remain consistent with the Specific Plan policies and guidelines.
- Significant Effect. The area of impact has been previously disturbed by urban development. As detailed in the analysis in the Planning Commission staff report, dated May 12, 2026, no significant environmental effects related to traffic, noise, air quality, or water quality would occur as a result of the Project. The area of impact is already disturbed and improved with an existing commercial development, and will be redeveloped into multi-family residential units consistent with the Downtown Specific Plan. No unusual circumstances are surrounding the project which would result in a reasonable possibility of a significant effect on the environment.
- Scenic Highways. The proposed Project will not damage scenic resources, including trees, historic buildings, rock outcroppings, or similar resources as the areas of impact have already been disturbed. - Hazardous Waste Sites. The project site is not located on a site as referenced in Section 65952.5 of the California Government Code.
- Historical Resources. The proposed Project is not on a site which contains a significant resource, and would not cause a substantially adverse change to the significance of a historical resource.

Lead Agency Contact Person: Alex Rangel Telephone: 760-839-4542 Signature: Date:

Alex Rangel
Associate Planner
Signed by Lead Agency Date filed with SCH:

Signed by Authorized Applicant Representative
257
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STAFF REPORT
June 10, 2026
File Number 0800-40

SUBJECT
PL24-0067 – AN APPEAL OF THE PLANNING COMMISSION’S DECISION TO APPROVE A TENTATIVE

SUBDIVISION MAP AND ADOPT AN ADDENDUM TO THE ENVIRONMENT DOCUMENT FOR THE SUBDIVISION OF ONE LOT INTO 5 RESIDENTIAL LOTS FOR FUTURE DEVELOPMENT ON HAMILTON

LANE AND BERNARDO AVENUE

DEPARTMENT
Planning Services, Development Services

RECOMMENDATION
Request the City Council adopt Resolution No. 2026-90 denying the appeal of the Planning Commission’s decision to approve the Tentative Subdivision Map and Addendum for the subdivision of one lot into 5 residential lots for future development on Hamilton Lane and Bernardo Avenue.

Staff Recommendation: Approval (Development Services: Kevin Snyder, AICP, Director of Development Services)
Presenter: Melissa DiMarzo, Assistant Planner II
ESSENTIAL SERVICE – Yes, Land Use/Development
COUNCIL PRIORITY – Drive Community and Land Development

FISCAL ANALYSIS
The Applicant will be responsible for payment of all Development Impact Fees. Additionally, the Applicant will be responsible for a Hamilton Lane Storm Drain Repayment for lots 1 and 2, as detailed in the Engineering Conditions of Approval Item #2 – Repayments and Fees.

PREVIOUS ACTION
On April 28, 2026, the project was heard by the Planning Commission, who motioned to approve the project. The motion was approved by a 4-1 vote.

BACKGROUND
Previous development proposal:
258
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On June 6, 2007, City Council approved the Annexation, Pre-zone, Tentative Subdivision Map, and adopted the Mitigated Negative Declaration prepared for a previous project at this location, with a language update to the resolution requested by The San Diego Local Area Formation Commission (LAFCO) adopted on June 4, 2008 (“Approved Project”). The Tentative Subdivision Map for the project (TR 931) was set to expire on June 2, 2010; however, state map extensions extended the expiration date to June 6, 2017. The project proponent filed an extension of time request prior to the 2017 expiration date, and City Council approved a 3-year extension on July 19, 2017 under Resolution No. 2017-97, setting the expiration to June 6, 2020. The California Governor extended certain qualifying subdivisions under a state of emergency declared due to the COVID-19 pandemic (CA Govt Code Section 65914.5), which granted an additional 18 months to any tentative map approved prior to March 4, 2020, which set the new expiration date for the 2007 approved map to December 6, 2021. However, the City did not receive any subsequent extension of time requests, and the map subsequently expired at the end of 2021.

Current development proposal:

On March 7, 2024, Robert D’Amaro of Masson & Associates (“Applicant”) filed an application to develop a 6.02-acre parcel located at the southeast corner of Hamilton Lane and Bernardo Avenue (APN 238-360- 68-00) (“Property”). The Property has a General Plan land use designation of Estate I (E1) and a zoning designation of Residential Estates (RE-40: 40,000 square-foot minimum lot sizes). The Property is surrounded by single-family residential uses to the north, east, south, and west, with the northern, eastern, and southern borders of the property abutting unincorporated San Diego County property.

The proposed development consists of a five (5) Lot Tentative Subdivision for the future development of five (5) single-family homes with the addition of a stormwater basin to address stormwater drainage on-site (“Project”). The request also includes the approval of an addendum to the previously adopted Initial Study/Mitigated Negative Declaration (IS/MND) for the site to document the minor changes to the Project from the previously Approved Project.

Per the Escondido Zoning Code Article 6 Table 33-98(a), the minimum lot size required for the property is 40,000 square-feet and the permitted use of the property is single-family residential, with an average lot width of 150 feet, and minimum street frontage of 20 feet (or connected to a public street by a permanent access easement). A copy of the proposed tentative map is included in the April 28, 2026 Planning Commission Staff Report (Attachment “3”).

Further analysis of the Project can be found within Attachment “3” – Planning Commission staff report, dated April 28, 2026.

PLANNING COMMISSION ACTION
On April 28, 2026, the Planning Commission held a duly noticed public hearing on the Project. A motion to approve the resolution approving the Project was passed by a 4 – 1 vote. 259
Item8.

PUBLIC INPUT
The April 28th, 2026, Planning Commission hearing was duly noticed in accordance with the Escondido Zoning Code, which included mailers sent out to properties within a 500-foot radius of the Property, posting in the Times-Advocate, and on-site posting.

City staff received two (2) public comments prior to the hearing which are included as Attachment “5” to the Planning Commission staff report (Attachment “3”). These comments were limited to general inquiries, and traffic and density concerns. City staff provided the requested information regarding the Project.

On the day of the hearing, additional oral and written public comment was provided and was addressed at the public hearing (See Attachment “1”).

APPEAL
On May 7, 2026, Heidi Whitman (“Appellant”) filed an appeal of the Planning Commission’s decision to approve the Project. On May 11, 2026, the Appellant provided a Supplemental Submission to City Council Appeal, and on May 21, 2026, Appellant provided a Second Supplemental Submission to City Council Appeal. All three of these appeal documents are attached to the Staff Report as Attachment “3”.

The Appeal alleges that the environmental review for the Project is insufficient, and raises concerns related to:

1. Adequacy of the environmental review provided for the Project;

2. Movement of soil from grading activities; and

3. Stormwater Basin Design.

STANDARD OF REVIEW:

The City Council’s review of this Appeal is a de novo action, meaning the City Council has full authority to modify any aspect of the action or Project to the same extent the Planning Commission could have required that modification. The Council is not bound by the prior Planning Commission decision.

CITY STAFF RESPONSE TO APPEAL
Legal Framework
260
Item8.

Pursuant to California Environmental Quality Act (“CEQA”), several types and classes of projects are exempt from environmental review, and preparation of an Initial Study (“IS”) is not required. It was determined that the Project is not categorically or statutorily exempt from CEQA due to the Project size.

If a project is not exempt from environmental review, City staff will research to see if the environmental impacts of the Project were covered in an adopted environmental document.

Because there was a prior adopted MND for a prior project on the same property, there are two relevant CEQA Guidelines. California Code of Regulations (hereinafter “Guidelines”) Section 15162 describes the circumstances under which subsequent or supplemental environmental review is required, while Section 15164 details when an addendum is permissible.

Pursuant the Public Resource Code 21166 (CEQA Guidelines Section 15162), which governs subsequent review, a lead agency (i.e. the City) may not require a new Environmental Impact Report or Negative Declaration unless, specific findings are made. If none of the conditions described in Section 15162 are triggered then the City may choose to document the environmental review under Section 15164 governing Addendums to an adopted ND/MND.

This determination is governed by the substantial evidence standard. CEQA Guidelines section 15162 requires an agency to prepare an EIR when there is substantial evidence that the changes to a project for which a negative declaration has been approved might have a significant impact not previously considered for the project as originally approved. This position is supported by the California Supreme Court in Friends of College of San Mateo Gardens v. San Mateo County Community College District (2016) 1 Cal.5th 937.

Response to Issues Raised in Appeal
I. The Addendum is the Appropriate Level of Environmental Review Appellant asserts that the Addendum to the prior MND was insufficient and that a subsequent MND or EIR should have been prepared. However, staff, along with the consultant who performed the Addendum, fully analyzed the relevant factors and determined that an Addendum was appropriate in this instance.

As part of its review of the Project, City staff evaluated whether the proposed development would result in any new or more severe impacts than those previously analyzed in the adopted MND. To assess potential hazardous material concerns, staff reviewed a Phase I Environmental Site Assessment (ESA) prepared for the Project site. The Phase I ESA evaluated historical and current uses of the property, reviewed regulatory databases, and assessed whether recognized environmental conditions were present that could indicate contamination requiring further investigation or remediation.

The Chatham Barrel Yard was declared a Superfund site in the 1980s, and has been subject to regulatory oversight primarily by the California Department of Toxic Substances Control (DTSC). The site has undergone its own CEQA review, and is subject to ongoing remediation and monitoring requirements, all 261
Item8.
of which were known at the time of the prior adopted MND for the Project, and were evaluated in the Phase 1 ESA.

Based on the findings of the Phase I ESA, staff determined that the project would not create any new significant hazardous materials impacts beyond those previously analyzed, nor did the study identify substantial new information showing that previously identified impacts would be more severe than anticipated. Accordingly, as discussed in more detail below, staff concluded that the circumstances described in CEQA Guidelines Section 15162 requiring preparation of a subsequent MND or EIR were not present. Instead, the environmental effects associated with hazardous materials could be adequately addressed through an Addendum pursuant to CEQA Guidelines 15164.

A. None of the Conditions Listed in Section 15162(a) Have Been Met Under Section 15162, “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” certain factors. These factors are discussed below.

1. No Substantial Changes to the Project Were Identified Section 15162(a)(1) would allow for a subsequent EIR or MND if “[s]ubstantial 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.”
Staff determined this trigger was not met, because the only changes to the Approved Project are the inclusion of the stormwater basin, and adjustments to the lot sizes which conform with the requirements of the underlying zoning. The proposed Project is in conformity with all other provisions of the zoning code and general plan land use designation, and the previously Approved Project.

2. No Substantial Change in Circumstances Were Identified Section 15162(a)(2) would allow for a subsequent EIR or MND if “[s]ubstantial 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.” Staff analyzed the Project under this criterion, and based on aerial views, the property appears to exist as it did when it was first approved by the City. The existing biological mitigation measures would address any impacts to vegetation, and there don’t appear to be any significant change to the existing site.

3. No New Information of Substantial Importance Was Identified 262
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Section 15162(a)(3) would allow for a subsequent EIR or MND if “[n]ew 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;
(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.

Staff determined that none of these factors apply. At the time the IS/MND was adopted, the Chatham Barrel Yard was an existing, known, state Superfund site, which has been monitored by state and local agencies since the early 1980s. An Environmental Site Assessment was prepared by Weis Environmental for the project in April of 2025, which concluded that “No features, activities, uses and/or conditions that, in our professional judgment, may indicate the presence or likely presence of hazardous substances or petroleum products that have significantly impacted the Site were identified during the completion of this assessment.”
On February 3, 2026, the Applicant provided a final draft of the Addendum for review. Issues identified during review were the current status of Monitoring Well 57 (MW57) as well as the vegetation removal that was completed without permits or mitigation. Documentation was provided which substantiated that the monitoring well had been decommissioned by the Department of Toxic Substances and Control (DTSC) on November 12, 2008, and subsequently, Well Destruction Permit No. LMON106099 was issued by the County Department of Environmental Health (DEH). Per Hargis + Associates, Inc., the work was completed on January 16, 2009 (Appendix E to Addendum). Further, the Addendum acknowledged the unpermitted removal of special status vegetation and requirement for mitigation as identified in the prior environmental document and adopted mitigation measures for the previous project.

B. The Addendum Was Sufficient and Complies with CEQA
When there has been a previously adopted MND, the factors discussed above come into play because an in-depth review of the Project has already occurred, the time for challenging that MND has expired, and the question is whether circumstances have changed enough to justify repeating a substantial portion of the process. See, Benton v. Board of Supervisors (1991) 226 Cal.App. 3rd 1467, 1479. 263
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The Phase I Environmental Site Assessment (ESA) was conducted for the Project by consultant Weis Environmental. The ESA addresses the environmental status of the site, including the adjacency to the barrel yard. The ESA recognized that it was analyzing “a parcel of real estate with respect to the range of contaminants within the scope of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)” and it performed a review of regulatory records and historical information, and performed a subject property reconnaissance before preparing the written findings.

Additionally, the most recent monitoring report for the Chatham Barrel Yard site, completed in April of 2025, states that the monitoring well nearest the Project site (33-G3) has no detectible Volatile Organic Compounds (VOCs), and the well to the north (MW-39) is at 1.3 micrograms per liter. A full copy of the annual report is located here:
https://www.envirostor.dtsc.ca.gov/getfile?filename=/public%2Fdeliverable_documents%2F671529066 5%2F2025%2006%2027_ChatPRP_April%202025_Annual%20Rpt.pdf Based on the information provided by the Applicant in the prepared draft Addendum, including substantiation that the findings listed under Section 15162 do not apply to the project, and a review of the previously adopted IS/MND and relevant mitigation measures, staff determined that a subsequent EIR or MND is not required, and the CEQA Addendum sufficiently addresses any and all potential environmental impacts that may occur as a result of the Project. Pursuant to Section 15164, public review of the Addendum is not required.

II. The Movement of Soil from Grading Activities Was Sufficiently Analyzed Another issue raised by the Appellant is the construction activities that will result from construction of the five (5) single family homes. Pursuant to the Escondido Municipal Code and Escondido Zoning Code, all construction activities are regulated by existing policies and ordinances codified in the aforementioned codes, especially noise disturbances. The information provided throughout the development review processes is consistent with information that is typically provided at this stage. Additionally, the City’s grading ordinance does require best management practices (BMPS) throughout the construction of the Project and which are enforced by the City’s stormwater division.

III. The Biofiltration Basin and Stormwater Design Was Sufficiently Analyzed As a part of the development review process, a preliminary water quality management plan is submitted and reviewed by the City’s Engineering Services. Prior to issuance of any grading permits, the Applicant will be responsible for submittal of a Final Water Quality Management Plan for review and approval which must conform to the preliminary water quality management plan. The appellant states that further review is necessary due to the potential runoff issues, and that a more detailed analysis must be done; however, given the current stage of the Project, the appropriate level of analysis was done and approved by the City’s Engineering Services.
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A. The Project’s Basin and Stormwater Infrastructure is Not “Infiltration-Oriented” Appellant bases her complaints about the Project’s stormwater infrastructure on the assertion that “the current project proposes the addition of a ‘bioretention basin’ and infiltration-oriented stormwater infrastructure as part of the subdivision design.” (Attachment “2” - Second Supplemental Submission, p. 1). This statement is incorrect, and reveals a fundamental misunderstanding of the Project’s stormwater infrastructure. In fact, the Project’s design includes a biofiltration basin that is fully lined with an impermeable liner.

In general terms, a bioretention basin is a shallow, vegetated depression that promotes natural infiltration of stormwater into native soils, filtering pollutants through engineered media. In contrast, a fully lined biofiltration basin is an impermeable, sealed system designed to filter water and redirect it into the municipal storm drain, preventing any groundwater infiltration.

Because Appellant’s arguments are all based on what would be required if the Project included a bioretention basin, they are simply not applicable to the Project as designed. If the Project had included a bioretention basin, a geotechnical analysis would likely have been required. However, since the Project included a fully lined biofiltration basin, no further study was needed.

The Project, as proposed, includes a biofiltration structural best management practice (BMP) to meet pollutant control and hydromodification management performance standards in the current MS4 permit and City of Escondido Storm Water Design Manual and Appendices.

The proposed biofiltration BMP design includes a 30-ml PVC impermeable liner to prevent stormwater from infiltrating the underlying soil. Stormwater runoff from the development is conveyed to the biofiltration BMP, treated, and discharged via the underdrain pipe to the outlet pipe, which connects to the City storm drain infrastructure.

There are two Green Street treatment features proposed to treat the off-site impervious area: a Proprietary Biofiltration unit that treats runoff from Hamilton Lane and Bernardo Ave, and a Green Street Bio Swale that receives stormwater runoff from a portion of Hamilton Lane for treatment.

B. The City Analyzed the Project’s Basin and Stormwater Infrastructure Under Current Standards Appellant is correct in her assertion that there has been a change in stormwater and groundwater protection standards since 2007. However, her assertion that the Project was analyzed pursuant to those 2007 standards is incorrect. The MS4 Stormwater permit utilized the most recent adopted standards from 2015, updated in 2018, and was reviewed and approved by the City. 265
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CONCLUSION AND RECOMMENDATION
Based on the analysis discussed throughout this staff report, staff recommends City Council adopt Resolution 2026-90, denying the appeal and upholding the decision of the Planning Commission.

Alternatively, the City Council could grant the appeal and require additional environmental review (either a full EIR or a subsequent MND), or the City Council could continue the hearing and provide staff with direction to conduct additional studies and either revise the addendum or determine whether additional review is needed.

RESOLUTION
a. Resolution No. 2026-90
b. Resolution No. 2026-90 – Exhibit “A” – Legal Description c. Resolution No. 2026-90 – Exhibit “B” – Plan Set
d. Resolution No. 2026-90 – Exhibit “C” – Initial Study/Addendum e. Resolution No. 2026-90 – Exhibit “D” – Revised Mitigation and Monitoring Reporting Program
f. Resolution No. 2026-90 – Exhibit “E” – Findings of Fact/Factors to be Considered g. Resolution No. 2026-90 – Exhibit “F” – Conditions of Approval

ATTACHMENTS
a. Attachment “1” – Planning Commission Written Public Comment b. Attachment “2” – Appeal and Supplemental Applications c. Attachment “3” – April 28, 2026 Planning Commission Staff Report d. Attachment “4” – CEQA Notice of Determination
e. Attachment “5” – Initial Study/Addendum
f. Attachment “6” - Previously adopted Mitigated Negative Declaration 266
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April 28th, 2026
City of Escondido Planning Commission
201 North Broadway
Escondido, CA 92025
Re: PL24-0067 — Hamilton Lane 5-Lot Tentative Subdivision Map Dear Chair and Commissioners,
My name is Heidi Whitman, and | live and own directly across the street from the proposed project site. | am writing to express serious concerns regarding the adequacy of the environmental review for this project.

The City is relying on a 2007 Mitigated Negative Declaration (MND) to support approval of a project in 2026. However, the circumstances surrounding this site have materially changed, and ; substantial new information has emerged that was not analyzed in the original environmental document. Under CEQA Guidelines Section 15162, this triggers the need for additional environmental review.

1. Proximity to the Chatham Barrel Yard and Updated Contamination Concerns The project site is located adjacent to the Chatham Barrel Yard, a known Superfund cleanup site with a long history of contamination and ongoing regulatory oversight. While prior documents suggest limited impact, more recent information indicates that concerns remain unresolved.

The April 2025 monitoring report indicates that contamination soil vapor has been detected along the plume boundary. Critically, no soil vapor testing has been conducted directly at the project site, despite its location at or near the edge of the plume and downgradient from the source area.

Given that soil vapor intrusion is a recognized pathway for human exposure, the absence of site-specific testing raises serious public health concerns. It is not reasonable to conclude that impacts are less than significant without fully evaluating this risk.

Additionally, there are documented community concerns regarding long-term health impacts associated with the Chatham site that have never been fully resolved. | have included testimony from community members in the record to reflect these ongoing concerns. (Below)

2. New Biological Information and Changed Site Conditions The applicant commissioned a new biological assessment in 2024, which identifies current site conditions, including the presence of 17 mature and protected trees, several of which qualify as Heritage Coast Live Oaks.

The existence of this updated study demonstrates that conditions have been reassessed nearly two decades after the origina WiND-{f no meaningful changes had occurred, such a study would not have been necessary.

Attachment "1"
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Further, City records indicate that unpermitted vegetation removal occurred in 2021, including areas previously identified for mitigation. This activity alone reflects a change in baseline environmental conditions from those analyzed in 2007.

Together, the 2024 biological study and the 2021 vegetation removal constitute new information of substantial importance under CEQA.

3. Impacts to Heritage Coast Live Oaks and Community Character The project proposes the removal of several mature trees, including some of the most prominent Heritage Coast Live Oaks on the site. These trees are located on one of the highest and most visible portions of the property and contribute significantly to the rural character of the surrounding neighborhood.

While replacement planting is proposed, it does not provide an equivalent ecological or visual impact to the loss of mature heritage trees. Treating this impact as insignificant based on a 2007 ___ analysis does not reflect current conditions or community context. _

4. Potential Cultural Resource Impacts
There are also credible concerns regarding the potential presence of Native American cultural resources on or near the site, given its proximity to Felicita Creek and known areas of historical significance. It is unclear whether this has been fully evaluated under current standards or whether appropriate tribal consultation has occurred.

This represents an additional impact category that warrants further review.

Overall, it is clear that this project presents new information and potentially significant impacts that were not adequately addressed in the 2007 MND.

Under CEQA, these circumstances require a more thorough environmental analysis. An addendum is not sufficient.
| respectfully request that the Planning Commission require a full Environmental Impact Report (EIR) to ensure that current conditions are properly evaluated and that public health, environmental resources, and community character are fully considered.

Thank you for your time and consideration.

Sincerely,
Heidi Whitman
2336 Rancho Diego Ct
Attachment "1"
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Prominent Heritage Coast Live Oaks Proposed for Removal - #3, #4 Attachment "1"
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Chatham Barrel Yard community testimony -
Hello. | grew up on 1312 Hamilton Lane and my house backed to the Chatham site. | lived there in the 80's. | went to Del Dios Middle School and San Pasquale HS and had many friends as neighbors, the majority of my friends have experienced rare, health issues, including the rarest of rare brain tumors, one requiring open heart surgery in her 30’s with no family history of heart issues, and another that just passed this last summer from colon cancer at the age of 50. They were three sisters who lived on Bernardo and backed up to the dump site. My step dad suffered from bladder cancer in his 50’s, again no family history, my next door neighbor died of a rare kidney cancer, a friend who lived next door to the three sisters | mentioned earlier also suffers from a rare brain tumor and she wasnt young woman when it was diagnosed. | myself, suffer from a thyroid disease, and my sister suffers from autoimmune disease as well. We're in our 40’s. There were only a few dozen people living around that dump site in the 70’s and 80’s. The majority of whom have come down with tumors, cancers or lifetime afflictions’... The chemicals - found in the soil are directly associated with the diseases we have uncovered. — - Sincerely,
Alison Wieseler
(425) 753-0853
Attachment "1"
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woRTH COUNTy North County Group GROUP Sierra Club San Diego SIERRA CLUB « SAN DIEGO Escondido, CA 92033
August 28, 2018
Mr. Hossein Nassiri, DTSC Project Manager
5796 Corporate Avenue
Cypress, California 90630
RE: Sierra Club North County Group comments on Five-Year Remedy Review Report for Chatham Brothers Barrel Yard, Escondido
Dear Mr. Nassiri:

The Sierra Club North County Group (NCG) represents 2,700 members in the inland North County area, including in Escondido and environs. Several of our members have contacted us about the issues at the Chatham Brothers Barrel Yard remediation. As we understand it, members of the Chatham family owned the property at 2257 Bernardo Ave, Escondido and ran a hazardous waste processing and collection business for decades. In the early 1980’s, massive pollution of the site was discovered and the facility was closed. The Chatham Barrel yard was listed as a state superfund site and emergency soil removal action was conducted. Additionally, on-site water remediation has been on-going for over 20 years.

However, in the intervening decades, the groundwater pollution has spread significantly and can now be found under Felicita County Park and many area homes. Further, the contamination is now entering Felicita Creek in a public area where the public is unwittingly exposed.

In spite of over 30 years of remedial action, much of it passive through the adoption of a passive strategy called ‘natural attenuation’, the cleanup objectives have not been met. It is clear that more proactive measures must be taken.

We have been notified that the Five-Year Remedy Review Report is underway and NCG would like to provide comments and recommendations for your consideration.

Sierra Club NCG requests the Department of Toxic Substances Control, as lead agency, take the following actions prior to certification of the Review.

1. Make a finding that, after 30 years of implementation of natural attenuation as a remedial action, the remedial objectives have not been met.

2. Direct additional proactive measures to achieve the remedial objectives, especially to stop unbated discharges into Felicita Creek.

3. Establish and timeline of performance for meeting the objectives.

Please add us to your mailing list [email protected] .

Thank you for your consideration,
Suzi Sandore, Chair
Sierra Club NCG
cc. David Gibson, Regional Water Quality Control Board
Attachment "1"
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et 2 i
FOR CITY USE ONLY f= Ee
—_— CITY OF ESCONDIDO Application Code(s) [: re
7 City Clerk Fee (Non-Refundable) q fa S ID 201 North Broadway Receipt No. ia = ESCONDIDC 0 Escondido, CA 92025 es ret cay es h o ouncil Hearing Date 4, (760) 839-4617 Planning Case File No. +o (if applicable) me

NOTICE OF APPEAL APPLICATION
Applicant Herds Whitman Phone: 18\-S12-1S50
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Mailing Address: 255 © Rancho D wi (0) Cy E Scone re oO q 20 ZW (Street) (City) (Zip)
Legal Owner: 4210 \ Whiiman Phone: (see above) (Print)
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| Property Address: Aen: 238-360 - 6-00
| (Subject of Appeal)
| | | | | |
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Is legal owner aware of this application? w Yes [ifs
Justification for appeal (May use additional paper, if necessary):

See G\tachmen*®.

Distribution:

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City Manager e =
City Clerk 5 T 2-6
Other Date
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MW/Forms/Appeal Application July 2013
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Attachment "2"
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Item8.

CITY OF ESCONDIDO
CITY COUNCIL APPEAL — PL24-0067
Hamilton Lane Residential Subdivision Project
To the Honorable Mayor and Members of the Escondido City Council, I respectfully submit this formal appeal of the Planning Commission’s approval of the Hamilton Lane residential subdivision project (PL24-0067). As a directly impacted homeowner who lives across from the proposed development site, I have serious concerns regarding the adequacy of the environmental review relied upon for approval of this project, particularly given the project’s location within the known Chatham Brothers Barrel Yard contamination plume area and the substantial changes in environmental conditions since the original environmental documentation was prepared.

One of the primary issues underlying this appeal is the City’s continued reliance on a Mitigated Negative Declaration originally prepared in 2007, nearly two decades ago. Environmental conditions, regulatory understanding, groundwater monitoring data, and surrounding land use conditions have materially changed since that time. Despite the passage of approximately 19 years, the project was advanced using an addendum rather than requiring a more comprehensive and current environmental review. In my opinion, this does not reflect the level of analysis warranted for a project within an area associated with known contamination concerns and a designated state superfund clean up. The Regional Water Quality Control Board itself acknowledged ongoing concerns regarding the Chatham plume in its October 8, 2014 Executive Officer Report. Specifically, staff noted that “the remedy had failed to limit the migration of the groundwater plume” and further stated that there were concerns that the existing natural attenuation remedy “will not restore groundwater quality within a reasonable time frame.” Given these unresolved concerns within a designated State Superfund plume area, it is difficult to understand how a project involving grading, excavation, and infiltration based bioretention infrastructure can proceed under environmental analysis that largely relies on documentation prepared in 2007.

Of particular concern is the lack of updated and site-specific soil vapor analysis tied to current conditions. Recent monitoring reports associated with the Chatham plume continue to show the presence of contaminants in nearby areas. However, there does not appear to have been a comprehensive evaluation of soil vapor or subsurface conditions in relation to the proposed grading depths, excavation activities, utility trenching, or future residential exposure pathways.

This is especially concerning given the project’s location within or adjacent to a known contamination area.

Additionally, the project proposes the removal and relocation of very large granite boulders along with extensive grading. In this region, these formations are often substantially larger below grade than what is visible at the surface, meaning their removal may require deep and disruptive excavation. The environmental documentation does not appear to meaningfully analyze how this level of subsurface disturbance could affect groundwater movement, soil stability, or contaminant migration within the plume area.

Attachment "2"
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Item8.

I am also concerned about the proposed bioretention basin and stormwater infiltration design.

The project includes plans to infiltrate stormwater into soils within or near a known contamination plume area, yet there appears to be limited analysis of whether this could alter groundwater flow patterns, mobilize contaminants, or increase migration risk to surrounding properties. This is a significant issue that warrants a more detailed and current hydrogeologic evaluation.

Beyond the environmental review itself, there are also very real construction related impacts that have not been adequately addressed. Thescale of grading, excavation, and boulder removal proposed for this site will generate significant dust, runoff, and disturbance that will directly impact neighboring properties, including my own and those of nearby residents such as Norm and Debbie Greene.

Given the site’s slope and soil conditions, there is a clear risk of sediment-laden runoff leaving the project site during grading and storm events. Without a more robust and clearly defined erosion and runoff control plan, adjacent properties could be exposed to sediment, contaminants, and drainage impacts. In addition, dust generated during excavation, particularly if soils contain contaminants, raises concerns about airborne exposure for nearby residents.

These construction phase impacts are not minor or speculative, they are a direct and foreseeable result of the proposed scope of work, and they deserve a higher level of analysis and mitigation than what was presented during the Planning Commission process.

The Planning Commission hearing included only limited discussion of these issues despite public concern. The reliance on an outdated environmental document, combined with the lack of detailed analysis regarding current subsurface conditions, contamination risks, and construction impacts, raises serious questions about whether the project has been adequately evaluated under CEQA.

For these reasons, I respectfully request that the City Council overturn the Planning Commission’s approval and require a more thorough and updated environmental review. This should include current soil vapor and subsurface investigation, evaluation of grading and excavation impacts, detailed analysis of the proposed bioretention basin, and a clear assessment of construction related impacts to neighboring properties.

Thank you for your time and consideration.

Sincerely,
Heidi Whitman
2336 Rancho Diego Ct
781-572-1550
[email protected]
Attachment "2"
274
Item8.

SUPPLEMENTAL SUBMISSION TO CITY COUNCIL APPEAL
PL24-0067 – Hamilton Lane Residential Subdivision Project To the Honorable Mayor and Members of the Escondido City Council, I am submitting this supplemental information in support of my filed appeal of the Hamilton Lane residential subdivision project (PL24-0067). This submission provides additional technical context, updated monitoring information, and relevant regulatory considerations that were not adequately addressed in the Planning Commission process or reflected in the project record. This information further supports my position that the environmental review relied upon for project approval is incomplete and does not meet the level of analysis warranted under current site conditions.

I have been in direct communication with the San Diego Regional Water Quality Control Board regarding the project and its location within or adjacent to the Chatham contamination plume area. Based on these communications, I understand that the Water Board is actively reviewing and investigating aspects of the project as they relate to groundwater quality, contamination, and stormwater infiltration. I will be submitting these communications as part of the administrative record. The involvement of the responsible regulatory agency underscores that there remains uncertainty regarding current site conditions and potential environmental risks, which warrants a full and comprehensive EIR/environmental review than what has been relied upon to date.

A central concern remains the project’s proposal to include a bioretention/biofiltration basin designed to infiltrate stormwater into underlying soils without sufficient site specific analysis of whether such infiltration is appropriate given known contamination conditions. The project application and supporting environmental documentation do not appear to include a site specific hydrogeologic evaluation, groundwater quality assessment, soil vapor investigation, contaminant migration analysis, or infiltration compatibility study that would evaluate the safety and feasibility of infiltration within or near a mapped contamination plume. This omission is significant. The San Diego Regional Water Quality Control Board has made clear that infiltration feasibility determinations must be supported by site specific technical analysis, including geotechnical evaluation, testing, and documented conclusions sufficient to support the determination. The absence of this level of analysis in the project record raises serious concerns about whether the proposed stormwater design complies with applicable regulatory expectations and adequately protects public health and groundwater quality.

Recent monitoring data further underscores the need for updated and site specific evaluation. The most recent monitoring report April 2025 monitoring report shows results that impact the site or are adjacent or close by can be found on pages 48-51. Soil Vapor Monitoring shows results of contamination (pp 10-12) from the plume at the outside edge along Felicita road, but have not been monitored near the site. The site in question is in or at the northern edge of the plumes and could be a source of soil gas vapor. Monitoring for this is something that must be done prior to building housing in this area.

Without site specific soil vapor testing and subsurface evaluation, there is no meaningful way to determine whether future residential development could be subject to vapor intrusion or other Attachment "2"
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Item8.
exposure pathways. Monitoring of these conditions is something that must be conducted prior to the construction of housing in this area.

These concerns are compounded by the project’s design, which proposes stormwater infiltration in an area where contamination has been documented but not fully characterized at the site level.

The introduction of infiltration infrastructure has the potential to alter subsurface conditions, mobilize contaminants, or change groundwater flow patterns in ways that have not been evaluated in the current environmental record. The project staff report confirms the inclusion of a bioretention basin as part of the proposed development, yet concludes that no additional environmental review is required and that reliance on an addendum to a previously adopted Mitigated Negative Declaration is sufficient. Given the presence of updated monitoring data, the lack of site specific investigation, and the nature of the proposed stormwater design, this conclusion does not appear to be supported by substantial evidence.

Under CEQA, additional environmental review is required where new information of substantial importance becomes available, where previously unexamined impacts may occur, or where existing analysis is no longer adequate due to changed circumstances. Recent monitoring data demonstrates that contamination remains present in the vicinity of the project, site specific conditions have not been evaluated, and the project introduces infiltration infrastructure that has not been meaningfully analyzed in the context of current environmental conditions. In addition, the fact that the Regional Water Quality Control Board is actively reviewing the project further supports the conclusion that environmental conditions and regulatory considerations have evolved since the original environmental document was prepared. These factors collectively indicate that reliance on a nearly 20 year old environmental document, supplemented only by an addendum, is insufficient.

For these reasons, I respectfully request that the City Council require preparation of a full Environmental Impact Report. At a minimum, such review should include current site specific soil vapor and vapor intrusion analysis, groundwater and hydrogeologic investigation, evaluation of grading and excavation impacts on subsurface conditions, detailed analysis of the proposed bioretention basin and infiltration feasibility, and an assessment of contaminant transport and potential exposure pathways associated with both construction and long term residential use.

This issue is not a minor technical deficiency but rather a fundamental question of environmental safety and adequacy of analysis. Approving a project that proposes stormwater infiltration within or near a known contamination plume, without conducting site specific investigation, introduces uncertainty and potential risk that has not been properly evaluated. At a minimum, the City should require the level of analysis necessary to ensure that future residents, neighboring properties, and groundwater resources are not adversely impacted.

Thank you for your time and consideration.

Sincerely,
Heidi Whitman
Attachment "2"
276
Item8.

Heidi Whitman <[email protected]>
Hamiton Lane project
Heidi Whitman <[email protected]> Tue, May 5, 2026 at 4:44 PM To: [email protected]
Hi Sarah,
Thank you so much for taking a look into this, really appreciate it. Myself, along with other neighbors, have serious concerns about the contamination plume and the proposed removal of very large embedded granite formations that to my understanding have not been thoroughly analyzed by the city. I'll be formally appealing the Planning Commission’s approval of the project this Thursday. There’s no immediate rush on my end, I’m more focused on making sure a complete and accurate understanding of current site conditions is considered, especially given the city's reliance on a much older environmental document from 2007 with just an addendum. I attended the planning commission hearing and there was very surface level discussion before approval (commissioners said they didn't get complaints from residents about smells etc so they concluded the Chatham plume is a non issue) but did not analyze any regional well monitoring data etc.

One of my main concerns is whether the proposed grading, excavation, and proposed bioretention basin have been evaluated against current groundwater conditions and any potential contamination, particularly given the site’s location within the Chatham plume area. The project also proposes the removal and relocation of very large embedded granite boulders (photo attached), which in this region are often significantly larger below grade than what is visible at the surface.

Neighbors have run into this issue when excavating for a pool. The extent of excavation required to remove these formations could result in substantial subsurface disturbance.

The most recent April 2025 monitoring report includes data relevant to this site and nearby areas (see pages 48–51). Soil vapor monitoring results (pp. 10–12) show contamination associated with the plume along Felicita Road, however, comparable monitoring does not appear to have been conducted on the project site. The contaminants associated with the Chatham Barrel Yard site are known to be volatile and mobile. Unlike areas that are upgradient and have been approved for development, this location appears to be downgradient and within known contamination areas.

Please let me know if there is anything I should be providing to help your review, or if there are specific aspects of the project you’d recommend highlighting from a water quality standpoint.

Thanks again for your time, I truly appreciate your guidance on this! Best,
Heidi Whitman
2336 Rancho Diego Ct
781-572-1550
On Tue, May 5, 2026 at 12:54PM Mearon, Sarah@Waterboards <[email protected]> wrote:

Hello
My supervisor forwarded your email (copied below) to me regarding a project near the Chatham Brothers waste site. I will need some time to look into the issues you have raised. Currently we do not have any involvement in the work you described. I can try to get back to you by the end of this week if that is ok. -Sarah
Hi,
I’m a resident who lives next to the proposed subdivision project at the southeast corner of Bernardo Ave and Hamilton Lane in Escondido (PL24-0067), located within/downgradient to the Chaltham waste contamination plume (superfund site) and I wanted to reach out to see if your office is aware of it or involved in any review.

From what I can tell in the City’s materials, the project includes grading, relocation of large subsurface boulders, and construction of a bioretention (infiltration) basin. The site also references existing monitoring wells and past oversight tied to the Chatham Brothers waste site.

I’m trying to understand whether there has been any recent evaluation of groundwater conditions on this site or soil vapor monitoring particularly in relation to the current status or extent of any contamination plume, whether 5/11/26, 3:50 PM Gmail - Hamiton Lane project
https://mail.google.com/mail/u/0/?ik=8cfb1f26ce&view=pt&search=all&permmsgid=msg-a:r7495118066678081407&dsqt=1&simpl=msg-a:r7495118066678081407 1/3 Attachment "2"
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infiltration (via the proposed basin) has been evaluated for compatibility with site conditions, or potential impacts from excavation or subsurface disturbance.

The City appears to be relying on an older environmental document (from 2007), and I’m not seeing anything clearly addressing current conditions or how these new site changes interact with them.

I want to confirm whether your office is aware of or has reviewed this project, any updated groundwater or contamination related analysis has been done since the April 2025 report and if this type of infiltration basin would typically require review given the site history.

I’m planning to raise this with the City as well and wanted to understand whether the Regional Board has had any involvement.

If there’s someone more specific I should be directing this to, I’d really appreciate being pointed in the right direction.

Thanks for your time, I appreciate any guidance you can provide.

Best,
Heidi Whitman
781-572-1550
2336 Rancho Diego Ct Escondido
Sarah Mearon, PG
Senior Engineering Geologist
R9 SAN DIEGO
R9 Site Restoration & Groundwater Protection | R9 Site Restoration Email: [email protected]
Phone: +1 (619) 521-3363
Regional Water Quality Control Board
2375 Northside Drive, Suite 100, San Diego CA 92108
Website: www.waterboards.ca.gov
Follow: X | YouTube | Facebook | LinkedIn
4 attachments
Hamilton_Boulder_removal.jpg
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5/11/26, 3:50 PM Gmail - Hamiton Lane project
https://mail.google.com/mail/u/0/?ik=8cfb1f26ce&view=pt&search=all&permmsgid=msg-a:r7495118066678081407&dsqt=1&simpl=msg-a:r7495118066678081407 2/3 Attachment "2"
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GiantBoulders2_HamiltonLn.jpg
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hamiltonLnboulders.jpg
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HamiltonLn_Boulder_Relocation.jpg
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5/11/26, 3:50 PM Gmail - Hamiton Lane project
https://mail.google.com/mail/u/0/?ik=8cfb1f26ce&view=pt&search=all&permmsgid=msg-a:r7495118066678081407&dsqt=1&simpl=msg-a:r7495118066678081407 3/3 Attachment "2"
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Water Boards
San Diego Regional Water Quality Control Board
April 28, 2017 Sent via E-mail
San Diego County Municipal Storm Water Copermittees
EDMUND G. BROWN J R.

GOVERNOR
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Sl'.CAl'TARY fOA
ENVIAONMF.:NlAL PROTECTION
Subject: San Diego Water Board's Expectations of Documentation To Support a Determination of Priority Development Project Infiltration Infeasibility This letter provides information to clarify the California Regional Water Quality Control Board, San Diego Region's (San Diego Water Board) expectation on the types of documentation needed to support a storm water infiltration infeasibility determination made by a Copermittee during the development planning project approval process. The San Diego Water Board would review such supporting documentation during a storm water municipal program audit of the development planning infiltration and retention requirements in the National Pollutant Discharge Elimination System Permit and Waste Discharge Requirements for Discharges from the Municipal Separate Storm Sewer Systems Draining the Watersheds within the San Diego Region (Regional MS4 Permit).

The San Diego Water Board participated in a collaborative meeting on February 14, 2017, to discuss challenges associated with the requirement for development projects to infiltrate storm water onsite, including low impact development, retention, and infiltration best management practices. Meeting participants included Copermittees, members of the Building Industry Association, members of the geotechnical engineering community and the public. As an outcome of the meeting, participants requested the San Diego Water Board provide information on the type of documentation expected in a Copermittee' project development file to support a determination that infiltration1 is not technically feasible at a development site.

Provision E.3 of the Regional MS4 Permit requires each Copermittee to use their land use and planning authorities to implement a Development Planning Program in accordance with the strategies in an accepted Water Quality Improvement Plan (WQIP).

Implementation of Development Planning Programs must include, in part, priority development project structural BMP performance requirements, which requires each priority development project to implement onsite structural BMPs to control pollutants in storm water that may be discharged from a project. Priority development projects must implement low impact development BMPs and structural controls designed to retain (e.g., infiltrate) onsite, pollutants contained in the volume of storm water runoff produced from a 24-hour 85th percentile storm event to the Maximum Extent Practical (MEP). The 1 Provision E.3.c(1 )(a) requires each Priority Development Project be required to implement LID BMPs that are designed to retain on site the pollutants contained in the volume of storm water runoff produced from a 24-hour 851 h
percentile storm event. Retain means intercept, store, infiltrate, evaporate, and evapotranspire.

HENRY ABARBANEL, PH D ., CHAIR I DAVID GIBSON, EXECUTIVE OFFICER 2375 Northside Drive Suite 100, San Diego, California 92108-2700 I www.waterboards.ca.gov/sandiego

C, RECYCLED PAPER
Attachment "2"
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Item8.

San Diego County Copermittees - 2 - April 28, 2017
Regional MS4 Permit identifies numeric design criteria and mitigation requirements, if retention or biofiltration is not technically feasible on the project site.

The San Diego County Copermittees developed a BMP Design Manual that includes a general process to evaluate infiltration feasibility on a project site based on site conditions and a professional engineer's assessment. A San Diego Water Board audit of a Copermittees' land development program would look at a Copermittees' adherence to the outlined process in the BMP Design Manual and look to the documented rationale for support of an infiltration feasibility determination.

BMP Design Manual Section 3.3.4 Developing Conceptual Storm Water Control Strategies, describes a systematic approach to determining BMP feasibility categories (i.e. full, partial, or no infiltration condition). However, additional language could be added to more clearly describe when the Copermittee expects infiltration feasibility analysis to be conducted. Additionally, Form 8 in Appendix I to the BMP Design Manual could be revised to allow for submittal of comprehensive narrative rationale supportive of a determination that infiltration is technically infeasibility. It is the San Diego Water Boards expectation that the process to determine a site's infiltration feasibility, be initiated as early as possible in the entitlement process and ideally within the environmental alternative assessment I mitigation stage, and/or project conditions of approval stage. The San Diego Water Board considers such early consideration as compliance with the MEP standard.

The systematic approach should also create a robust transparent record supporting the determinations and actions of the jurisdiction. The record for determining the feasibility of infiltration at a site should at a minimum document: 1) when in the entitlement process did a geotechnical engineer analyze the site for infiltration feasibility; 2) scope and results of testing, if conducted2, by a geotechnical engineer; 3) public health and safety requirements that affect infiltration locations; and 4) conclusions and recommendation of the jurisdiction's and applicant's geotechnical engineer. The record should also include a detailed narrative, documenting early and frequent site design discussions of potential infiltration locations between jurisdiction staff and the project geotechnical engineer, which should clearly identify, but not be limited to, the following:
• The development status of the site prior to the project application (i.e., new development with raw ungraded land, or redevelopment with existing graded conditions);
• The history of design discussions for the site proposed project, resulting in the final design determination;
2 A Copermittee retains full authority to require additional or more recent testing and/or studies to substantiate findings needed to make a determination on infiltration feasibility (See Appendix I-Form 8). In certain circumstances, a Copermittee may also be able to rely on existing current data and/or studies to support a determination on infiltration infeasibility.

Attachment "2"
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Item8.

San Diego County Copermittees - 3 - April 28, 2017
• The consideration of site design alternatives to achieve infiltration or partial infiltration on site;
• The physical impairments (i.e., fire road egress, public safety considerations, sewer lines, etc.) and public safety concerns; and
• The extent low impact development BMP requirements were included in the project site design.

During a San Diego Water Board audit, the above supporting documentation should be available in the project file as part of the Copermittee's compliance record on implementation of provision E.3.a of the Regional MS4 Permit. The record should be in sufficient technical detail to support the finding of technical infeasibility to infiltrate onsite. If a Copermittee determines that it is infeasible to infiltrate onsite, the Copermittee may allow a priority development project to utilize flow-thru treatment control BMPs to treat runoff leaving the site, AND mitigate for the design capture volume not reliably retained onsite pursuant to provision E.3.(c)(b) of the Regional MS4 Permit.

San Diego Water Board staff encourage Copermittees to continue their outreach efforts to collaborate with the San Diego Water Board and the geotechnical engineering community.

Please contact Ms. Laurie Walsh, Senior Water Resources Control Engineering of the Storm Water Management Unit at 619-521 -3373 or at
[email protected] if you have any questions. ;;;:JJw. ~ David W. Gibson
Executive Officer
DWG:jgs:law:rnm
Distribution via email:
cc via email:

Order No.

NPDES No.

Place ID
San Diego County Copermittees
Orange County Copermittees
Riverside County Copermittees
Tech Staff Info & Use
R9-2013-0001, as amended by Orders Nos. R9-2015-0001 and R9-2015-0100 CAS0109266
786088
Attachment "2"
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Item8.

San Diego County Copermittees
Richard Gilb
San Diego Co. Reg . Airport Authority
Environmental Affairs Department
P.O. Box 82776
San Diego, CA 92138-2776
[email protected]
Kim Godby
City of Coronado
101 B Street
Coronado, CA 92118
[email protected]
Helen Davies
City of Escondido
201 North Broadway
Escondido, CA 92025
[email protected]
Joe Kuhn
City of La Mesa
8130 Allison Avenue
La Mesa, CA 91941
[email protected]
Mo Lahsaie
City of Oceanside
300 North Coast Highway
Oceanside, CA 92054
[email protected]
Cecilia Padres-Tipton
City of Santee
10601 Magnolia Avenue
Santee, CA 92071 -1266
[email protected]
JoAnn Weber
County of San Diego
5510 Overland Ave., Suite 410
San Diego, CA 92123
[email protected]
Elane Lukey /James Wood
City of Carlsbad
1635 Faraday Avenue
Carlsbad, CA 92008
[email protected]
[email protected]
Mikhail Ogawa
City of Del Mar
1050 Camino Del Mar
Del Mar, CA 92014
[email protected]
Erik Steenblock
City of Encinitas
505 South Vulcan Ave
Encinitas, CA 92024-3633
[email protected]
Malik Tamimi
City of Lemon Grove
3232 Main Street
Lemon Grove, CA 91945
[email protected]
Melody Rocco
City of Poway
13325V Civic Center Drive
Poway, CA 92064
[email protected]
Karen Holman
San Diego Unified Port District
P.O. Box 120488
San Diego, CA 92112
[email protected]
Dan Goldberg/Ron Borromeo
City of Solana Beach
635 South Highway 101
Solana Beach, CA 92075
[email protected]
[email protected]
Boushra Salem
City of Chula Vista
1800 Maxwell Road
Chula Vista, CA 91911
[email protected]
John Phillips
City of El Cajon
200 East Main Street
El Cajon, CA 92020-3912
[email protected]
Chris Helmer
City of Imperial Beach
825 Imperial Beach Blvd.

Imperial Beach, CA 91932
[email protected]
Kuna Muthusamy
City of National City
1243 National City Blvd
National City, CA 91950-4397
[email protected]
Drew Kleis
City of San Diego
9370 Chesapeake Drive, Ste. 100,
M.S. 1900
San Diego, CA 92123
[email protected]
Reed Thornberry
City of San Marcos
1 Civic Center Drive
San Marcos, CA 92069
[email protected]
Cheryl Filar
City of Vista
600 Eucalyptus Avenue
Vista, CA 92084
[email protected]
Attachment "2"
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Item8.

Orange County Copermittees
Moy Yahya
City of Aliso Viejo
12 Journey, Suite 100
Aliso Viejo, CA 92656-5335
[email protected]
Amber Shah
City of Laguna Hills
24035 El Toro Rd.

Laguna Hills, CA 92653
[email protected]
Devin Slaven
City of Lake Forest
25550 Commercentre Drive, Suite100
Lake, Forest, CA 92630
[email protected]
Greg Yi
Orange County Flood Control
300 N. Flower Street, Suite 716
Santa Ana, CA 92703
[email protected]
Hossein Ajideh
City of San Juan Capistrano
32400 Paseo Adelanto
San Juan Capistrano, CA 92675
[email protected]
Riverside County Copermittees
Bill Woolsey/Bob Moehling
City of Murrieta
One Town Square
Murrieta, CA 92562
[email protected]
[email protected]
Mayra De La Torre
City of Temecula
41000 Main Street
Temecula, California 92590
[email protected]
Lisa Zawaski
City of Dana Point
33282 Golden Lantern
Dana Point, California 92629
[email protected]
Ziad Mazboudi
City of Laguna Niguel
30111 Crown Valley Parkway
Laguna Niguel, CA 92677
zmazboud i@cityoflag u nanig uel .org
Joe Ames
City of Mission Viejo
200 Civic Center
Mission Viejo, CA 92691
[email protected]
Deborah Carson
City of Rancho Santa Margarita
22112 El Paseo,
Rancho Santa Margarita, CA 92688
[email protected]
Steven Horn
County of Riverside
4080 Lemon Street, 4th Floor
Riverside, CA 92501
[email protected]
Matt Bennett
City of Wildomar
23873 Clinton Keith Rd., Suite 201
Wildomar, CA 92595
[email protected]
Mary Vondrak
City of Laguna Beach
505 Forest Avenue
Laguna Beach, California 92651
[email protected]
Christopher Macon
City of Laguna Woods
24264 El Toro Rd.

Laguna Woods, CA 92637
[email protected]
Chris Crompton
County of Orange
2301 N. Glassel! Street
Orange, CA 92865
[email protected]
Cynthia Mallett
City of San Clemente
910 Calle Negocio, Suite 100
San Clemente, CA 92673
[email protected]
Stuart McKibbin
Riverside County Flood Control
1995 Market Street
Riverside, CA 92501
[email protected]
Attachment "2"
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Item8.

SECOND SUPPLEMENTAL SUBMISSION TO CITY COUNCIL
APPEAL
PL24-0067 – Hamilton Lane Residential Subdivision Project To the Honorable Mayor and Members of the Escondido City Council, I am submitting this Second Supplemental Submission in support of my previously filed appeal and prior supplemental submission regarding the Hamilton Lane residential subdivision project (PL24-0067). This supplemental information provides additional regulatory context including correspondence with the DTSC, updated stormwater and MS4 permit details, and further technical information regarding infiltration feasibility requirements and groundwater protection standards applicable to the proposed project.

This supplemental submission is intended to further support and expand upon the concerns previously raised regarding the adequacy of the environmental review relied upon for approval of this project, particularly given the project’s location within or adjacent to the known Chatham contamination plume area and the projects inclusion of infiltration-oriented stormwater infrastructure.

I have also been in direct communication with Ahmad Aboughaida, Project Manager/Hazardous Substances Engineer with the Site Mitigation and Restoration Program, who manages the Chatham cleanup case. Based on these communications, I understand that he is actively reviewing the project as it pertains to the ongoing site cleanup efforts and the groundwater plume conditions associated with the Chatham contamination area. The involvement of the agency responsible for oversight of the cleanup effort in conjunction with the San Diego Regional Water Board further underscores that there remain active environmental and groundwater related considerations relevant to the proposed project and its stormwater infiltration design.

The current project proposes the addition of a “bioretention basin” and infiltrationoriented stormwater infrastructure as part of the subdivision design. The City staff report specifically states that the applicant submitted a request for a five-lot subdivision “with the addition of a bioretention basin to address stormwater drainage on-site.” The environmental analysis section similarly states that “[t]he Project entails a 5-lot tentative subdivision map with a bioretention basin.” The project landscape plans further identify the feature as a “BIOBASIN” and “RAIN GARDEN.”
At the same time, the City continues to rely upon a Mitigated Negative Declaration originally prepared in 2007, concluding that the prior environmental document “remains valid per CEQA.” The staff report further concludes that “no subsequent EIR or mitigated negative declaration is required.”
Attachment "2"
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Item8.

The City’s current environmental analysis repeatedly emphasizes that the prior environmental review remains sufficient, despite the substantial evolution of stormwater and groundwater protection standards since 2007. The staff report states that “the adoption of an addendum to the previously adopted Initial Study/Mitigated Negative Declaration (IS/MND) for the site… as the original environmental document prepared for the site remains valid per CEQA.” The Environmental Analysis section further concludes that “City staff concluded that the Mitigated Negative Declaration (“MND”) prepared for the prior Approved Project fully analyzed and mitigated all potentially significant environmental impacts… and therefore, no subsequent EIR or mitigated negative declaration is required.” The report additionally states that “The proposed First Addendum is appropriate pursuant to CEQA Guidelines section 15164 because only minor changes and additions to the Mitigated Negative Declaration are necessary…” These conclusions are central to the City’s reliance on the 2007 environmental framework despite the addition of infiltration-oriented stormwater infrastructure and the materially updated MS4 permit, and groundwater protection standards that now govern stormwater infiltration analysis in sensitive environmental settings.

The Fifth Term Permit, or Regional MS4 Permit, shifts the focus of the permit requirements from a minimum level of actions to be implemented by the Copermittees to identifying outcomes to be achieved by those actions.

Regulatory requirements moved from checklist/minimum-action stormwater compliance toward outcome-based water quality regulation.

This issue is particularly important because the current project proposes infiltrationoriented stormwater infrastructure in an environmentally sensitive setting involving known groundwater contamination concerns. Since approval of the original 2007 project, the Regional MS4 Permit framework has materially changed. The San Diego Regional Water Quality Control Board itself has described the 2013 MS4 Permit as a major “paradigm shift” from prior permit structures, noting that modern stormwater permits are substantially more detailed and outcome-focused than earlier generations of regulation.

Likewise, the Regional Model BMP Design Manual was specifically developed to replace earlier SUSMP-era requirements associated with the prior 2007 permit framework. These updated standards reflect a substantially more advanced regulatory understanding of infiltration feasibility, groundwater protection, and contaminant migration risks than existed when the original MND was prepared.

The County of San Diego BMP Design Manual (September 2020), prepared pursuant to updated Regional Municipal Separate Storm Sewer System (MS4) Permit requirements, specifically states that the Regional MS4 Permit requires local jurisdictions to implement LID standards through BMP design requirements. The San Diego Regional Water Attachment "2"
286
Item8.

Quality Control Board further issued guidance regarding the technical documentation required to support infiltration feasibility determinations during the entitlement and environmental review process.

These updated regulatory expectations and documentation standards did not exist in their current form when the original 2007 environmental document relied upon by the City was prepared.

Importantly, the original environmental record already acknowledged contamination related conditions associated with the Chatham plume area. The 2007 Mitigated Negative Declaration specifically references groundwater monitoring wells MW57 and MW28 and states that monitoring access must remain available to the “Chatham Brothers RP Group.” The adopted mitigation measures further required that “[n]o wells for drinking water or irrigation are to be drilled on site.”
Despite the acknowledged presence of contamination related conditions and groundwater monitoring infrastructure, the current public project record does not appear to include a plume specific infiltration analysis evaluating whether the proposed stormwater infiltration system could alter contaminant migration pathways, groundwater flow characteristics, soil vapor conditions, or long-term groundwater quality impacts.

I have not identified within the project record any site specific hydrogeologic evaluation, infiltration compatibility analysis, contaminant transport modeling, or soil vapor intrusion analysis addressing the interaction between the proposed infiltration basin and the known Chatham contamination plume area.

This omission is particularly significant because the updated MS4/LID regulatory framework reflects a substantially more advanced understanding of groundwater risk pathways and infiltration related impacts than existed in 2007.

Notably, the original 2007 MND stated that the project would comply with the “latest National Pollution Discharge Elimination System (NPDES) standards.” However, the “latest” standards applicable in 2007 are not the same as those governing stormwater infiltration today. Since that time, Regional MS4 Permit requirements, LID mandates, infiltration feasibility standards, and groundwater protection guidance have substantially evolved, particularly regarding infiltration BMPs near sensitive environmental conditions and contamination concerns.

In addition, DTSC personnel responsible for oversight of the Chatham cleanup effort, including Ahmad Aboughaida, Project Manager/Hazardous Substances Engineer with the Site Mitigation and Restoration Program, are actively reviewing the project as it relates to the groundwater plume and ongoing remediation efforts. The fact that the agency Attachment "2"
287
Item8.
overseeing the cleanup effort is currently evaluating the project further supports the need for updated environmental review and agency coordination before any approvals move forward.

Under CEQA, additional environmental review is required where changed circumstances or new information of substantial importance demonstrates that prior environmental analysis may no longer adequately evaluate current environmental conditions or project impacts.

The combination of updated MS4 regulatory requirements, the project’s proposed infiltration-oriented bioretention basin, the acknowledged presence of contaminationrelated conditions and groundwater monitoring wells, and the apparent absence of a plume specific infiltration analysis collectively raises serious questions regarding whether reliance on a nearly 20-year-old environmental framework remains adequate for this project. As a copermittee under the Regional MS4 Permit, the City is required to implement applicable stormwater, Low Impact Development (LID), and infiltration requirements through its land use and project approval processes.

For these reasons, I respectfully request that the City Council require preparation of a full Environmental Impact Report, or at minimum require comprehensive updated technical review addressing infiltration feasibility, groundwater quality, contaminant migration pathways, hydrogeologic impacts, soil vapor and vapor intrusion potential, and the interaction between the proposed bioretention basin and the known Chatham plume area.

This issue is not a minor technical deficiency but rather a fundamental question regarding the adequacy of environmental review and whether current groundwater protection standards have been meaningfully applied to a project proposing stormwater infiltration within or adjacent to a known contamination plume area.

Thank you for your time and consideration.

Sincerely,
Heidi Whitman
References / Citations
Hamilton Lane Project Application and Staff Report, PL24-0067 (April 28, 2026) County of San Diego BMP Design Manual (September 2020)
https://www.sandiegocounty.gov/content/sdc/dpw/watersheds/DevelopmentandConst ruction/BMP_Design_Manual.html
Attachment "2"
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Item8.

Heidi Whitman <[email protected]>
Time Sensitive: Hamilton Lane Project - Chatham Plume / Infiltration Concerns Heidi Whitman <[email protected]> Fri, May 15, 2026 at 10:52 AM To: "Aboughaida, Ahmad@DTSC" <[email protected]> Hi Ahmed,
Here is the link to the Planning Commission agenda packet for the project, the project materials begin on page 13. https://mccmeetings.blob.core.usgovcloudapi.net/escondidca-pubu/MEET-Packet-68a9f7e5df1b4686a3d86cf849508c 8b.pdf
Thanks for taking the time to review this. Really appreciate your willingness to take a look given the ongoing DTSC oversight of the Chatham site and the potential concerns associated with the proposed project given its location within the plume.

From my understanding of regional and state guidelines, California stormwater guidance consistently treats proposed stormwater infiltration basins near contaminated groundwater plumes as requiring heightened scrutiny and a site specific feasibility analysis which I do not see in the public project file. I attended the planning commission hearing as well and there was no discussion of this proposed infiltration bio basin as it pertains to the plume and to long term remediation clean up efforts. In addition to the infiltration and plume compatibility concerns, my appeal also raises broader issues regarding the project’s reliance on a 2007 environmental document despite substantially updated environmental conditions. Stormwater and infiltration guidance in California and at the regional level has evolved significantly since the 2007 environmental review, especially regarding groundwater protection, infiltration feasibility, and evaluation of contamination risks associated with infiltration BMPs, including current plume oversight, soil vapor considerations.

Additionally, multiple large scale embedded boulders are proposed to be removed and relocated. In this area, large granite boulder formations often extend well below grade and require significant excavation and disturbance. A neighbor in the surrounding community could not proceed with excavating a pool for this reason. Removal of these boulders could alter the contamination plume flow and affect nearby properties. No hydrogeologic analysis or groundwater flow evaluation is referenced in the project application as it pertains to the plume. As an impacted resident directly across from this proposed project, myself and neighbors surrounding the site have serious concerns about the lack of record and analysis.

Thanks again and please let me know if there is any additional information or documents that would be helpful as you review. :)
Best,
Heidi Whitman
(781) 572-1550
On Thu, May 14, 2026 at 10:24AM Aboughaida, Ahmad@DTSC <[email protected]> wrote:

Hi Heidi,
Thank you for your email. Do you happen to have a link to the project workplans for this new development so that I can discuss it with my team? To my knowledge, DTSC was not notified of this development. Thanks, Ahmad Aboughaida
Project Manager/Hazardous Substances Engineer
Site Mitigation & Restoration Program
[email protected]
5/21/26, 12:50 PM Gmail - Time Sensitive: Hamilton Lane Project - Chatham Plume / Infiltration Concerns https://mail.google.com/mail/u/0/?ik=8cfb1f26ce&view=pt&search=all&permmsgid=msg-a:r5336611675830873479&dsqt=1&simpl=msg-a:r5336611675830873479 1/2 Attachment "2"
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Item8.

Department of Toxic Substances Control
California Environmental Protection Agency

From: Heidi Whitman <[email protected]>
Sent: Tuesday, May 12, 2026 1:33 PM
To: Aboughaida, Ahmad@DTSC <[email protected]> Subject: Time Sensitive: Hamilton Lane Project - Chatham Plume / Infiltration Concerns Hi Mr. Aboughaida, Sarah Mearon with the Regional Water Quality Control Board suggested I reach out to you regarding the proposed Hamilton Lane residential project in Escondido, given your role managing the Chatham cleanup case and the time Hi Mr. Aboughaida,
Sarah Mearon with the Regional Water Quality Control Board suggested I reach out to you regarding the proposed Hamilton Lane residential project in Escondido, given your role managing the Chatham cleanup case and the time sensitivity of the project approval.

I recently filed an appeal of the project with the City of Escondido and wanted to provide the materials for your reference. My concerns primarily relate to the project’s proposed grading, large embedded boulder formation removal and proposed bioretention basin designed for on site stormwater infiltration in proximity to the Chatham groundwater plume area and ongoing cleanup site. Based on my review of the public project record, I was unable to identify site specific groundwater, soil vapor, contaminant migration, or infiltration compatibility analysis evaluating whether the proposed development and infiltration infrastructure are appropriate under current site conditions or compatible with longterm remediation considerations. In speaking with nearby residents, I also know there are broader community concerns regarding potential impacts associated with development, runoff and infiltration activities in and around the plume area and potential risk to nearby residents and properties.

I also wanted to ask whether DTSC has been consulted or provided input regarding the project’s proposed infiltration infrastructure and residential use in relation to the active cleanup area. I’ve attached my appeal and supplemental materials for your reference in case they are helpful as part of DTSC’s ongoing oversight of the cleanup case.

Thank you for your time and consideration, and please let me know if there is any additional information I can provide.

Best regards,
Heidi Whitman
2336 Rancho Diego Ct
781-572-1550
5/21/26, 12:50 PM Gmail - Time Sensitive: Hamilton Lane Project - Chatham Plume / Infiltration Concerns https://mail.google.com/mail/u/0/?ik=8cfb1f26ce&view=pt&search=all&permmsgid=msg-a:r5336611675830873479&dsqt=1&simpl=msg-a:r5336611675830873479 2/2 Attachment "2"
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Item8.

STAFF REPORT
DATE: April 28, 2026
PL24-0067 Hamilton Lane 5 Lot Tentative Subdivision Map PROJECT NUMBER / NAME: PL24-0067 Hamilton Lane 5 Lot Tentative Subdivision Map REQUEST: Approval of a Tentative Subdivision Map to subdivide a 6.02-acre parcel into five (5) lots, with a General Plan Designation of Estate I (E1) and a Zoning Designation of Residential Estates (RE-40; 40,000 square-foot minimum lot sizes) . The Project includes on-site improvements related to grading and stormwater, and off-site improvements including but not limited to: sidewalk, curb, and cutter, and other standard frontage improvements. The request also includes consideration of the environmental document prepared for the Project.

PROPERTY SIZE AND LOCATION: The 6.02-acre site is
located on the southeast corner of Bernardo Avenue and
Hamilton Lane and is addressed at 0 Hamilton Lane,
Escondido, CA 92029 238-
360-68-00)
APPLICANT: Masson & Associates
GENERAL PLAN / ZONING: Estate I (E1)/Residential
Estates (RE-40; 40,000 square-feet minimum lot sizes)
PRIMARY REPRESENTATIVE:

Associates
DISCRETIONARY ACTIONS REQUESTED: Tentative Subdivision Map PREVIOUS ACTIONS: City Council approved Ordinance 2007-11 and Resolution No. 2007-58 for an Annexation, Prezone, Tentative Subdivision Map, and Mitigated Negative Declaration (2005-06-AN, 2005-46-PZ, Tract 931, ER 2005- 33) to bring the parcel into City limits, and subdivide the parcel into five (5) lots. The City Council approved an Extension of Time (SUB17-0022) which subsequently expired December 6, 2021.

CEQA RECOMMENDATION: Adoption of an Addendum to the previously adopted Mitigated Negative Declaration CEQA Guidelines Section 15164 (Addendum to an EIR or Negative Declaration) STAFF RECOMMENDATION: Approval of the Project, subject to the Conditions of Approval REQUESTED ACTION: Approve Planning Commission Resolution No. 2026-03 CITY COUNCIL HEARING REQUIRED: ___YES _X_NO
REPORT APPROVALS: Dare DeLano, Assistant City Attorney
X Veronica Morones, Assistant Director of Development Services 13 Attachment "3"
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Item8.

BACKGROUND
& Associates filed an application for a five (5) lot
Tentative Subdivision of a 6.02-acre parcel located at the southeast corner of Hamilton Lane and Bernardo Avenue (APN 238-360-68-00) . The Property has a General Plan land use designation of Estate I (E1) and a zoning designation of Residential Estates (RE-40: 40,000 square-foot minimum lot sizes) (see Attachment 1 Aerial, General Plan land use, and zoning map). The Property is surrounded by single-family residential uses to the north, east, south, and west, with the northern, eastern, and southern borders of the property abutting unincorporated San Diego County property.

Previous development proposal:

On June 6, 2007, City Council approved the Annexation, Pre-zone, Tentative Subdivision Map, and adopted the Mitigated Negative Declaration prepared for a previous project at this location, with a language update to the resolution requested by The San Diego Local Area Formation Commission (LAFCO) adopted on June 4, 2008 . The Tentative Subdivision Map for the project (TR 931) was set to expire on June 2, 2010; however, state map extensions extended the expiration date to June 6, 2017. The project proponent filed an extension of time request prior to the 2017 expiration date, and City Council approved a 3-year extension on July 19, 2017 under Resolution No. 2017-97, setting the expiration to June 6, 2020. The California Governor extended certain qualifying subdivisions under a state of emergency declared due to the COVID-19 pandemic (CA Govt Code Section 65914.5), which granted an additional 18 months to any tentative map approved prior to March 4, 2020, which set the new expiration date for the 2007 approved map to December 6, 2021. However, the City did not receive any subsequent extension of time requests, and the map subsequently expired at the end of 2021.

Unpermitted vegetation removal:
property owner for weed
abatement under case C21-0785. Following issuance of this notice, the Code Officer completed a reinspection on June 14, 2021, and noted that all vegetation had been removed from the site. The code case was subsequently closed; however, no mitigation was purchased or Vegetation Removal Permit (VRP) obtained for the removal of the .02 acres of Coastal Sage Scrub or 3.06 acres of Non-Native Grassland previously identified for mitigation in the adopted Mitigation Monitoring and Reporting Program (MMRP).

Per Escondido Zoning Code Article 55 Section 33-1068.B(b)(1), a separate Vegetation Removal Permit (VRP) is not required when the Project is subject to discretionary action, however, the requirement for the previously identified mitigation remains in effect per the prepared Addendum and updated MMRP for the current Project, and is conditioned under Condition of Approval E.g BIO-1 and BIO-2.

SUMMARY OF REQUEST
The Applicant submitted a request for a five (5) Lot Tentative Subdivision for the future development of five (5) single-family homes with the addition of a bioretention basin to address stormwater drainage on-site. The request also includes the adoption of an addendum to the previously adopted Initial Study/Mitigated Negative Declaration (IS/MND) for the site to address the minor changes to the Project from the previously Approved Project, as the original environmental document prepared for the site remains valid per CEQA. 14 Attachment "3"
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Item8.

Per the Escondido Zoning Code Article 6 Table 33-98(a), the minimum lot size required for the property is 40,000 square-feet and the permitted use of the property is single-family residential, with an average lot width of 150 feet, and minimum street frontage of 20 feet (or connected to a public street by a permanent access easement). A copy of the proposed tentative map is included in the staff report (Attachment 2 Tentative Map), and the table below identifies the required development standards for the site required standards.

SUPPLEMENTAL DETAILS OF REQUEST
Standard

1. Property Size: 6.02 gross acres /5.70 net acres

2. Number of Lots: 5
Minimum Required by the R-E zoning district Proposed

3. Lot Size: 40,000 square-foot (sq. ft.) net 40,192 sq. ft. -54,014 sq. ft. net

4. Lot Width: 150 feet (average) 150+ feet (average)

5. Density: 0-15% slopes: 1 dwelling unit (du) / 1 acre (ac) 15-25% slopes: 1 du/2-ac
25-35% slopes: 1du/4-ac
35%+ slopes: 1du/20-ac
Total allowable = 0.99 du/ac
Total proposed = 0.83 du/ac

6. Setbacks: a. Front
Yard:
25 feet 25 feet
b. Rear
Yard:
20 feet 20 feet
c. Side
Yard:
10 feet 10 feet

7. Open Space /
Landscaping:
1 tree per lot
1 street tree per 30 linear feet of street frontage
1 tree per lot
1 street tree per 30 linear feet
of street frontage (total: 41
street trees)

PROJECT ANALYSIS

1. General Plan Conformance:
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a. The City is taking steps to encourage, promote, and facilitate the development of housing consistent with policies 1.1 and 2.1 of the Housing Element of the General Plan, while section 65584. No Net Loss Law (Government Code section 65863) ensures development - and moderate-income
households. In general, jurisdictions cannot approve new housing at significantly lower densities or at different income categories than was projected in the Housing Element without making specific findings and identifying other sites that could accommodate these units and affordability val. The soresidential density or is approved at a lower residential density than shown in the Housing Element . The Project site is identified in the Housing Element to accommodate a portion of the regional housing need. The estimated dwelling unit capacity on the Project site is as follows:

Very-low Low Moderate Above Moderate
0 0 0 5
The Project does not reduce the density of the site below what was projected in the Housing Element for the identified income category; the Housing Element shows a site capacity of 5 abovemoderate income units, which is consistent with the Project.

Very-low Low Moderate Above Moderate
Sites
Inventory
capacity for
Project site
0 0 0 5
Proposed
Units
0 0 0 5
Change in
units +/ (-) n/a n/a n/a 0
The proposed residential density is consistent with the Housing Element, and the remaining sites identified in the Housing Element are adequate to meet the requirements of Government Code 16 Attachment "3"
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Section 65583.2 and to accommodate the City's share of the regional housing need pursuant to Section 65584.

The proposed Project complies with General Plan Housing Policies 1.1 and 1.4, which state that the City should aim to expand the stock of all housing while preserving the health, safety, and welfare of residents to maintain fiscal stability of the City and channel residential growth to areas where the concurrent provision of services and facilities, including schools, parks, fire and police protection and street improvements can be assured. The proposed Project adds housing stock to the City within a developed area that can be serviced by nearby infrastructure, community protection agencies, and educational facilities. Any deficiencies in local infrastructure have been addressed through the application of development fees conditioned as a part of the Project. b. Density
The Project site may yield up to 1 dwelling unit per acre based on the slope categories across the property. As shown in the Supplemental Details of Request dwelling units per acre (5 units/6.02 acres), which is consistent with the General Plan allowances for Estate I properties with majority slopes of 0-15%.
c. Land Use and Community Form
Per the Land Use and Community Form element of the General Plan, the Estate designation accommodates detached single-family homes on large lots. This designation applies to areas that are on the edge of urban development, or in areas that are already characterized by an estate development pattern. The subject property is surrounded by estate residential development within the City to the west, and borders property within the County to the north, east, and south, which is developed in a similar single-family residential pattern.

The proposed setback of building pads from the street and conceptual landscaping plan follows the recommended urban form characteristics for the Estate I designation as detailed in Figure II-6 of the Land Use and Community Form element of the General Plan. The proposed private road easement is consistent with the recommendation to provide informal streets with rustic character in the area.

Per Land Use and Community Form Goals and Policies, Community Character Goal 1, Policy 1.1, new development should serve to reinforce the C -
intensity development within the downtown area and lower-intensity development in outlying areas; and new development should be compatible with the existing surrounding land uses. The proposed Project is surrounded by low-intensity, larger-lot single-family development, both within the incorporated and unincorporated areas.

Per Community Character Policy 1.5, the City should maintain its single-family residential development pattern, except in locations such as downtown and along major transportation corridors and around commercial and public activity centers. The proposed Project is consistent with this policy, as the property is not located in a commercial or major transportation corridor area.
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2. Zoning Conformance:

Per Article 6 (Residential Zones) of the Escondido Zoning Code (EZC), the estate residential (R-E) zone is established to provide a rural setting for family life in single-family detached dwellings. Provisions are made for maintenance of limited agricultural pursuits as well as those uses necessary and incidental to singlefamily living. The Project anticipates the future construction of single-family residences on large lots, and each lot is designed to accommodate all required development standards of the estate residential zone.

While the Project does not include plotting of residential units, the Project includes pad areas with front, side, and rear setbacks labeled, which demonstrate zoning code conformance for future development onsite.

Pursuant to Article 64 (Design Review), the future design of the homes is subject to City staff design review, at which time City staff will review the proposed architectural designs, landscape plans, and other on-site improvements that are regulated under the aforementioned Article. This item is included in the Conditions of Approval E.d attached as Exhibit F to Resolution 2026-03.

3. Climate Action Plan Consistency:

The Applicant completed the Climate Action Plan (CAP) Consistency Checklist for the Project, and based on the screening criteria (36 single family dwellings), the Project does not exceed the established threshold; and therefore, is screened from further CAP analysis.

4. Site Design
a. Grading, topography, retaining wall, and fencing:

The Project requires minor grading; however, the proposed cut and fill slopes do not exceed 10 feet, as permitted administratively under Article 55 (Grading and Erosion Control) of the EZC. Per the proposed grading plan for the Project, the elevation of the site ranges from 640 to approximately 656 and the proposed pad elevations range from 642 to 659.50. Proposed cut slopes are 8,700 cubic yards, and fill slopes are 8,700 cubic yards, representing a balanced grading site.

Based on the proposed grading plan, no soil would be imported or exported to/from the site. b. Project Access and Circulation:

Primary access to Lots 2 through 5 would be from a 28-foot-wide private road easement off of Hamilton Lane, with Lot 1 taking access from Bernardo Avenue. The private road easement and fire hammerhead at the terminus of the road
(HOA), as provided in the Conditions of Approval for the Project. The Project would also construct curb and gutter and sidewalks along Bernardo Avenue and Hamilton Lane adjacent to the site, and along the west side of the private road easement.
c. Building Orientation:
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The plotted pads shown on the proposed civil plans for the Project demonstrate the proposed buildable area for the future single-family residences. All future residential home construction will be subject to the provisions of the zoning code and applicable development standards provided therein. Proposed building elevations and orientation will be subject to City staff Design Review prior to building plan approval as denoted in Condition of Approval E.d of Exhibit F to Resolution 2026-03.
d. Open Space and Landscaping
Per the preliminary landscaping plan for the Project ( -03), the Project would include 41 15-gallon street trees planted along Bernardo Avenue, Hamilton Lane, and the proposed private road easement, as required by Article 62 (Water Efficient Landscape Regulations) of the EZC for single-family developments (1 street tree per 30 feet of street frontage).

Additionally, the Project would preserve 9 total existing oak trees on site, and mitigate for the Coastal Sage Scrub previously removed from the site without the required Vegetation Removal Permit and mitigation credit purchase, as conditioned (see Conditions of Approval Section E Mitigation Measures - BIO-1 within Resolution 2026-03). e. Parking:

Parking for the proposed Project shall be consistent with EZC Article 39 (Off-Street Parking) for single-family dwellings, which requires two (2) covered parking spaces per single-family residence.

Additionally, no parking will be permitted along the eastern boundary of the private road easement so as to accommodate Fire Department access.

5. Hamilton Lane Storm Drain Basin Ordinance 91-26
The City previously adopted City Council Ordinance 91-26 on July 17, 1991, establishing a drainage basin in the vicinity of Hamilton Lane and requiring reimbursement to the City for previously constructed drainage improvements which protect a number or properties in the area from flooding. Both proposed lots 1 and 2 are subject to this fee, which is invoiced at $39,236 per acre. This fee is further subject to an 8% increase on July 1st of each year. The current calculated total for the Project is $82,396, as conditioned under Exhibit F to Resolution 2026-03, Engineering Condition of Approval G Repayments and Fees - Item #2.

ENVIRONMENTAL ANALYSIS
Pursuant to CEQA, when taking subsequent discretionary actions in furtherance of a project for which a Mitigated Negative Declaration has been adopted, the lead agency is required to review any changed circumstances or new information to determine whether any of the circumstances under Public Resources Code section 21166 and CEQA 19 Attachment "3"
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Guidelines section 15162 require additional environmental review. City staff concluded that the Mitigated Negative ior Approved Project fully analyzed and mitigated all potentially significant environmental impacts, if any, that would result from the approval of the Project, and therefore, no subsequent EIR or mitigated negative declaration is required. On that basis, the Applicant prepared an Addendum for the changes, pursuant to CEQA Guidelines section 15164 ( C 4).

City staff evaluated the current Project, and all elements of the changes, in light of the standards for subsequent environmental review outlined in Public Resources Code section 21166 and CEQA Guidelines section 15162. The Project entails a 5-lot tentative subdivision map with a bioretention basin. City staff conclude the drafted environmental document, the First Addendum, may be used to fulfill the environmental review requirements of the current Project. The proposed First Addendum is appropriate pursuant to CEQA Guidelines section 15164 because only minor changes and additions to the Mitigated Negative Declaration are necessary to address the Project changes and no circumstances exist calling for the preparation of a subsequent or supplemental MND pursuant to CEQA Guidelines sections 15162 and 15163. The proposed First Addendum concluded that there are no substantial changes to the circumstances under which the proposed Project is undertaken that would require major revisions to the adopted MND. There is no new information of substantial importance which was not known or could not have been known at the time the MND was adopted that shows the proposed Project would have significant effects not discussed previously; a substantial increase in severity or 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 which are considerably different from those analyzed in the adopted MND which would substantially reduce one or more significant effects on the environment.

The Project would not result in new or more severe impacts beyond those addressed in the adopted MND, and would not meet any of the conditions requiring further environmental review under State CEQA Guidelines sections 15162 and 15163. Therefore, not further analysis is required.

The adopted MND prepared for the Approved Project in this location has been attached for consideration by the Planning Commission as required by Section 15164(d) of the State CEQA Guidelines (Attachment 3 Adopted MND for the Approved Project).

PUBLIC NOTICE/PUBLIC INPUT
Pursuant to Section 33-1300 of Division 6 (Public Hearings, Notices, Fees, and Appeals) in Article 61 (Administration and Enforcement) of the Escondido Zoning Code, public notice was provided through the following methods:

Times-Advocate: The Notice of Public Hearing was published in the Times-Advocate on Thursday, April 16, 2026.

Mailings: The Notice of Public Hearing was mailed out to approximately 76 property owners within a 500-foot radius of the subject property with prepaid postage on Monday, April 13, 2026.

On-site posting: The Applicant posted a Notice of Public Hearing on the Project site on Saturday, April 11, 2026, for a period of 17-days.

Public Comments
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To date, the City has received two (2) public comments regarding the Project, one as a general inquiry and the other related to density and traffic concerns, which are included as Attachment 5 to this report. Both residents have been provided the requested information regarding the Project.

CONCLUSION AND RECOMMENDATION
The Project consists of a Tentative Subdivision Map to create 5 parcels on 6.02 gross acres of residentially zoned property. As provided in this staff report, the Project complies with the provisions of the Escondido Zoning Code The Project would facilitate housing development on a currently vacant parcel, and assist with the City fulfilling its Regional Housing Needs Allocation (RHNA).

Motion as recommended by City staff: Adopt Resolution No. 2026-03 approving the Project, as conditioned and adopt the First Addendum prepared for the Project.

ATTACHMENTS

1. Aerial, General Plan, and Zoning Map

2. Tentative Map Design

3. Adopted Mitigated Negative Declaration prepared for the Approved Project (ER2005-33)

4. Draft Planning Commission Resolution No. 2026-03 including Exhibits A, B, C, D, E, and F Legal Description
Landscape and Civil Plan Set
C First Addendum to the adopted MND prepared for the Approved Project Revised Mitigation Monitoring and Reporting Program
E Factors to be considered/Findings of Fact
F Conditions of Approval

5. Public Comments
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PREPARED BY: M A S S O N ASSESSOR'S PARCEL NO: LEGAL DESCRIPTION: OWNER/APPLICANT: VICINITY MAP PROJECT DESCRIPTION ROBERT D'AMARO LEE DURAN DATE 11/6/2025 11/6/2025 DATE Attachment "2" 25 Attachment "3"
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PREPARED BY: M A S S O N ASSESSOR'S PARCEL NO: LEGAL DESCRIPTION: OWNER/APPLICANT: VICINITY MAP PROJECT DESCRIPTION Attachment "2" 26 Attachment "3"
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PREPARED BY: M A S S O N ASSESSOR'S PARCEL NO: LEGAL DESCRIPTION: OWNER/APPLICANT: VICINITY MAP PROJECT DESCRIPTION Exhibit B Attachment "2" 28
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ATTACHMENT 4
Planning Commission
Hearing Date: April 28, 2026
Effective Date: May 11, 2026
PLANNING COMMISSION RESOLUTION NO. 2026-03

A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF

ESCONDIDO, CALIFORNIA, ADOPTING THE ENVIRONMENTAL

DOCUMENT AND REVISED MITIGATION MONITORING AND

REPORTING PROGRAM PREPARED FOR THE PROJECT, AND APPROVE A FIVE (5) LOT TENTATIVE SUBDIVISION MAP IN THE RESIDENTIAL ESTATE 40,000 (RE-40) ZONE
APPLICANT:

CASE NO: PL24-0067
WHEREAS, , Planning Case
No. PL24-0067 constituting a request for a Tentative Subdivision Map for the subdivision of one existing lot into five (5) lots ( on a 6.02 gross acre site located at 0 Hamilton Lane (APN 238-360-68-00), with the Estate (E1) General Plan Land Use Designation, in the Residential Estate 40,000 (RE-40) Zone; and
WHEREAS, the subject property is all that real property described in Exhibit "A which is attached hereto and made a part hereof by this reference as though fully set forth herein ; and WHEREAS, the Application was submitted to, and processed by, Planning Services of the Development Services Department in accordance with the rules and regulations of the Escondido Zoning Code and the applicable procedures and time limits specified by the Permit Streamlining Act (Government Code section 65920 et seq.) and the California Environmental Quality Act (Public Resources Code section 21000 et seq.) ; and
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ATTACHMENT 4
WHEREAS, Tentative Subdivisions are permitted subject to review and approval of a Tentative Subdivision Map, subject to the rules and regulations of the California Subdivision and in accordance with Chapter 32 (Subdivisions) of the Escondido Municipal Code; and WHEREAS, a Tentative Subdivision Map is required for the subdivision of one existing parcel into five (5) lots within the RE-40 zoning district; and
WHEREAS, pursuant to CEQA and the CEQA Guidelines (Title 14 of California Code of Regulations, Section 15000 et. seq.), the City is the Lead Agency for the Project, as the public agency with the principal responsibility for approving the proposed Project; and
WHEREAS, on June 6, 2007, the City Council adopted an Initial Study/Mitigated Negative Declaration (IS/MND) for a project constituting a 5-lot subdivision on the site (City Log No. ER 2005-33) ; and,
WHEREAS, on June 6, 2007, the City Council adopted the Prior Project, and subsequently on December 6, 2021, -lot Tentative Subdivision Map expired; and, WHEREAS, pursuant to CEQA, when taking subsequent discretionary actions in furtherance of a project for which an MND has been adopted, the lead agency is required to review any changed circumstances to whether any of the circumstances under Public Resources Code section 21166 and CEQA Guidelines Section 15162 require additional environmental review; and, WHEREAS, City staff evaluated the environmental impact of the proposed modification to the Project in light of the standards for subsequent environmental outlined in Public Resources Code Section 2166 and CEQA Guidelines section 15162; and,
WHEREAS, based on this evaluation, staff concluded that the MND had fully analyzed and mitigated, in compliance with CEQA, all potentially significant environmental impacts, if any, that would result from the Project modifications, that the impacts to the environment as a result of the modifications 66 Attachment "3"
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ATTACHMENT 4
are consistent with and would not create substantial new or increased impacts beyond those that were evaluated in the MND, and that, therefore, no subsequent EIR or mitigated negative declaration is now required; and
evaluation of the environmental impact of said modifications, Applicant prepared an Addendum to the MND pursuant to CEQA Guidelines section 15164; and WHEREAS, pursuant to CEQA Guidelines Section 15164, an addendum need not be circulated for public review;
WHEREAS, Planning Services studied the Application, performed necessary investigations, prepared a written report, and hereby recommends approval of the Project as depicted on the plan set shown in Exhibit "B", which is attached hereto and made a part hereof by this reference as though fully set forth herein; and
WHEREAS, City staff provided public notice of the application in accordance with City (Article 61, Division 6) and State public noticing requirements; and WHEREAS, on April 28, 2026, the Planning Commission held a duly noticed public hearing as prescribed by law, at which time the Planning Commission received and considered the reports and recommendation of Planning Services and gave all persons full opportunity to be heard and to present evidence and testimony regarding the Project. Evidence was submitted to and considered by the Planning Commission, including, without limitation:
a. Written information including plans, studies, written and graphical information, and other material, submitted by the Applicant;
b. Oral testimony from City staff, interested parties, and the public; 67 Attachment "3"
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ATTACHMENT 4
c. The staff report, dated April 28, 2026, with its
on the Project, which is incorporated herein as though fully set forth herein; and d. Additional information submitted during the public hearing; and WHEREAS, the public hearing before the Planning Commission was conducted in all respects as required by the Escondido Municipal Code and the rules of this Planning Commission.

NOW, THEREFORE, BE IT RESOLVED by the Planning Commission of the City of Escondido that:

1.The above recitations are true and correct.

2. The Planning Commission, in its independent judgement, has determined the Project to have no new significant environmental impacts and no increase in severity of impacts previously identified in the adopted Mitigated Negative Declaration, and therefore an Addendum to the MND is sufficient in accordance with CEQA Guidelines Section 15164, and in accordance generally with the California Environmental Quality Act (Public Resources Code Section 21000 et. seq.). The Planning Commission has reviewed and considered the adopted MND and First Addendum
including the revised Mitigation Monitoring and Reporting Program, attached hereto as prepared for the Project and finds that those documents taken together contain a complete and accurate reporting of all the environmental impacts associated with the revised Project. The Planning Commission further finds that the First Addendum and administrative record have been completed in compliance with CEQA and the State CEQA Guidelines, and that the findings related to the MND and First

3. Based upon the evidence submitted and as demonstrated by the analysis included in the First Addendum, which is attached hereto as C , none of the conditions 68 Attachment "3"
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ATTACHMENT 4
described in Section 15162 or 15163 of the CEQA Guidelines calling for the preparation of a subsequent or supplemental EIR or negative declaration have occurred, specifically:
a. There are no substantial changes proposed in the Project which would require major revisions of the previous environmental document due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects. b. Substantial changes have not occurred with respect to the circumstances under which the Project is undertaken which would require major revisions of the previous environmental document due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.
c. There is no 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 environmental document was adopted, that shows any of the following:
i. The Project would have one or more significant effects not discussed in the previous environmental document;
ii. Significant effects previously examined would be substantially more severe than shown in the previous environmental document; iii. Mitigation measures 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
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ATTACHMENT 4
iv. Mitigation measures or alternatives which are considerably different from those analyzed in the previous environmental document would substantially reduce one or more significant effects on the environment, but the Project proponents decline to adopt the mitigation measure or alternative.

3. After consideration of all evidence presented, and studies and investigations made by the Planning Commission and on its behalf, the Planning Commission makes the following substantive findings and determinations, attached E
considered. In accordance with the Findings of Fact and the foregoing, the Planning Commission reached a recommendation on the matter as hereinafter set forth.

4. The Application to use the Property for the Project, subject to each and all of the conditions hereinafter set forth in Exhibit F is hereby approved by the Planning Commission. The Planning Commission expressly declares that it would not have approved this Application except upon and subject to each and all of said conditions, each and all of which shall run with the land and be binding upon the Applicant, the owner, and all subsequent owners of the Property, and all persons who use the Property for the use permitted hereby.

6. The development plans for the Project are on file in Planning Services of the Development Services Department and are available for inspection by anyone interested herein, and the development plans are incorporated herein by this reference as if they were fully set forth herein. The Project is conditionally approved as set forth on the Application and Project drawings, all designated as approved by the Planning Commission, and which shall not be altered without the express authorization by Planning Services. Any deviations from the approved development plans shall be reviewed by the City for substantial compliance and may require amendment by the appropriate hearing body. 70 Attachment "3"
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ATTACHMENT 4
BE IT FURTHER RESOLVED that, pursuant to Government Code section 66020(d)(1):

1. NOTICE IS HEREBY GIVEN that the Project is subject to dedications, reservations, and exactions, as specified in the Conditions of Approval. The Project is subject to certain fees described in Services and Public
Works Departments. The Applicant shall be required to pay all development fees of the City then in effect facilities and capital improvements be
imposed to ensure that new development pays the capital costs associated with growth. The Applicant is advised to review the Planned Fee Updates portion of the web page, www.escondido.gov, and regularly monitor and/or review fee-related information to plan for the costs associated with undertaking the Project.

2. NOTICE IS FURTHER GIVEN that the 90-day period during which to protest the imposition of any fee, dedication, reservation, or other exaction described in this Resolution begins on the effective date of this Resolution, and any such protest must be in a manner that complies with Government Code section 66020.
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ATTACHMENT 4
PASSED, ADOPTED, AND APPROVED by a majority vote of the Planning Commission of the City of Escondido, California, at a regular meeting held on the 28th day of April, 2026, by the following vote, to wit:

AYES: COMMISSIONERS:

NOES: COMMISSIONERS:

ABSTAINED: COMMISSIONERS:

ABSENT: COMMISSIONERS: ______________________________ STAN WEILER, Chair Escondido Planning Commission
ATTEST: ______________________________ VERONICA MORONES, Secretary of the Escondido Planning Commission
I hereby certify that the foregoing Resolution was passed at the time and by the vote above stated.
_____________________________ ANGEL ESTRADA, Minutes Clerk Escondido Planning Commission
Decision may be appealed to City Council
pursuant to Zoning Code Section 33-1303
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LEGAL DESCRIPTION

THE LAND REFERRED TO HEREIN BELOW IS SITUATED IN THE COUNTY OF SAN DIEGO, STATE OF CALIFORNIA, AND IS DESCRIBED AS FOLLOWS:

PARCEL 1 OF PARCEL MAP NO. 13268, IN THE COUNTY OF SAN DIEGO, STATE OF CALIFORNIA, FILED IN THE OFFICE OF THE COUNTY RECORDER OF SAN DIEGO COUNTY, MAY 10, 1984.

APN: 238-360-68-00
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PREPARED BY: M A S S O N ASSESSOR'S PARCEL NO: LEGAL DESCRIPTION: OWNER/APPLICANT: VICINITY MAP PROJECT DESCRIPTION ROBERT D'AMARO LEE DURAN DATE 11/6/2025 11/6/2025 DATE Exhibit B 74
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PREPARED BY: M A S S O N ASSESSOR'S PARCEL NO: LEGAL DESCRIPTION: OWNER/APPLICANT: VICINITY MAP PROJECT DESCRIPTION Exhibit B 75
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PREPARED BY: M A S S O N ASSESSOR'S PARCEL NO: LEGAL DESCRIPTION: OWNER/APPLICANT: VICINITY MAP PROJECT DESCRIPTION Exhibit B 77
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Exhibit BExhibit B 78
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INITIAL STUDY ADDENDUM
City of Escondido, California

1. PROJECT TITLE: Hamilton Bernardo Tentative Tract Map Project

2. LEAD AGENCY & ADDRESS: City of Escondido; 201 North Broadway; Escondido, CA 92025

3. CONTACT PERSON & PHONE: Melissa DiMarzo, Assistant Planner II

4. PROJECT LOCATION: The project site is located southeast of the Hamilton Lane/Bernardo Avenue intersection and comprises 6.02 gross acres in the City of Escondido (Assessor Parcel Number 238-360- 68-00).

5. PROJECT SPONSOR & ADDRESS: Hamilton Bernardo LLC
PO Box 1795
La Jolla, CA 92038
Lee Duran
858-699-9311

6. GENERAL PLAN DESIGNATION: Estate 1

7. ZONING DESIGNATION: Residential Estate (RE)-40

8. SURROUNDING LAND USES & PROJECT SETTING:

The project site is vacant. An existing single-family residence is located adjacent to and south of Lot 2 and east of the proposed stormwater biofiltration basin in unincorporated San Diego County. Adjacent land to the west is zoned RE-40. Unincorporated San Diego County is located to the north, east and south. Surrounding land use is single-family residential development.

9. SUMMARY OF ORIGINAL PROJECT:

The original project was a Subdivision Map consisting of 5 single-family residential lots on minimum 40,000 square foot lots and associated public infrastructure improvements such as circulation, storm drains, and water and sewer lines. The project would include grading to create the proposed private street and home building sites. No grading exemptions are required. The approximately 6.28-acre site is comprised of one Assessor Parcel Number (238-360-6800) connecting to and fronting on both Bernardo Avenue and Hamilton Lane. The proposed project is located in an area composed of a mix of established residential development, newer housing tracts and some remaining vacant parcels.

The City of Escondido prepared and adopted an Initial Study/Mitigated Negative Declaration for Case Number ER 2005-33, TR 931, 2005-46-PZ, 2005-06 AN. The Initial Study was circulated for public review from March 22, 2007 to April 11, 2007. The Initial Study determined that no significant impacts to the environment would occur with implementation of the proposed annexation and subdivision map. The following mitigation measures were identified and incorporated into the Mitigation Monitoring and Reporting Program (MMRP).

Air Quality
Impact. The project will potentially impact air quality in the area surrounding the project during construction.

Mitigation. Prior to construction and issuance of grading and building permits, a site-specific analysis shall be prepared to determine equipment and methods necessary to protect adjacent properties. 79 Attachment "3"
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Initial Study Addendum -2- City of Escondido, California Biological Resources
Impact. The project will have a direct impact on 3.06 acres of non-native grasslands.

Mitigation. The proposed mitigation ratio is 0.25:1 for direct impacts through the purchase of habitat credits from an approved mitigation bank (BIO-1).

Impact. Project will have a direct impact on .02 acres of Coast Sage Scrub. U.S. Fish and Wildlife and California Department of Fish and Game approval required.

Mitigation. The proposed mitigation ratio is 1:1 for direct impacts through the purchase of habitat credits from an approved mitigation bank (BIO-2).

Impact. The project will require the removal of four individual oak trees to develop the residential lots within the subdivision.

Mitigation. Impacts to native Live Oak trees will be mitigated by relocating the four Live Oaks on-site and planting four new Live Oak trees on-site (BIO-3).

Impact. The project will remove four individual oak trees to develop the residential lots within the subdivision.

Mitigation. A qualified biologist must inspect trees for nests prior to any brushing, grading, tree relocation or construction within close proximity to, or within the existing Oaks discussed in the Biological Report's addendum of 2/14/07. If any active nests of sensitive species are found, no impacts will be allowed until all young have fledged (BIO-4).

Impact. Oak trees planted as part of the replacement program must be monitored to ensure viability.

Mitigation. The applicant shall provide funding to the satisfaction of the City for the five-year monitoring of the oak trees with sufficient reserve for the replacement of any dead/dying stock (BIO-5).

Hazardous Materials
Impact. Project is near the Chatham Barrel Yard (a Superfund Cleanup Site). The project site has one County Monitoring well to that is to remain.

Mitigation. Monitoring well MW57 is to remain onsite and be accessible to the Chatham Brothers RP Group for monitoring purposes until officially released. Upon release, it is to be removed per Regional Board and City of Escondido standards. Alternately, if a new replacement well is installed nearby and approved by the Regional Board and Department of Toxic Substances Control (DTSC), existing well MW57 can also then be released and removed per Regional Board and City of Escondido standards.

This well was decommissioned as documented in a letter provided by Chatham Site PRP Group dated May 21, 2009. This mitigation measure has been satisfied.

Hydrology/Water Quality
Impact. Project is near the Chatham Barrel Yard (a Superfund Cleanup Site). The project site has one County Monitoring well that is to remain.

Mitigation. No drinking water wells are to be drilled on-site and no excavations shall be allowed on-site without proper permits (HYD-1).
80 Attachment "3"
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Initial Study Addendum -3- City of Escondido, California Proposed Project
The project applicant is seeking entitlement approval from the City of Escondido for a Tentative Tract Map subdividing an existing 6.02 gross/5.95 net acre parcel into five single-family residential estate lots and one stormwater detention basin lot. The applicant is requesting the following entitlement approvals:
- PL24-0067
Hamilton Bernardo, LLC, (applicant) submitted a proposal to the City of Escondido for approval of a subdivision to create five single-family estate lots and one lot for the construction of a stormwater biofiltration basin. The proposed single-family residential lots would be a minimum of 40,000 square feet and accommodate one single-family residence with related improvements. Primary access would be from Hamilton Lane with secondary emergency vehicle access (EVA) from Bernardo Avenue. Potable water would be provided by the City of Escondido Water Department. Sewer conveyance and treatment and public services (i.e., fire, police and stormwater) would be provided by the City of Escondido.

School services would be provided by the Escondido Union School District. Grading would require cut/fill of 8,700 cubic yards. Grading spoils would be balanced on-site. Construction would begin in mid2026 and be completed in 2027.

10. OTHER REQUIRED AGENCY APPROVALS:

None required.

11. HAVE CALIFORNIA NATIVE AMERICAN TRIBES TRADITIONALLY & CULTURALLY AFFILIATED

WITH THE PROJECT AREA REQUESTED CONSULTATION PER PUBLIC RESOURCES CODE SECTION 21080.3.1? IF SO, IS THERE A PLAN FOR CONSULTATION THAT INCLUDES, FOR

EXAMPLE, THE DETERMINATION OF SIGNIFICANCE OF IMPACTS TO TRIBAL CULTURAL RESOURCES, PROCEDURE REGARDING CONFIDENTIALITY, ETC.?
The proposed project will disturb native soils during site preparation and grading. Approval of the project would incorporate conditions of approval to address potential adverse effects to Cultural Resources and/or Tribal Cultural Resources during construction. The 2007 Initial Study was prepared prior to adoption of AB 52; thus, while tribal cultural resources are addressed herein, no consultation with Native American Tribes per AB52 is required.

12. ENVIRONMENTAL DETERMINATION/ADDENDUM:

As stated, the City previously prepared and adopted an Initial Study and Mitigated Negative Declaration for Case Number ER 2005-33, TR 931, 2005-46-PZ, 2005-06, dated March 21, 2007.. Based on all available information and in light of the entire record, the analysis in this Addendum, and pursuant to Sections 15162 of the State CEQA Guidelines, the City has determined the following

1. There are no substantial changes proposed in the project which will require major revisions of the previous environmental document due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;

2. Substantial changes have not occurred with respect to the circumstances under which the project is undertaken which will require major revisions of the previous environmental document due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or

3. There is no 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 environmental 81 Attachment "3"
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Initial Study Addendum -4- City of Escondido, California document was certified as complete or was adopted, shows any of the following:

A. The project will have one or more significant effects not discussed in the previous Mitigated Negative Declaration;
B. Significant effects previously examined will be substantially more severe than shown in the previous Mitigated Negative Declaration;
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 Mitigated Negative Declaration would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

Per Section 15164 (a) of the CEQA Guidelines, the lead agency has prepared an addendum to a previously adopted Mitigated Negative Declaration because, while some changes or additions to the previous Mitigated Negative Declaration were necessary, none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.

Based upon review of the current project, none of the conditions described in Sections 15162 and 15164 of the State CEQA Guidelines apply. No changes in circumstances have occurred, and no new information of substantial importance has manifested, which would result in new significant or substantially increased adverse impacts as a result of the project. As stated, pursuant to Section 15164, , this Addendum has been prepared to document minor technical changes or additions to the Project.

4. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED: The project would not affect any environmental factors resulting in a Potentially Significant Impact or Potentially Significant Impact Unless Mitigated. A summary of the environmental factors potentially affected by this project, consisting of a Potentially Significant Impact or Potentially Significant Impact Unless Mitigated, include:

Aesthetics Agriculture & Forestry Resources Air Quality Biological Resources Cultural Resources Geology / Soils Greenhouse Gas Hazards & Hazardous Materials Hydrology / Water Quality Land Use / Planning Mineral Resources Noise
Population / Housing Public Services Recreation
Transportation Tribal Cultural Resources Utilities / Service Systems Mandatory Finding of Significance Greenhouse Gas Emissions Wildfire Energy
DETERMINATION. (To be completed by lead agency) Based on this initial evaluation:

I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.

I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because the mitigation measures described herein have been included in this project. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required. 82
Attachment "3"
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Initial Study Addendum -5- City of Escondido, California I find that the proposed project MAY have a potentially significant impact or potentially significant unless mitigated impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project. An Addendum is being prepared to address minor changes to the project. Nothing further is required.

Melissa DiMarzo, Assistant Planner II

5. EVALUATION OF ENVIRONMENTAL IMPACTS

1. A brief explanation is required for all answers except No Impact answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A No Impact answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A No Impact answer should be explained where it is based on project-specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis).

2. All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.

3. Once the lead agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. Potentially Significant Impact is appropriate if there is substantial evidence that an effect may be significant. If there are one or more Potentially Significant Impact entries when the determination is made, an EIR is required.

4. Negative Declaration: Less Than Significant With Mitigation Incorporated applies where the incorporation of mitigation measures has reduced an effect from Potentially Significant Impact to a Less Than Significant Impact. The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from Earlier Analyses, as described in (5) below, may be cross-referenced).

5. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). In this case, a brief discussion should identify the following:
a) Earlier Analysis Used. Identify and state where they are available for review. b) Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. c) Mitigation Measures. For effects that are Less than Significant with Mitigation Measures Incorporated, describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project. 83 Attachment "3"
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Initial Study Addendum -6- City of Escondido, California

6. Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated.

7. Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion.

8. This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a projects environmental effects in whatever format is selected.

9. The explanation of each issue should identify:
a) the significance criteria or threshold, if any, used to evaluate each question; and b) the mitigation measure identified, if any, to reduce the impact to less than significance. 84 Attachment "3"
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Initial Study Addendum -7- City of Escondido, California

14.1 AESTHETICS. 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 building within a state scenic highway?
c. In nonurbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from a 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?
2007 Initial Study
The proposed map is not located on a Ridgeline identified in the Community Open Space/Conservation Element of the General Plan. No Grading exemptions are being requested in conjunction with this tentative map. The highest fill proposed on the site is approximately 10 feet in height, consistent with the maximum height allowed in the City's Grading Ordinance. It is located along one pad area in the far northeastern corner of the project. The deepest proposed cut areas are up to 6 feet deep, with a maximum of 20 feet being allowed in the Grading Ordinance. The largest cuts are located within the north-central portion of the site.

These proposed cuts and fills are at a 2:1 ratio, also consistent with the Grading Ordinance. These proposed slopes are considered minor in nature by the Code and will not block significant views.

Residential projects typically do not directly illuminate or reflect glare upon adjacent properties, therefore no significant light or glare impact would result from the proposed project. Development of the proposed future development will not obstruct scenic views or vistas open to the public since neither the City nor the State designates Hamilton Lane or Bernardo Avenue as a scenic resources.

Proposed Project
a) Have a substantial adverse effect on a scenic vista? Less than Significant Impact. The project would approve five new single-family estate lots and one lot to accommodate a stormwater bioretention basin. The site is currently vacant and comprised of rolling terrain with several granite boulder clusters. As stated, the site is zoned RE-40 and surrounded by existing singlefamily residential development. New residential lots would be planned and residences constructed consistent with City of Escondido Zoning Code (Chapter 33) Article 6 (Residential Zones), and Article 64 (Design Review).

The General Plan Conservation Element notes that hillsides and ridgelines provide a visual resource and aesthetic value to Escondido that contributes to the communitys sense of identity. These areas are located to the west and east of the site (see Conservation Element, Figure VII-5). The project site does not have any designated scenic features and while the project would change existing views into the site; the site is not a scenic vista. The proposed project would not further obstruct existing public views of hillsides and ridgelines; 85 Attachment "3"
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Initial Study Addendum -8- City of Escondido, California thus, the approved project would not result in adverse effects to scenic resources identified in the General Plan. Impacts would be consistent with those identified in the 2007 Initial Study. b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
No Impact. No officially designated state scenic highways exist within City limits. Additionally, the Citys General Plan Resource Conservation Element does not identify any local scenic roadways (City of Escondido 2012). Grading would likely remove or relocate existing vegetation and boulders; however, no impact within a state scenic highway corridor would occur. Impacts would be consistent with those identified in the 2007 Initial Study.
c) In nonurbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from a 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?
Less-Than-Significant Impact. Scenic quality is governed by the Citys Zoning Code and General Plan. As discussed under response (a), the proposed project would not result in an adverse effect to a scenic vista as defined in the Citys General Plan. As indicated above, the project site does not have any designated scenic features and while the project would change existing views into the site; the site is not a scenic vista. The proposed project would not further obstruct existing public views of hillsides and ridgelines; thus, the approved project would not result in adverse effects to scenic resources identified in the General Plan. Impacts would be less than significant. The project is within an urbanized area and it would not conflict with applicable RE-40 zoning and other regulations governing scenic quality. Impacts would be consistent with those identified in the 2007 Initial Study.
d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less-Than-Significant Impact. There are two primary artificial sources of light that generally affect an urban environment: light emanating from building interiors that passes through windows to the outside and light from exterior sources (e.g., street lighting, parking lot lighting, building illumination, security lighting, and landscape lighting) that affect the natural ambient light level. The introduction of light can affect adjacent areas and diminish night sky views depending on the location of the light sources and proximity to nearby light-sensitive areas.

Glare can be caused by unshielded or misdirected lighting sources. Reflective surfaces such as chrome or polished metal can also be a source of glare. Glare results from development and associated parking areas that contain reflective materials such as hi-efficiency window glass, highly polished surfaces and expanses of pavement. The Project site is in a developed area with predominantly single-family uses. The existing lighting in the project area includes streetlights and vehicle lights within the adjacent roadway corridors and interior and exterior building lighting from developed parcels proximal to the site.

Proposed lighting is anticipated to include a combination of street and security lighting. City of Escondido Zoning Code Article 35 addresses the use of light fixtures on residential properties to minimize the amount of light cast on adjoining properties and public right-of-way. During construction, lights may be used within the construction areas, notably the construction staging areas, to provide security for construction equipment and construction materials. Further, in the event that construction-related activities occur during nighttime hours, temporary, overhead artificial lighting would be provided to illuminate the work area. Compliance with applicable lighting regulations and standards would reduce potential impacts to less than significant. Impacts would be consistent with those identified in the 2007 Initial Study. 86 Attachment "3"
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Initial Study Addendum -9- City of Escondido, California Based on the foregoing analysis and information, there is no evidence that the project would require a major change to the 2007 Initial Study. The project would not result in any new significant impact, nor would a substantial increase in the severity of impacts from that described in the 2007 Initial Study result.

14.2 AGRICULTURE & FORESTRY RESOURCES. In determining
whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the states inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:
a. Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance as depicted on maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency?
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 by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
d. Result in the loss of forest land or conversion of forest land to nonforest use? e. Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to nonagricultural use or conversion of forest land to non-forest use? 2007 Initial Study
The project site is not in agricultural production and is not listed as Prime Agricultural Land as identified in the General Plan Final Environmental Impact Report, which was prepared for the City's most recent General Plan revisions in 2012.

The California Department of Conservation, which publishes farmland conservation reports, classifies the site as "Urban and Built-up Land" which is defined as:
" ... land occupied by structures with a building density of at least one unit to 1.5 acres, or approximately six structures to a 10-acre parcel, including residential, industrial, commercial, institutional facilities, cemeteries, airports, golf courses, sanitary landfills, sewage treatment, and water control structures. 87 Attachment "3"
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Initial Study Addendum -10- City of Escondido, California The development of residential lots and natural vegetated lands to remain; would therefore, not result in significant individual or cumulative impacts to agricultural resources.

Proposed 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?
No Impact. The site is not designated as Prime Farmland, Unique Farmland or Farmland of Statewide Importance. Construction of the proposed project would not convert farmland to non-agricultural use Impacts would be consistent with those identified in the 2007 Initial Study. b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? No Impact. The proposed project is located in an area zoned to accommodate the existing use. Agricultural designations do not occur within the project area and no Williamson Act contracts apply. Therefore, implementation of the project would not result in any conflicts with existing zoning for agricultural use or a Williamson Act Contract. No impact would occur. Impacts would be consistent with those identified in the 2007 Initial Study.

No Impact. The project site is neither zoned for agricultural use, nor subject to a Williamson Act contract.

Approval of the proposed project would have no impact on existing agricultural zoning or to land under a Williamson Act contract. No impact would occur. Impacts would be consistent with those identified in the 2007 Initial Study.
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))? No Impact. The project site is not zoned as forest land or timberland or for Timberland Production nor do these uses occur on the site. No impact would occur. Impacts would be consistent with those identified in the 2007 Initial Study.
d) Result in the loss of forest land or conversion of forest land to non-forest use? No Impact. The project site does not contain forested areas or designated forest land. The proposed project would not result in the loss of forest land or conversion of forest land to non-forest use. No impact would occur. Impacts would be consistent with those identified in the 2007 Initial Study. 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? No Impact. The project site is not located on a site dedicated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. Implementation of the proposed project would not result in changes in the environment that would result in the conversion of farmland to non-agricultural use. No impact would occur.

Impacts would be consistent with those identified in the 2007 Initial Study.

Initial Study Addendum -11- City of Escondido, California

14.3 AIR QUALITY. Where available, the significant criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determination. 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?
2007 Initial Study
The project area is within the San Diego Air Basin (SDAB). Air quality at a particular location is a function of the kinds and amounts of pollutants being emitted into the air locally, and throughout the basin, and the dispersal rates of pollutants within the region. The major factors affecting pollutant dispersion are wind, speed and direction, the vertical dispersion of pollutants (which is affected by inversions) and the local topography.

The air basin currently is designated a state and federal non-attainment area for ozone and particulate matter.

However, in the SDAB, part of the ozone contamination is derived from the Los Angeles area South Coast Air Basin during periods of westerly winds (Santa Ana condition) when air pollutants are windborne over the ocean, drift to the south and eventually are blown easterly into the SDAB. Local agencies can control neither the source nor transportation of pollutants from outside the basin. The Air Pollution Control District (APCD) policy; therefore, has been to control local sources effectively enough to reduce locally produced contamination.

For long-term emissions, the direct impacts of a project can be measured by the project's consistency with regional plans to improve and maintain air quality. Local air-quality impacts are directly related to the number of vehicle trips and operation levels on adjacent streets and intersections. For planning purposes, the APCD assumed the City's General Plan designation of Estate I in calculating air quality impacts. According to CEQA Guidelines, a project normally is considered to have a significant air quality impact if it violates any ambient air quality standard, contributes substantially to an existing or projected air-quality violation, or exposes sensitive receptors to substantial pollution concentrations.

Emissions resulting from developing the site would be directly related to the amount of vehicular traffic generated by the project. The increase of 5 units would have an incremental impact to basin-wide air quality.

Considering the cumulative impacts of thousands of sources, the impact attributed to the project is immeasurably small on a regional scale and will not cause ambient air-quality standards to be exceeded.

Since development would not materially degrade the levels of service on adjacent streets and intersections, and would not violate daily emissions thresholds, the project will not have a significant impact on air quality and no mitigation measures are required.

Construction-Related Emissions
Construction-related activities are temporary, short-term sources of air emissions. Sources of constructionrelated air emission include:
89 Attachment "3"
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Initial Study Addendum -12- City of Escondido, California Fugitive dust from grading activities; Construction equipment exhaust; Construction-related trips by worker, delivery trucks and material-hauling trucks; and Construction-related power consumption.

Maximum daily emissions of NOx during construction periods are not projected to exceed City thresholds or APCD standards based on similar studies performed for similar size grading operations. Since construction is a one-time temporary activity, and because average daily construction emissions are projected to be below thresholds of significance, operation of equipment during project construction is not anticipated to result in substantial air quality impacts. Dust from grading and other site preparation would generate particulate matter emission; however, with appropriate use of grading and operation procedures as described in the attached mitigation measures (in conformance with APCD Best Management Practice for dust control), the project would not generate significant particulate matter or dust.

The City of Escondido Grading Ordinance and erosion control requirements include provisions for dust control to reduce impacts to air quality during grading and construction activities. At a minimum, these ordinances and provisions require projects to perform regular watering and timely re-vegetation of disturbed areas to minimize the dust and airborne nuisance impacts to off-site receptors. Emissions from construction equipment, worker and delivery and material-hauling trucks, and construction-related power consumption would be temporary and would result in an extremely small contribution to the SDAB; and therefore, would not result in a significant impact.

As stated above, mitigation for air quality required preparation of a site-specific analysis and report to determine equipment and methods necessary to protect adjacent properties from adverse air quality impacts which may result from construction. A site-specific analysis was prepared and is summarized below; thus, satisfying this mitigation measure.

Proposed Project
Information within this section was obtained in part from the California Emission Estimator Model version 2022.1. The output file is provided as Appendix A.
a) Conflict with or obstruct implementation of the applicable air quality plan? No Impact. The project site is zoned RE-40 which supports low density single-family residential development.

SANDAGs Regional Plan population, employee population and housing estimates for the years 2020 and 2035 was compared to the estimated increase in population, employees, and housing generated by the proposed project. The number of housing units in the City was projected to be 54,910 in 2025 and 58,990 in 2035, or an increase in 4,080 housing units. Furthermore, the Citys population was projected to be 165,127 residents in 2025 and 169,122 residents in 2035, or an increase of 3,995 residents over the period. The average household size is 2.8 people per dwelling unit, which translates into approximately 14 residents for the proposed project. Therefore, the project would be within SANDAGs population growth forecast and, as addressed below, the proposed project emissions would not conflict with the State Implementation Plan (SIP), AQMP and RAQS. Therefore, as the Final IS/MND disclosed regarding the approved project, the proposed project would not conflict with or obstruct implementation of the applicable air quality plan. Impacts would be consistent with those identified in the 2007 Initial Study. 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? Less than Significant Impact. The thresholds listed in Table 1 are screening-level thresholds used to evaluate whether proposed-project-related emissions could cause a significant impact on air quality.

Emissions below the screening-level thresholds would not cause a significant impact. The emissions-based thresholds for ozone precursors (ROG and NOx) are intended to serve as the threshold for ozone. This 90 Attachment "3"
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Initial Study Addendum -13- City of Escondido, California approach is used because ozone is not emitted directly; thus, ozone concentrations associated with individual projects precursors (VOC and NOx) emissions cannot be determined through air quality models or other quantitative methods. For nonattainment pollutants, if emissions exceed the thresholds shown in Table 1, the project has the potential to result in a cumulatively considerable net increase in these pollutants; and thus, could have a significant impact on the ambient air quality. Impacts would be consistent with those identified in the 2007 Initial Study.

Table 1
SDAPCD Air Emission Significance Thresholds
Construction Emissions
Pollutant Total Emissions (pounds per day)
Reactive Organic Gas (ROG) 75
Nitrogen Oxides (NOx) 250
Carbon Monoxide (CO) 550
Sulfur Oxides (SOx) 250
Respirable Particulate Matter (PM10) 100
Fine Particulate Matter (PM2.5) 55
Operational Emissions
Total Emissions
Pounds per Hour Pounds per Day Tons per Year
Reactive Organic Gas (ROG) -- 75 13.7
Nitrogen Oxides (NOx) 25 250 40
Carbon Monoxide (CO) 100 550 100
Sulfur Oxides (SOx) 25 250 40
Respirable Particulate Matter (PM10) -- 100 15
Fine Particulate Matter (PM2.5) -- 55 10
Lead and Lead Compounds -- 3.2 0.6
The estimated maximum daily construction and operating emissions are summarized in Table 2 below. As shown, the Project construction-source emissions and operating emissions would not exceed San Diego Air Pollution Control District (SDAPCD) regional thresholds for daily emission. Thus, a less than significant impact will occur and no mitigation measures are required. Impacts would be consistent with those identified in the 2007 Initial Study.
c) Expose sensitive receptors to substantial pollutant concentrations? Less than Significant Impact. Sensitive populations (i.e., children, senior citizens and acutely or chronically ill people) are more susceptible to the effects of air pollution than are the general population. Land uses considered sensitive receptors typically include residences, schools, playgrounds, childcare centers, hospitals, convalescent homes, and retirement homes. Sensitive receivers include the single-family residences located adjacent to and proximal to the site. In evaluating impacts to sensitive receptors, the two primary emissions of concern are diesel particulate matter and CO. The proposed project would generate approximately 50 daily trips (i.e., 10 trips per unit) and five trips during the peak hour. Per the City of Escondido Transportation Impact Analysis Guidelines (April 2021), projects that generate less than 200 daily trips may be presumed to have a less-than significant impact absent substantial evidence to the contrary. The project is not expected to cause a traffic impact or otherwise impede circulation within the project area and at proximal intersections.

Consequently, sensitive receptors would not be significantly affected by CO emissions generated by Projectrelated traffic.

Toxic Air Contaminants. The proposed project would be constructed within an RE-40 zone and require a common mix of equipment. As shown, construction emissions would not violate SDAPCD daily construction emission standards. With respect to operation, the proposed project would not include uses that cause or contribute to TAC emissions. Construction and operation of the proposed project would not 91 Attachment "3"
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Initial Study Addendum -14- City of Escondido, California Table 2
Maximum Daily Construction and Operational Emissions
Project Emissions
Maximum Emissions (lbs/day)
ROG NOx CO SOx PM10 PM2.5
Construction 2026 6.2 12.9 15.0 0.02 3.4 1.8
SDAPCD Screening
Thresholds 75 250 550 250 100 55
Threshold Exceeded No No No No No No
Operating Emission
Proposed Project 0.04 0.12 1.8 0.003 0.3 0.08
SDAPCD Screening
Thresholds 75 250 550 250 100 55
Threshold Exceeded No No No No No No
Source: Birdseye Planning Group, LLC., (March 2025) (Appendix A). expose sensitive receptors to substantial pollutant concentrations. Impacts would be consistent with those identified in the 2007 Initial Study.
d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less than Significant Impact. The Project does not contain land uses typically associated with emitting objectionable odors. Potential odor sources associated with the proposed Project may result from construction equipment exhaust and the application of asphalt and architectural coatings during construction activities and the temporary storage of typical solid waste (refuse) associated with the proposed Projects (long-term operational) uses. Standard construction requirements would minimize odor impacts from construction. The construction odor emissions would be temporary, short-term, and intermittent in nature and would cease upon completion of the respective phase of construction; and thus, is considered less than significant. It is expected that Project-generated refuse would be stored in covered containers and removed at regular intervals in compliance with the solid waste regulations. Therefore, odors associated with the proposed Project construction and operations would be less than significant and no mitigation is required. The 2007 Initial Study does not specifically address odors; however, as described herein, impacts would be less than significant.

14.4 BIOLOGICAL RESOURCES. Would the project:
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Initial Study Addendum -15- City of Escondido, California 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 Game or the USFWS?
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 Game (DFG) or U.S. 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?
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/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?

Information provided in this section was in part, obtained from the Biological Resources Memorandum prepared by Tierra Data, Inc., July, 2024.(Appendix B). 2007 Initial Study
A series of biological reports dated 6/19/06, 11/20/06, and 2/14/07 were prepared by the Chambers Group to augment the Biological Resource Assessment conducted in 1991 for the subject property. Taken in combination, the reports conclude that the 6.28-acre parcel is composed mostly of non-native grassland with a few oaks in the southeastern portion of the site and a small isolated patch of coastal sage scrub along a fence line adjacent to Hamilton Lane. Based on information detailed in Appendix B, there are currently no sensitive wildlife species present on the site. The biological resource reports concluded that development of the site under the 2007 proposal would necessitate the removal of 3.06 acres of non-native grassland, four oak trees and .02 acres of coastal sage scrub. Proposed mitigation would bring the impacts to biological resources to less than significant.
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 Game or the USFWS? Less than Significant. The parcel is primarily Disturbed Habitat (DH) composed of annual non-native grasses and non-native vegetation, reflecting the history of agricultural use and repeated mowing for weed abatement.

Due to the significant disturbance and a shift from the original vegetation composition, resilient and fastgrowing non-native species and grasses now outcompete the native flora including several brome grasses (Bromus madritensis ssp. rubens, B. hordeaceus and B. diandrus) and slender wild oat (Avena barbata), as well as non-native forbs, such as mustards (Hirshfeldia incana and Brassica nigra), and filarees (Erodium brachycarpum, E. cicutarium, and E. moschatum).
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Initial Study Addendum -16- City of Escondido, California Despite the dominance of non-native species, the parcel supports some native species, predominantly annual forbs such as Menzies' Fiddleneck (Amsinckia menziesii), Narrow Leaf Bedstraw (Galium angustifolium) and a few diminutive perennial species including Coast Buckwheat (Eriogonum fasciculatum), and Broom Baccharis (Baccharis sarothroides) which have clearly been mowed annually. Additionally, several large piles of mulch have been placed on the property, with some already spread. These piles consist primarily of Mexican fan palm (Washingtonia robusta) material, laden with seeds that are now sprouting abundantly.

Animals observed included species of native and non-native Argentine ants (Linepithema humile), Great Basin fence lizards (Sceloporus occidentalis) on the rocks, a dead gopher snake (Pituophis catenifer catenifer), evidence of Coyote (Canis latrans), Bottas pocket gopher (Thomomys bottae), and a woodrat nest (Neotoma sp.), and common birds including mourning dove (Zenaida macroura), house finch (house finch), California towhee (Melozone crissalis), and northern mockingbird (Mimus polyglottos). Larger birds were using the offsite trees in the vicinity, including California scrub jay (Aphelocoma californica), hooded oriole (Icterus cucullatus), acorn woodpecker (Melanerpes formicivorus), and American crows (Corvus brachyrhynchos). A red-tailed hawk (Buteo jamaicansis) was seen flying overhead in the area.

No special status plants or animals were observed at the time of the survey nor is the on-site habitat expected to support sensitive species.

As stated in the 2007 Initial Study, the project would require mitigation for direct impacts to 3.06 acres of nonnative grassland and .02 acres of coastal sage scrub. Neither of these habitat types remain on the project site under current conditions. The property was cleared as requested in weed abatement orders issued by the City of Escondido on May 26, 2021, and August 12, 2025 (see Appendix C). Thus, impacts associated with the proposed project would be less than significant and less than what was identified in the 2007 Initial Study. However, mitigation measures addressing impacts to these habitat types in the 2007 Initial Study and listed above in Section 9, Summary of Original Project, remain applicable and would require implementation with approval of the proposed Project.
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 Game (DFG) or U.S. Fish and Wildlife Service?
No Impact. The site is vacant and does not contain any federal or State jurisdictional areas. The proposed project would have no substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Game or U.S. Fish and Wild Service. The project site is void of riparian corridors and sensitive habitat. Thus, no impacts to riparian habitat or sensitive natural communities would occur. Impacts would be consistent with those identified in the 2007 Initial Study.
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? No Impact. No wetlands, as defined by Section 404 of the Clean Water Act, exist on-site or immediately adjoining the site. Thus, the project would not result in impacts to wetlands. Impacts would be consistent with those identified in the 2007 Initial Study.
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?
No Impact. The project site is disturbed and located within an urban area. Project implementation would not interfere with the movement of any native resident or migratory fish or wildlife species, with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites, as none exist within the immediate project area. No impacts to migratory corridors or native wildlife nursery sites would occur.

Impacts would be consistent with those identified in the 2007 Initial Study. e. Conflict with any local policies or ordinances protecting biological resources, such as tree preservation 94 Attachment "3"
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Initial Study Addendum -17- City of Escondido, California policy/ordinance?
Less than Significant Impact. The Escondido Municipal Code regulates removal of trees identified as Mature or Heritage (i.e., Protected), trees (Sec 33-1069). Mature and Protected trees are defined in the Escondido Municipal Code Sec 33-1052 as:

Mature tree is any self-supporting woody perennial plant, native or ornamental, with a single welldefined stem or multiple stems supporting a crown of branches. The single stem, or one of the multiple stems of any mature oak tree (genus Quercus), shall have a diameter 4 inches or greater when measured at 4½ feet diameter at breast height (DBH) above the trees natural grade. All other mature trees shall have a diameter of 8 inches DBH, or greater, for a single stem or one of the multiple stems.

Protected tree is any oak (genus Quercus) which has a 10-inch or greater DBH, or any other species or individual specimen listed on the local historic register, or determined to substantially contribute to the historic character of a property or structure listed on the local historic register, pursuant to Article 40 of the Escondido Zoning Code.

A total of 17 mature and protected trees are located on-site. Most of the trees on site are in the southern portion of the site. Two trees are in the west and center of the site, one a small black locust (Robinia pseudoacacia) and the other, a Heritage coast live oak (Quercus agrifolia). The southern portion of the site contains six Heritage coast live oak trees, three mature coast live oak trees and three mature non-native trees. The remaining four trees do not meet the Protected tree criteria.

Several Mature and Heritage Trees are located on Lots 2, 4, and 5. The proposed project could potentially remove two Heritage coast live oak trees located within the pad of Lot 4 while avoiding all other oak trees. A coast live oak tree on the boundary of Lots 4 and 5 would be avoided. Two additional Mature olive trees would also be removed by grading Lot 5. Lastly, a black locust tree meets neither Heritage nor Mature tree criterion, would be removed to create the retention basin. All the impacted Heritage or Mature trees are far from the three roads that border the parcel and the loss of four trees would not significantly change views for area residents or the aesthetics of the area. It is expected that future homeowners will plant trees around their homes that will offset any aesthetic impacts from removal of the four trees. While multiple trees would be removed, the Project would be in compliance with Citys current Municipal Code requirements for trees.

As stated in the 2007 Initial Study, the proposed project would require removal of four Live Oak trees; thus, requiring on-site relocation or replacement of the four existing Live Oak trees and planting of four additional Live Oak trees. The current project as proposed would be consistent with the Citys Municipal Code requirements for removal of heritage and mature trees. However, removal of any Live Oak tree would require replacement of that tree plus planting of one additional live oak tree as stated in the 2007 Initial Study mitigation measures for biological resources. Impacts would be similar to what was identified for the project as proposed in 2007.

Based on the foregoing analysis and information, there is no evidence that the project would require a major change to the 2007 Initial Study. The project would not result in any new significant impact, nor would a substantial increase in the severity of impacts from that described in the 2007 Initial Study result. 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? No Impact. The City is no longer participating in the local regional Natural Community Conservation Planning (NCCP) effort and the site was not in a Focused Planning Area of the Multiple Habitat Conservation Plan (MHCP). Thus, the proposed Project would neither impact regional conservation planning efforts under the NCCP or MHCP, and because of its location and features, development would not impact any future regional conservation planning efforts. Impacts would be consistent with those identified in the 2007 Initial Study. 95 Attachment "3"
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Initial Study Addendum -18- City of Escondido, California

14.5 CULTURAL RESOURCES. Would the project:
a. Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5 of CEQA?
b. Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5 of CEQA? c. Disturb any human remains, including those interred outside of dedicated cemeteries?
2007 Initial Study
The undeveloped site currently has only some minor indications that farming and citrus grove activity took place on the property in the past. The hilltop and surrounded land is now vacant. The property does not appear on the list of Archaeological Resources Sites; therefore, it is assumed the proposed development would have less than significant impacts on cultural resources.

Proposed Project
Information provided in this section was in part, obtained from the Phase I Cultural Resources Report prepared by South Environmental, LLC, May 2025 (Appendix D). a. Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5 of CEQA?
No Impact. On March 27, 2025, South Environmental performed an in-person cultural resources records search of the project site and a 0.5-mile search radius at the South Coastal Information Center (SCIC), which houses cultural resources records for San Diego County. This search included their collections of mapped prehistoric and historic archaeological resources and historic built-environment resources, State of California Department of Parks and Recreation Series 523 forms (DPR forms), technical reports, archival resources, and ethnographic references. Additional consulted sources include historical maps of the study area, the National Register of Historic Places (NRHP), the California Register of Historic Resources (CRHR), the lists of California State Historical Landmarks, California Points of Historical Interest, and the Archaeological Resource Directory and Historic Built Environment Resource Directory lists. The SCIC records search identified three cultural resources studies (SD-8588, -8596, and -10211) that were conducted within the project site and an additional 42 studies within a 0.5-mile radius. None identified any historic resources on-site that are listed or eligible for listing on the NRHP or CRHR. Further, no historic resources were identified. No impact to historic resources would occur. Impacts would be consistent with those identified in the 2007 Initial Study. b. Cause a substantial adverse change in the significance of an archaeological resource pursuant to 15064.5 of CEQA?
Less than Significant with Mitigation. As stated above, The SCIC records search identified three cultural resources studies (SD-8588, -8596, and -10211) that were conducted within the project site and an additional 42 studies within a 0.5-mile radius. These are summarized as follows:

SD-08588. The Draft Environmental Impact Report for Expansion of Wastewater Treatment Facility was completed by the City of Escondido in 1980. This Environmental Impact Report (EIR) included a cultural resources inventory that identified an archaeological site within the treatment plant site to be avoided by its 96 Attachment "3"
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Initial Study Addendum -19- City of Escondido, California expansion. The study included a records search but no pedestrian survey. Adherence to State and Regional Historic Preservation regulations was recommended to mitigate impacts to cultural resources. However, the identified archaeological site is nowhere near the current project site, located west of Interstate 15 and south of State Route 78. The EIRs broad study area included the current project site but did not include archaeological surveys within or near the project site.

SD-08596. The Results of a Cultural Resource Survey of the Escondido Reclaimed Water Distribution System Project: Draft Environmental Impact Report was prepared by Brian F. Smith and Associates in 1992. This study inventoried cultural resources within and adjacent to the 24.2-mile project alignment. A record search found 115 prehistoric sites and two historic sites near the project alignment, but no cultural resources were discovered within the studys project boundaries. The entire project alignment was surveyed. Where terrain permitted, the project alignment was intensively surveyed with 20-foot linear transects, and areas with steep grades, heavy foliage, structures, or pavement that inhibited access or ground visibility were surveyed at a reconnaissance level. This approach resulted in approximately 25 percent of the project alignment being intensively surveyed. The eastern half of the current project site falls with the 100-foot buffer zone of the Smith 1992 project alignment; however, no details are provided that indicate the current project site was intensively surveyed. Archaeological monitoring was recommended for certain areas deemed sensitive but not the entirety of the project alignment. Standard mitigation measures were also recommended.

SD-010211. The Results of Archaeological Testing at CA-SDI-12525 Report was prepared by Susan Underbrink of Chambers Group, Inc. in 2006. This multicomponent resource was originally recorded by Del James, Steven Briggs, and Scott Campbell of ERC Environmental and Energy Services in 1991. The prehistoric component was initially described as possessing numerous slicks on 17 different granite bedrock outcrops, more than 20 chipped stone flakes, two manos, one metate fragment, and more than 50 marine shell fragments. An L-shaped concrete foundation and a subterranean concrete foundation was also referenced. It was stated that the area around the bedrock outcrops had been subject to disking but also estimated that the subsurface appeared to retain good integrity.

Susan Underbrink (2006) of Chambers Group, Inc. conducted resurvey and archaeological testing of P-37- 012535 for CRHR eligibility evaluation in May 2006. Underbrink recorded 20 bedrock milling features (labeled as Features A-T) with 27 milling surfaces, all flush or shallow slicks. Underbrink noted that many of the milling surfaces were heavily eroded and that some of the features identified in 1991 could not be relocated.

Underbrink excavated 16 shovel test pits and two 1-meter by 1-meter test units to a maximum depth of 70 centimeters. From the excavations she collected nine metavolcanic chipped stone flakes or shatter, one quartz flake, three small marine shell fragments of unidentified genus or species, one burnt large mammal bone, and one metal plate that states, American Automobile Owners Association. Test Unit 1 produced 10 of the 15 artifacts and ecofacts between 0-30 centimeters of depth. No artifacts from the surface were recorded or collected. Underbrink described the site as a food processing site with a paucity of subsurface cultural material lacking diagnostic artifacts or evidence of habitation. The report (Underbrink 2006) stated that the research potential of P-37-012535 has been exhausted and the site was recommended not eligible for the CRHR and no further work is necessary beyond archaeological monitoring.

Native American Scoping
A Native American Heritage Commission (NAHC) Sacred Lands File search was requested by South Environmental on March 21, 2025. The NAHC responded to the request on April 4, 2025, and reported positive result and recommended contacting the San Luis Rey Band of Mission Indians. The NAHC also recommended contacting 31 Native American tribal representatives for additional information or knowledge they may have regarding the presence of cultural resources that may be impacted by the proposed project.

South Environmental sent letters to each contact provided by the NAHC on April 7, 2025, and sent follow-up emails on April 17, 2025, to non-responsive contacts.

Four tribal contacts have responded to the outreach letters to date. The Pala Band of Mission Indians and Rincon Band of Luiseño Indians stated that the area is archaeologically sensitive with known sites recorded 97 Attachment "3"
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Initial Study Addendum -20- City of Escondido, California within the vicinity. These tribes, along with the San Pasqual Band of Diegueño Mission Indians expressed concern about potential impacts the project may have on local tangible cultural heritage and declared interest in entering formal government-to-government consultation.

Field Survey Results
On April 22, 2025, South Environmental conducted an intensive-level survey of the project site. The site was surveyed using transects spaced approximately ten meters apart throughout the site. Areas with exposed ground surface were examined for the presence of prehistoric artifacts (e.g., flaked stone tools, tool-making debris, stone milling tools), historical artifacts (e.g., metal, glass, ceramics), sediment discolorations that might indicate the presence of a cultural midden, depressions, and other features that might indicate the former presence of structures or buildings (e.g., post holes, foundations).

The previously recorded multicomponent archaeological site P-37-012525 (CA-SDI-12525/H) referenced above was relocated and one medium-grained metavolcanic flake was observed within the archaeological site. Some of the previously recorded bedrock milling slicks were relocated; however, others appeared to have eroded through weathering since the 2006 recordation and testing. No artifacts or other evidence was identified to change the previous characterization of site P-37-012525. No additional archaeological or historic built environment resources were observed during the survey beyond the previously recorded and tested P37-012525. Based on these findings, no further archaeological testing of P-37-012525 is recommended.

Further, the current findings are consistent with the previous recommendation that the site lacks significant data potential and is not eligible for CRHR listing.

No Cultural Resources were identified within the project site through Native American scoping; however, the Native American scoping identified the project vicinity as highly sensitive for prehistoric/Native American resources as referenced above. This sensitivity is supported by the five previously recorded resources with prehistoric components within 0.5-mile of the project site, including the CRHR/NRHP-listed multicomponent site P-37-000570 within Felicita Park, which contains a large prehistoric habitation component.

Given the presence of a previously recorded archaeological site within the project site and evidence of archaeological sensitivity indicated by the records search results and responses from tribal contacts, archaeological and Native American monitoring of all project-related earth disturbing activities is recommended as a condition of approval for addressing any discoveries of cultural resources. With implementation of Condition of Approval (COA) CUL-1, impacts to cultural resources would be less than significant.

CUL-1. Archaeological and Native American Monitoring. Based on the sensitivity of the project site and the presence of P-37-012525, archaeological and Native American monitoring should be considered at the Citys discretion and conducted during all project-related ground disturbance, including but not limited to, grading and excavation for and installation of foundations and utilities.

Within 30 days of the conclusion of all monitoring activities, an archaeological monitoring report shall be prepared by a qualified archaeologist and submitted to the appropriate parties detailing the results of all monitoring activities and any cultural resources identified. Any discoveries of cultural resources or human remains shall be addressed in accordance with the unanticipated discovery measures outlined below.

As stated in the 2007 Initial Study, the proposed project was not expected to have any adverse impact to cultural or historic resources. Based on the current Phase I Cultural Resources Report, there is evidence that resources may occur on-site; and per existing protocol, monitoring during construction is recommended at the Citys discretion as a Condition of Approval. Implementation of this Condition of Approval does not represent a substantial change proposed in the project which will require major revisions of the previous environmental document due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects that would necessitate revisions to the 2007 Initial Study. 98 Attachment "3"
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Initial Study Addendum -21- City of Escondido, California c. Disturb any human remains, including those interred outside of formal cemeteries? Less than Significant. There are no known grave sites within the project limits. Therefore, the disturbance of human remains is not anticipated. However, in the unlikely event that human remains are encountered, State Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. The County Coroner must be notified of any human remains find immediately. If the remains are determined to be prehistoric, the Coroner will notify the Native American Heritage Commission (NAHC) which will determine and notify a Most Likely Descendant (MLD). With the permission of the landowner or his/her authorized representative, the MLD may inspect the site of the discovery, and shall complete the inspection within 24 of notification by the NAHC. The MLD will have the opportunity to make recommendations to the NAHC on the disposition of the remains. With implementation of existing regulations, potential impacts associated with the disturbance of human remains would be less than significant. This issue was not discussed in the 2007 Initial Study; however, compliance with State Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98, does not represent a substantial change proposed in the project which will require major revisions of the 2007 Initial Study.

14.6 Energy. Would the project:
a. Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during the project construction or operation?
b. Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
2007 Initial Study
An evaluation of energy impacts was not required under Appendix G of the CEQA Guidelines when the 2007 Initial Study was prepared.
a. Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during the project construction or operation? Less than Significant Impact. During construction, the Project would temporarily consume energy for the operation of construction equipment and vehicles. Standard methods of earth moving, excavations, building construction, and paving are planned. The proposed construction activities do not include methods of construction which would result in inefficient or unnecessary use of energy resources. For operational energy use, the project would be required to meet CCR Title 24 building energy and California Green Building (CALGreen) Code standards. Energy-efficient buildings require less electricity, natural gas, and other fuels.

Electricity production from fossil fuels and on-site fuel combustion (typically for space or water heating) results in greenhouse gas (GHG) emissions. The Title 24 standards are updated approximately every three years to allow consideration and possible incorporation of new energy efficiency technologies and methods.

The 2022 Title 24 standards went into effect on January 1, 2023. The standards are divided into three basic sets. First, there is a basic set of mandatory requirements that apply to all buildings. Second, there is a set of 99 Attachment "3"
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Initial Study Addendum -22- City of Escondido, California performance standardsthe energy budgetsthat vary by climate zone (of which there are 16 in California) and building type; thus, the standards are tailored to local conditions. Finally, the third set constitutes an alternative to the performance standards, which is a set of prescriptive packages that are basically a recipe or a checklist compliance approach.

CALGreen (CCR Title 24, Part 11) is a code with mandatory requirements for all residential and nonresidential buildings (including industrial and commercial buildings) for which no other state agency has authority to adopt green building standards. The current 2022 Standards for new construction of, and additions and alterations to, residential and nonresidential buildings went into effect on January 1, 2023. CALGreen is intended to (1) reduce GHG emissions from buildings; (2) promote environmentally responsible, cost-effective, healthier places to live and work; (3) reduce energy and water consumption; and (4) respond to the directives by the Governor. In short, the code is established to reduce construction waste; make buildings more efficient in the use of materials and energy; and reduce environmental impact during and after construction. CALGreen contains requirements for storm water control during construction; construction waste reduction; indoor water use reduction; material selection; natural resource conservation; site irrigation conservation; and more.

All fuel calculations are based on the total Carbon Dioxide Equivalent (CO2e) value calculated for each construction phase and vehicle miles traveled (VMT) using the California Emission Estimator Model (CalEEMod) version 2022.1. Data are reported in annual metric tons of CO2e for the duration of each construction phase. Metric tons are converted to kilogram CO2e and then divided by a conversion factor used by the U.S. Environmental Protection Agency to estimate gallons of gasoline consumed based on carbon emissions. For the purpose of determining fuel demand, it was assumed that all worker vehicles would be use gasoline and all construction equipment would diesel-fueled. Deisel demand would be approximately 22,659 gallons. Demand for gasoline would be approximately 504 gallons. During operation, the project would generate demand for approximately 30,706 kilowatt hours (kWh) of electricity and 142,585 British Thermal Units (BTU) of natural gas annually. The annual gasoline demand generated by passenger vehicles visiting the site would be approximately 6,584 gallons.

Compliance with state Title 24 and CALGreen standards would ensure that the Project would not result in wasteful, inefficient, or unnecessary consumption of energy resources. No further Project-specific mitigation measures would be required. Implementation of the Project would not result in wasteful, inefficient, or unnecessary consumption of energy resources that may have a significant impact on the environment.

Impacts would be less than significant; and thus, would not be a significant effect not discussed in the 2007 Initial Study.
b. Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? No Impact. Several levels of government have implemented regulatory programs in response to reducing GHG emissions, which consequently serve to increase energy efficiency statewide. Multiple state agencies, including CARB, California Energy Commission, California Public Utilities Commission, CalRecycle, California Department of Transportation (Caltrans), and the Department of Water Resources have developed regulatory and incentive programs that promote energy efficiency. Many of the measures are generally beyond the ability of any future development to implement and are implemented by utility providers or manufacturers.

The project does not conflict with any state or local plans for renewable energy efficiency. The project would employ standard methods of construction and does not propose to create a project condition post-construction whereby a greater energy, relative to projects of a similar scope would occur. The project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. No impact would result from the project under this threshold; and thus, would not be a significant effect not discussed in the 2007 Initial Study.

As stated, this topical issue was not addressed in the 2007 Initial Study. However, based on the foregoing analysis and information, there is no evidence that the project would result in any significant energy 100
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Initial Study Addendum -23- City of Escondido, California impact.

14.7 GEOLOGY AND SOILS. 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 DM&G Pub. 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? 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 onsite 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 1994 UBC, creating substantial direct or indirect risks to life or property? e. Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
f. Directly or indirectly destroy a unique paleontological resource or site or unique geological feature?
2007 Initial Study
The highest fill areas proposed are approximately 10 feet in height, consistent with the maximum height allowed in the City's Grading Ordinance. The deepest cut areas are approximately 6 feet deep and located within the northern portion of the site. It is reasonably anticipated that conventional grading practices can be utilized to develop the site without the need for blasting. If blasting is required it would likely be limited to the central portion of the site and the contractor will be required to obtain the necessary permits and follow all City of Escondido procedures.

The site is not located on any active or potentially active fault trace as defined by the California Division of Mines and Geology. The nearest active fault to the site is the Rose Canyon Fault, located approximately 11 miles to the west. Other nearby faults include the Elsinore-Julian Fault and the Newport-Inglewood Fault. The site is not considered to possess a significantly greater seismic risk than that of the surrounding area based on accounts from other geotechnical investigations for projects developed in the area; therefore a significant geology and soils impact would not occur.

Proposed Project
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death 101
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Initial Study Addendum -24- City of Escondido, California 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.

Less Than Significant Impact. In 1972, the state passed the Alquist-Priolo (AP) Earthquake Zoning Act to help identify areas subject to severe ground shaking. Earthquake faults are categorized as active, potentially active, and inactive. A fault is classified as active if it is included as an Earthquake Fault Hazard Zone (EFHZ), which indicated movement within the past 11,000 years. The purpose of this Act is to prohibit the placement of most structures for human occupancy across the traces of active faults; thereby mitigating the hazard of fault ruptures. EFHZs identify the probability of ground rupture for future earthquakes. Where such zones are designated, no buildings or structures may be constructed on the trace of the fault. No EFHZs exist within the City of Escondido as reported in the City of Escondido General Plan Environmental Impact Report (EIR), Section 4.6, Geology/Soils. Impacts related to geology/soils would be consistent with those identified in the 2007 Initial Study. ii) Strong seismic ground shaking?
Less Than Significant Impact. Southern California is a seismically active region likely to experience, on average, one earthquake of Magnitude 7.0, and ten (10) earthquakes of Magnitude 6.0 over a period of 10 years. Active faults are those faults that are considered likely to undergo renewed movement within a period of concern to humans. These include faults that are currently slipping, those that display earthquake activity, and those that have historical surface rupture. The California Geological Survey (CGS) defines active faults as those which have had surface displacement within Holocene times (about the last 11,000 years). Such displacement can be recognized by the existence of sharp cliffs in young alluvium, un-weathered terraces, and offset modern stream courses. Potentially active faults are those believed to have generated earthquakes during the Quaternary period, but prior to Holocene times.

The San Jacinto Fault, Elsinore Fault and Rose Canyon Fault have the potential to result in seismic ground shaking within the proposed project area. Conformance with standard engineering practices and design criteria would reduce the effects of seismic ground shaking to less than significant. Impacts related to geology/soils would be consistent with those identified in the 2007 Initial Study. iii) Seismic-related ground failure, including liquefaction? Less Than Significant Impact. Liquefaction is the loss of strength of cohesionless soils when the pore water pressure in the soil becomes equal to the confining pressure. Liquefaction generally occurs as a quicksand type of ground failure caused by strong ground shaking. The primary factors influencing liquefaction potential include groundwater, soil type, relative density of the sandy soils, confining pressure, and the intensity and duration of ground shaking. According to Figure 4.6-3 in the General Plan EIR, the project area is not susceptible to liquefaction hazards. A less than significant impact would result from the project under this threshold; and thus, would not be a significant effect not discussed in the 2007 Initial Study.
iv) Landslides?
No Impact. Landslides are mass movements of the ground that include rock falls, relatively shallow slumping and sliding of soil, and deeper rotational or transitional movement of soil or rock. However, according to the According to Figure 4.6-4 in the General Plan EIR, the project is not located within a landslide hazard area. No impact would occur. A less than significant impact would result from the project under this threshold; and thus, would not be a significant effect not discussed in the 2007 Initial Study. b) Result in substantial soil erosion or the loss of topsoil? 102
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Initial Study Addendum -25- City of Escondido, California Less Than Significant Impact. Grading and trenching during the construction phase of the project would displace soils and temporarily increase the potential for soils to be subject to wind and water erosion. The contractor will be required to comply with standard engineering practices for erosion control and implement applicable elements of the Stormwater Pollution Prevention Plan (SWPPP) during ground disturbing activities. Impacts would be less than significant. A less than significant impact would result from the project under this threshold; and thus, would not be a significant effect not discussed in the 2007 Initial Study. 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?
Less Than Significant Impact. Subsidence, which can be caused by groundwater depletion, seismic activity, and other factors, refers to elevation changes of the land whether slow or sudden. The underlying geologic formations in the proposed project area are mostly granitic and have a very low potential of subsidence. No water extractions or similar practices are anticipated to be necessary that are typically associated with project-related subsidence effects. In addition, surface material that would be disrupted or displaced would be balanced and re-compacted on-site or removed. Adherence to standard engineering practices would result in less than significant impacts related to subsidence of the land. The site is generally flat. There are no steep slopes that could cause a landslide. As stated, there is no liquefaction potential in the project area. A less than significant impact would result from the project under this threshold; and thus, would not be a significant effect not discussed in the 2007 Initial Study.
d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? No Impact. As stated in the General Plan EIR, Section 4.6, Geology/Soils, certain types of clay soils expand when they are saturated and shrink when dried. These are called expansive soils and can pose a threat to the integrity of structures built on them without proper engineering. Expansive soils are derived primarily from weathering of feldspar minerals and volcanic ash. The expansion and contraction of the soil varies with the soil moisture content (wet or dry), and can be aggravated by the way a property is maintained or irrigated.

Human activities can increase the moisture content of the soils, and the threat of expansive soil damage.

According to Figure 4.6-5 in the General Plan EIR, there is no known potential for expansive soils occurring in the project area. No impact would occur. No impact would result from the project under this threshold; and thus, would not be a significant effect not discussed in the 2007 Initial Study. 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? No Impact. The proposed project does not include the implementation of septic tanks or alternative wastewater disposal systems. The project would connect to the existing sewer system located along Bernardo Avenue or Hamilton Lane. No impact would result from the project under this threshold; and thus, would not be a significant effect not discussed in the 2007 Initial Study. e) Directly or indirectly destroy a unique paleontological resource or site or unique geological feature? No Impact. According to the City of Escondido General Plan EIR Figure 4.5-2, the geologic formation on the project site is comprised of granitic and other intrusive crystalline rocks of all ages, mid-Cretaceous. Geologic formations that are composed entirely of volcanic or plutonic igneous rock, such as basalt or granite, do not have any potential for producing fossil remains. No impacts to paleontological resources would occur. No impact would result from the project under this threshold; and thus, would not be a significant effect not discussed in the 2007 Initial Study. Based on the foregoing analysis and information, there is no evidence that the project would require a major change to the 2007 Initial Study. The project would not result in any new significant impact, nor would a substantial increase in the severity of impacts from that described in the 2007 Initial Study result.
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Initial Study Addendum -26- City of Escondido, California

14.8 GREENHOUSE GAS EMISSIONS. Would the project:
a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
2007 Initial Study
An evaluation of greenhouse gas impacts was not required under Appendix G of the CEQA Guidelines when the 2007 Initial Study was prepared.
a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less Than Significant Impact. The vast majority of individual projects do not generate sufficient GHG emissions to create a project-specific impact through a direct influence to climate change; therefore, the issue of climate change typically involves an analysis of whether a projects contribution towards an impact is cumulatively considerable. Cumulatively considerable means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects (CEQA Guidelines, Section 15355). For future projects, the significance of GHG emissions are evaluated based on locally adopted quantitative thresholds, or consistency with a regional GHG reduction plan (such as a Climate Action Plan).

The City of Escondido approved a Climate Action Plan in March 2021. This CAP meets the criteria identified in Section 15183.5 of the CEQA Guidelines and, therefore, is considered a qualified CAP and may be used for the specific purpose of streamlining the analysis of GHG emissions for subsequent projects.

Furthermore, a projects incremental contribution to cumulative GHG emissions may be determined not to be cumulatively considerable. The City has established a GHG screening threshold (set at 500 metric tons carbon dioxide equivalent [MTCO2e] per year) for new development projects to determine if a project would need to demonstrate consistency with the CAP through the Checklist. New development projects that are consistent with the General Plan and are expected to generate fewer than 500 MTCO2e annually would not have a cumulative impact and would not be required to provide additional analysis.

Construction Emissions
Construction of the proposed project would generate temporary GHG emissions primarily associated with the operation of construction equipment, worker trips and truck trips required for hauling excavation spoils, materials and equipment. Site preparation and grading typically generate the greatest emission quantities because the use of heavy equipment is greatest during this phase of construction. Emissions associated with the construction period were estimated based on the projected maximum amount of equipment that would be used on-site at one time. Air districts such as the SDAPCD have recommended amortizing constructionrelated emissions over a 30-year period to calculate annual emissions.

Operational Emissions
Default values used in CalEEMod version 2022.1 are based on the CEC sponsored California Commercial End 104
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Initial Study Addendum -27- City of Escondido, California Use Survey (CEUS) and Residential Appliance Saturation Survey (RASS) studies. CalEEMod provides operational emissions of CO2, N2O and CH4. This methodology has been subjected to peer review by numerous public and private stakeholders, and in particular by the CEC; and therefore, is considered reasonable and reliable for use in GHG impact analysis pursuant to CEQA. It is also recommended by CAPCOA (January 2008).

Emissions associated with area sources (i.e., consumer products, landscape maintenance, and architectural coating) were calculated in CalEEMod based on standard emission rates from CARB, USEPA, and district supplied emission factor values (CalEEMod User Guide, 2022). Emissions from waste generation were also calculated in CalEEMod and are based on the IPCCs methods for quantifying GHG emissions from solid waste using the degradable organic content of waste (CalEEMod User Guide, April 2022). Waste disposal rates by land use and overall composition of municipal solid waste in California was primarily based on data provided by the California Department of Resources Recycling and Recovery (CalRecycle).

Emissions from water and wastewater usage calculated in CalEEMod were based on the default electricity intensity from the CECs 2006 Refining Estimates of Water-Related Energy Use in California using the average values for Northern and Southern California. The proposed Project would generate 84 MT of CO2e emissions annually including the amortized construction emissions. This would be less than the 500 MT CO2e screening threshold referenced above. A less than significant impact would result from the project under this threshold; and thus, would not be a significant effect not discussed in the 2007 Initial Study. b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
No Impact. Specific goals and actions included in the City of Escondido CAP and Title 24 that pertain to the proposed project include those addressing energy and water use reduction, promotion of green building measures, waste reduction, and reduction in vehicle miles traveled. The proposed project would also be required to implement all mandatory green building measures for new residential and commercial development under the CALGreen Code. This would require the project be designed to reduce water consumption, increase building system efficiencies, divert construction waste from landfills, and install low pollutant emitting finish materials. Implementation of these building and appliance standards would result in water, energy, and construction waste reductions for the proposed project. These requirements are included in the CAP Checklist prepared by the applicant to demonstrate project consistency with applicable elements of the CAP.

Consistency with EO S-3-05 and SB 32
EO S-3-05. This EO establishes the following goals: GHG emissions should be reduced to 2000 levels by 2010, to 1990 levels by 2020, and to 80% below 1990 levels by 2050.

SB 32. This bill establishes a statewide GHG emissions reduction target whereby CARB, in adopting rules and regulations to achieve the maximum technologically feasible and cost-effective GHG emissions reductions, shall ensure that statewide GHG emissions are reduced to at least 40% below 1990 levels by December 31, 2030.

The City prepared a GHG emissions inventory included in the above-referenced CAP. The Citys Final CAP was adopted on May 8, 2021. The CAP demonstrates that, with implementation of applicable General Plan objectives and policies, coupled with state and federal actions and execution of CAP measures and actions, the City will reduce GHG emissions consistent with state goals established by Senate Bill 32 and maintain a trajectory to meet its proportional share of the 2050 state target identified in Executive Order S-3-05. As stated, GHG emissions would not exceed the screening threshold of 500 MT CO2e annually; and thus, would not conflict with applicable State goals and policies regarding GHG reductions, include SB 32 and Executive Order S-3-05.

CARB has indicated that statewide, California is on track to achieving both the 2030 and 2050 goals. This is confirmed in the 2017 Scoping Plan and 2022 Update, which states that the Scoping Plan builds upon the 105
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Initial Study Addendum -28- City of Escondido, California successful framework established by the Initial Scoping Plan and First Update, while identifying new, technologically feasible and cost-effective strategies to ensure that California meets its GHG reduction targets.

As stated, the project would not generate enough GHG emissions to cumulatively contribute to global climate change. Measures implemented by the project to reduce overall GHG emissions would also contribute to GHG statewide reduction goals. Thus, the project would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases. No impact would result from the project under this threshold; and thus, would not be a significant effect not discussed in the 2007 Initial Study.

14.9 HAZARDS & HAZARDOUS MATERIALS. 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?
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 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? 2007 Initial Study
Research for the area was conducted by the County Department of Environmental Health and the site was not identified on the County's list of hazardous waste sites. The County Department of Environmental Health regulates the storage and on-site use of any potential hazardous materials such as fuel oil, motor oil, paints and hazardous cleaning materials to prevent the accidental release of, proper prevention of pollution of the environment. While the site is in the vicinity of the Chatham Brothers Barrel Yard, a State Superfund Site, the proposed project site was not known to store hazardous chemicals. Of the three wells previously installed to monitor groundwater quality beneath the site, two wells (MW27 and MW28) were approved by the San Diego Regional Water Quality Control Board (Regional Board) for closure on October 24, 2006. These have subsequently been removed and filled in. The Regional Board also determined the remaining well (MW57), which is located in the northwestern portion of the 6.28-acre site, should remain or that a replacement well, at a location 235 feet to the northwest, and within the proposed private street would be approved if it provides equivalent deep aquifer information.

The property is not adjacent or within two miles of an airport. Any proposed development would not impair the 106
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Initial Study Addendum -29- City of Escondido, California City's emergency response plan according to discussions with the City Fire Department. The areas will not expose people or structures to a significant risk of loss, injury or death involving wildfires since the site is in a suburban setting and once developed much of the property surrounding structures will be irrigated. Any impacts from the proposed annexation and subdivision map creation will be less than significant. Any further development projects will be subject to CEQA review.

A mitigation measure related to monitoring well MW57 stated that the well is to remain on the project site and be accessible to the Chatham Brothers RP Group for monitoring purposes until officially released. Upon release, it is to be removed per Regional Board and City of Escondido standards. Alternatively, if a new replacement well is installed nearby and approved by the Regional Board and Department of Toxic Substances Control (DTSC), existing well MW57 can also then be released and removed per Regional Board and City of Escondido standards. A letter prepared by the Chatham Site PRP Group (May 21, 2009), provided documentation to the California Department of Toxic and Substance Control, that well(s) MW56 (which is unrelated to the project site) and MW57 were decommissioned. The documentation has been provided as Appendix E.

Proposed Project
Information in this section is in part, based on the Phase I Environmental Site Assessment 1100 Hamilton Lane, prepared by Weis Environmental, April 2025 (Appendix F) a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
No Impact. The proposed project would be comprised of single-family residential development. It would not involve the routine transport, use, or disposal of hazardous materials. Impacts related to this threshold would be consistent with those identified in the 2007 Initial Study. 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? Less than Significant Impact. The proposed project is not anticipated to result in a release of hazardous materials into the environment. However, during the short-term period of project construction, there is the possibility of accidental release of hazardous substances such as spilling of hydraulic fluid or diesel fuel associated with construction equipment maintenance. The level of risk associated with the accidental release of these hazardous substances is not considered significant due to the small volume and low concentration of hazardous materials. The contractor will be required to use standard construction controls and safety procedures which would avoid and minimize the potential for accidental release of such substances into the environment. Impacts related to this threshold would be consistent with those identified in the 2007 Initial Study.
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? No Impact. The closest school to the site is Bernardo Elementary School located at 1222 Mountain Heights Drive approximately 0.23 south of the site. While located within ¼ mile of the site, the project would be a single-family residential development. Other than common cleaning supplies, no hazardous materials would be used or generated on-site or proximal to Bernardo Elementary School. This specific threshold was not discussed in the 2007 Initial Study; however, no impact would exceed this threshold. 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 107
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Initial Study Addendum -30- City of Escondido, California the environment?
No Impact. According to the Phase I Environmental Site Assessment (Weis Environmental, Inc., April 2025), the proposed project site is not included on a list of sites containing hazardous materials and would not result in a significant hazard to the public or to the environment. As discussed in the 2007 Initial Study and summarized above, the Chatham Brothers Barrel Yard, a State Superfund Site, is located proximal to the site.

The Phase I ESA prepared for the proposed project states the site is located approximately 700 feet northwest of the site. Further, a water supply well is present on the southern adjoining property of the site and to date, no ground water impacts have been reported in this well. Consistent with the above-referenced mitigation measure, a potentially responsible party is required to complete continued monitoring of groundwater in the area and any future mitigation that may be required should a change in conditions occur. As stated, the onsite MW57 was decommissioned as documented (see Appendix F). Thus, the former Chatham Brothers Barrel Yard is not a recognized environmental condition in connection with the site. This determination would not represent information related to a new or previously undisclosed significant environmental impact. The project would be consistent with the 2007 Initial Study. 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? No Impact. The proposed project is located approximately 10.7 miles southeast of McClellen-Palomar Airport.

Per Exhibit III-5 of the McClellen-Palomar Airport Land Use Compatibility Plan (ALUCP), the project site is located outside the safety compatibility area. Thus, airport operations would not result in a safety hazard for people residing or working in the project area. Impacts related to this threshold would be consistent with those identified in the 2007 Initial Study.
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
No Impact. The proposed project would develop five new single-family residential lots on a 6.02 gross acre site. Both Bernardo Avenue and Hamilton Lane would likely be used by residents for evacuation. The proposed project would have no impact on emergency response plans or emergency evacuation plans. No revisions to adopted emergency plans would be required as a result of the proposed project. Impacts related to this threshold would be consistent with those identified in the 2007 Initial Study. g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
No Impact. The project site is located within a developed area and a Local Responsibility Area for fire services. The project site would be served by the Escondido Fire Department. The project would not expose people or structures to a significant risk of wildland fires because the project site does not adjoin undeveloped wildland areas. Impacts related to this threshold would be consistent with those identified in the 2007 Initial Study.

14.10 HYDROLOGY AND WATER QUALITY. Would the project:
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Initial Study Addendum -31- City of Escondido, California 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; 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
iv. Otherwise impede or redirect flood flows?
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?
2007 Initial Study
The existing parcel includes gentle to moderate slopes (generally between 0 to 15% slope.) and primarily drains east to west, although the eastern edge does drain eastward. The amount of run-off from the site would be expected to incrementally increase upon development of the proposed lots due to impervious surfaces associated with the development of the residential structures and paving. The project would be required to comply with latest National Pollution Discharge Elimination System (NPDES) standards. The City of Escondido's Engineering Department has determined that because the project is required to have all postconstruction storm water treatment measures in place applicable prior to final occupancy and meet all City of Escondido Stormwater Management Standards thereafter, the runoff from the project would not be considered significant and the project would not materially degrade the existing drainage facilities. The City would provide sewer and water service from mains within the adjacent street or easements; consequently, no significant impact is expected to occur to the groundwater table. The project is outside the 100-year flood plain area as identified on current Flood Insurance Rate Maps (FIRM). Therefore, the project site is not subject to potential flooding, landslides or mudflows. Part of the project site is over a once contaminated groundwater, therefore, mitigation will be part of the approval as follows: 1) no drinking water wells shall be drilled on the site; 2) the existing monitoring well on site shall remain until released by DEH; and 3) no excavations shall be allowed on site without proper permits.
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality?
No Impact. The project would construct five new single-family residences and one stormwater retention basin. The basin would be constructed with an impervious liner over gravel and an underdrain system. The filtration media would be comprised of sand, sandy loam and compost to support native plant material.

Stormwater would drain through the media and convey into the underdrain and outlet pipe which would connect to the existing municipal stormwater system located along Hamilton Lane. A riser pipe would be constructed in the pond to directly convey overflow into the outflow pipe. Stormwater would not violate water quality standards or otherwise substantially degrade surface or groundwater quality. No impact would occur.

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Initial Study Addendum -32- City of Escondido, California b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? No Impact. The project would increase the amount of impervious area on the site. However, it would not pump groundwater nor is the site over an aquifer recharge area such that the project would substantially decrease groundwater supplies or interfere substantially with groundwater recharge in a manner that the project would impede sustainable groundwater management of the basin. Further, storm flows not conveyed into the on-site basin would percolate into the ground; thus, providing some recharge post-construction. No impact would occur. Impacts related to this threshold would be consistent with those identified in the 2007 Initial Study.
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 result in substantial erosion or siltation on- or off-site?
Less Than Significant Impact. The drainage pattern would be altered relative to existing conditions.

Stormwater would be conveyed into a new bioretention basin rather than sheet flow through the site.

However, no stream or river would be altered. Any temporary erosion control measures required per the Stormwater Pollution Prevention Plan during construction and post-construction Best Management Practices (BMPs) would minimize erosion and transport of sediments off-site. No impact would occur. Impacts related to this threshold would be consistent with those identified in the 2007 Initial Study. i. result in substantial erosion or siltation on- or offsite; Less Than Significant Impact. As stated, implementation of standard erosion control measures would minimize erosion and transport of sediments off-site. No impact would occur. Impacts related to this threshold would be consistent with those identified in the 2007 Initial Study. ii. substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite;
No Impact. As stated, implementation of standard erosion control measures would minimize erosion and transport of sediments off-site. No off-site flooding would occur with implementation of the proposed project.

No impact would occur. Impacts related to this threshold would be consistent with those identified in the 2007 Initial Study.
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 No Impact. Under the project design, all runoff would convey into the on-site stormwater bioretention basin.

The project will not result in cross-lot drainage or an increase in the rate of off-site run-off in a manner that would exceed the existing capacity of the off-site stormwater system. Further, a riser pipe would be constructed to convey any overflow directly into the municipal stormwater system. No impact would occur.

Impacts related to this threshold would be consistent with those identified in the 2007 Initial Study. iv. Otherwise impede or redirect flood flows?
No Impact. As stated, the downstream point of stormwater discharge from the site will not be altered from the 110
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Initial Study Addendum -33- City of Escondido, California predevelopment condition. However, all runoff would be conveyed into a new on-site stormwater bioretention basin. The project will not result in cross-lot drainage or an increase in the rate of off-site run-off in a manner that would impede or redirect flood flows. The project is required by law to implement stormwater Best Management Practices during construction to minimize erosion and pollutant discharge associated with stormwater runoff to the downstream drainage system. No impact would occur. Impacts related to this threshold would be consistent with those identified in the 2007 Initial Study. d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? No Impact. The project site is not located within a dam inundation area nor are there large open water bodies proximal to the site that would pose a potential seiche impact. The project site is not located within the San Diego County Tsunami Hazard Area as depicted in the California Department of Conservation tsunami map. https://www.conservation.ca.gov/cgs/tsunami/maps/san-diego. No impact would occur. This specific threshold was not discussed in the 2007 Initial Study; however, no impact would exceed this threshold. e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
No Impact. Per the City of Escondido 2020 Urban Water Management Plan, minimal groundwater sources are found throughout the Citys service area. Groundwater wells are privately owned and maintained. The City does not participate in any groundwater withdrawal, storage, or replenishment programs. No groundwater would be pumped on-site nor would it be used as part of potable water supplies provided to the project by the City of Escondido. Thus, the project would not result in any significant impacts relating to water quality. No impact would occur. This specific threshold was not discussed in the 2007 Initial Study; however, no impact would occur this threshold.

14.11 LAND USE AND PLANNING. 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?
2007 Initial Study
The City of Escondido General Plan designates the area as Estate I, allowing single-family residential development. The objective of the Estate I category is to promote single-family development with a maximum density of 1 unit per acre on relatively large lots with minimum 40,000 sq. ft. lot sizes. This designation is often applied in transitional areas between more intensive Suburban and less intensive Rural II development. Public wastewater collection and treatment are required in these areas only if the property cannot accommodate a functional septic system.

The extent of dwelling units permitted on the proposed development by Estate I is dependent on the topography of the site. The General Plan indicates that the maximum development yield of Estate I lands shall be sensitive to topography and be calculated according to the following slope categories:
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Initial Study Addendum -34- City of Escondido, California 0-15%: 1 dwelling unit per 1 acre;
15-25%: 1 dwelling unit per 2 acres;
25-35%: 1 dwelling unit per 4 acres; and
35+ 1: dwelling unit per 20 acres.

The minimum lot size shall be 40,000 square feet, unless the development is clustered. Based on the variable slope provisions contained in the City's General Plan, 6.02 dwelling units would be allowed for a subdivision map, which is consistent with the proposed 5-lot map submitted. The existing zoning of the entire site is proposed to be pre-zoned to RE-40, which is consistent with the General Plan. From a "plan to ground" analysis, the proposal would add five units to the 6.02-acre site. This is not considered significant since the proposed project would be consistent with existing adopted City of Escondido land use policies. No significant land use impact would occur as a result of the proposed project.

Proposed Project
a) Physically divide an established community?
No Impact. The proposed project would construct five new single-family residences and one new stormwater basin on a vacant 6.02-acre site zoned RE-40. The RE-40 designation requires a minimum lot size of 40,000 square feet. The residential lots would be designed to meet or exceed the minimum standard. An existing single-family lot is bordered to the north, south and east by the proposed project. This lot would retain its existing access to Bernardo Avenue. The project will not have an impact on the physical arrangement of an established community. Therefore, no impact would occur. This specific threshold was not discussed in the 2007 Initial Study; however, no impact would occur under this threshold. 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 impact? No Impact. The proposed project is consistent with the General Plan Land Use Elements designation for the project site and with the Official Zoning Map designation of the property. As stated in the General Plan Land Use Element, the Residential Estate designation accommodates detached single-family homes on large lots.

This designation applies to areas that are on the edge of urban development pattern or in areas that are already characterized by an estate development. Clustering is permitted pursuant to General Plan Residential Clustering Policies.

Land Use and Community Form - GOAL 1: A community composed of distinct residential neighborhoods, business districts, and employment centers, whose urban form reflects the natural environmental setting.

Community Character Policy 1.1 New development should serve to reinforce the citys present development pattern of higher-intensity development within the downtown area and lower-intensity development in outlying areas. As a guide toward accomplishing this objective, new development projects shall be at an appropriate density or clustered intensity based upon their compatibility with the majority of the existing surrounding land uses. This policy shall limit density transfers from constrained portions of a property as defined in the land use and open space goals.

Consistent. The proposed project would construct five new single-family residences and one stormwater basin with related infrastructure improvements. The proposed density would be consistent with the current RE-40 zoning.

Community Character Policy 1.2 The boundaries of the Land Use categories depicted on the General Plan are not precise. However, the categories are generally intended to avoid intensification of existing land use or zoning designations where land use compatibility and the objectives of the General Plan are at issue.

Consistent. The proposed project would construct five new single-family residences and one stormwater 112
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Initial Study Addendum -35- City of Escondido, California basin with related infrastructure improvements. The proposed density would be consistent with the current RE-40 zoning and the surrounding properties. The project would develop a vacant site; however, it would not intensify the intensity of existing development.

Community Character Policy 1.3 Focus development into areas where land use changes achieve the communitys long-term goals. Facilitate development that is consistent with the build out vision for each area through incentive programs and efficient administrative and discretionary approval processes for plot plans, Planned Developments, Area Plans, Specific Plans, and Zoning Overlays.

Consistent. The proposed density would be consistent with the current RE-40 zoning. The project would facilitate development that is consistent with the zoning designation which would support the Citys long-term goals. This specific threshold was not discussed in the 2007 Initial Study; however, no impact would exceed this threshold.

14.12 MINERAL RESOURCES. 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?
2007 Initial Study
No significant mineral resources have been identified on the subject site. The limited size of the project would not substantially increase the use of, or result in the depletion of any nonrenewable natural resources.

Proposed 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?
No Impact. The Citys General Plan and Zoning Ordinance would not permit any mineral extraction on or within the vicinity of the project site. Further, the site is not designated as area with known mineral resources.

No impact would occur. This would be consistent with the 2007 Initial Study. 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?
No Impact. Refer to Response 14.12a, above. No impact would occur. This would be consistent with the 2007 Initial Study.

Initial Study Addendum -36- City of Escondido, California

14.13 NOISE. Would the project:
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?
2007 Initial Study
The Noise Element in the City's General Plan contains noise policies which outline acceptable noise levels associated with each type of land use. A 60 dBA CNEL exposure is considered normally acceptable for exterior residential land uses and 45 dBA CNEL for interior levels based upon the assumption that any buildings involved are of normal conventional construction, without any special noise insulation requirements.

The City requires that noise levels be presented in terms of Community Noise Equivalent Level (CNEL). CNEL is a weighted sound level during a 24-hour period, after the addition of 5 decibels (dB) to average sound levels at evening hours (7 PM to 10 PM) and 10 dB to the average night hours (10 PM to 7 AM). The addition of 5 and 10 dB is applied to account for noise sensitivity during evening and nighttime hours.

To assess future noise generation associated with the improvement of the City's circulation system, a Final Environmental Impact Report was prepared in August 2000 for the Escondido General Plan Update illustrating existing and future noise contours. Noise levels depicted for the site show the exposure levels for the entire subject site at below the 60 CNEL standard contained in the Noise/Land Use Compatibility Guidelines of the General Plan. Therefore, the exposure to exterior noise levels is within acceptable levels and with proper design of the future residential units, it is anticipated that the exposure to interior noise will also be within acceptable levels. Therefore, no significant long-term noise impacts associated with the development are anticipated.

Future grading and construction on the site would create temporary noise impacts. Modem construction equipment, properly used and maintained, would meet the noise limits contained in the City's Noise Ordinance. All noise generated by the project would be required to comply with the City's Noise Ordinance.

Upon completion of the project, all construction noise from the project will cease. Because construction operations would be required to conform to the City's Noise Ordinance and because construction noise is temporary, no significant impact from construction noise is anticipated.

Proposed Project
Regulatory Standards.

State Standards. The State of California has adopted noise compatibility guidelines for general land use planning. Land uses addressed by the State standards and the acceptable noise categories for each land use 114
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Initial Study Addendum -37- City of Escondido, California are included in the State of California General Plan Guidelines, which is published and updated by the Governors Office of Planning and Research. The level of acceptability of the noise environment is dependent upon the activity associated with the particular land use. According to the State, an exterior noise environment up to 65 Community Noise Equivalent Level (CNEL) is normally acceptable for single and multi-family residential uses, up to 75 CNEL is conditionally acceptable with special noise insulation requirements, while 75 CNEL and above is identified as "clearly unacceptable" noise levels for residential uses. The maximum allowable interior noise level for residential structures is 45 CNEL.

California Green Building Code. Section 5.507.4.2 of the 2019 California Green Building Code (CALGreen) stipulates that for buildings exposed to a noise level of 65 dB or more when measured as a 1-hour Equivalent Sound Level (Leq), the building façade, including walls, windows, and roofs, shall provide enough sound insulation so that the interior sound level from exterior sources does not exceed 50 dBA during any hour of operation. This applies to non-residential occupancies only. For renovation projects, the requirement only applies to the portion of the project within the scope of the renovation.

California Building Code. Section 1206.4 Allowable Interior Noise Levels of California Building Code 2022, the interior noise levels attributable to exterior sources shall not exceed 45 dB in any habitable room. The noise metric shall be either the day-night average sound level (Ldn) or the community noise equivalent level (CNEL) consistent with noise element of the local general plan.

City of Escondido Municipal Code. The Citys Noise Ordinance (Chapter 17, Article 12. Noise Abatement and Control of the Escondido Municipal Code prohibits the making of disturbing, excessive, offensive or unusually loud noises within the City limits. Excessive noise is considered as a detriment to public health, comfort, convenience, safety, welfare, and prosperity of City residents. Table 3-5 provides Section 17.229(a) sound limit levels for stationary sources at any point on or beyond the boundaries of the property from where the sound is originated according to land use type and a permitted time of day.

According to Section 17.234(a-e), construction activities may not exceed more than one hour of 75 dB sound levels and are limited to Monday through Friday between 7:00 a.m. and 6:00 p.m., or on Saturdays between 9:00 a.m. and 5:00 p.m. However, as stated in Section 17.242 (a), the City Manager may waive any or all of the provisions of this subsection in cases where a variance was obtained, and vehicles or equipment used are reduced to the lowest sounds levels while conducting effective operations Table 3 shows the sound level limits based on the district zones. The above regulatory standards for the project are summarized in Table 3:

Table 3
Sound Level Limits Based on District Zones
Base District Zone Time Applicable Limit One
Hour Average Sound Level
(decibels)
Residential Zones 7:00 a.m. to 10:00 p.m. 50
10:00 p.m. to 7:00 a.m. 45
Multi-residential Zones 7:00 a.m. to 10:00 p.m. 55
10:00 p.m. to 7:00 a.m. 50
Commercial Zones 7:00 a.m. to 10:00 p.m. 60
10:00 p.m. to 7:00 a.m. 55
Light Industrial/Industrial
Park
Anytime 70*
General Industrial Zones Anytime 75*
+ - Subject to provisions of Section 17-229 (c)(5).

City of Escondido General Plan Community Protection Element. As shown on Page VI-22 of the General Plan Community Protection Element, 24-hour average (Ldn or Community Noise Equivalent Level [CNEL]) noise levels ranging between 50 and 60 A-weighted decibels (dBA) are normally acceptable for residential uses. Noise levels ranging between 60 and 70 dBA CNEL are conditionally acceptable assuming the 45 dBA interior standard can be met. As shown in Figure VI-14, a project-related increase in ambient noise levels, when ambient conditions reach 65 dBA CNEL, is significant if it is 3 dBA or higher.

Vibration Standard and Guidelines. Vibration is a unique form of noise as the energy is transmitted through 115
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Initial Study Addendum -38- City of Escondido, California buildings, structures and the ground whereas audible noise energy is transmitted through the air. Thus, vibration is generally felt rather than heard. The ground motion caused by vibration is measured as peak particle velocity (PPV) in inches per second. Vibration impacts to buildings are generally discussed in terms of PPV which describes particle movement over time (in terms of physical displacement of mass). Vibration can impact people, structures, and sensitive equipment groundborne vibration generated by construction projects is usually highest during pile driving, rock blasting, soil compacting, jack hammering, and other high impact demolition and excavation-related activities. Grading also has the potential to cause short-term vibration impacts if large bulldozers, loaded trucks, or other heavy equipment operate within proximity to sensitive land uses. Use of the PPV descriptor is common when addressing potential impacts to structures. Per Caltrans standards, excessive ground-borne vibration would occur if construction-related ground-borne vibration exceeds the severe vibration annoyance potential criteria for human receptors of 0.4 inch per second PPV or the damage potential criteria to older residential structures of 0.3 inch per second PPV for continuous/frequent intermittent construction sources.
a) Would the project cause 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?
Temporary Construction Noise
Less than Significant Impact. During construction, equipment will be audible at off-site receivers. The closest is located near the center of the development area approximately 35 feet from the property boundary and 150 feet from the center of site. Noise levels associated with the use of common construction equipment are shown in Table 4. As shown, the maximum noise level for all the equipment that could be used on-site would exceed the 75 dBA standard referenced in Chapter 17-234 of the Escondido Municipal Code at 50 feet.

However, the code assumes a one-hour average (Leq) noise levels. Heavy equipment would not operate continuously at the same time and in the same location. Assuming, three pieces of equipment (i.e., scraper, loader and truck) are operating at 75, 100 and 150 feet from the nearest receiver over a one-hour period, the Leq would be 74.2 dBA which is less than the 75 dBA Leq standard. As stated in the 2007 Initial Study, the project would meet construction noise requirements. Impacts would be less than significant.

Table 4
Typical Maximum Construction Equipment Noise Levels
Equipment Onsite
Typical Maximum
Level (dBA) 50
Feet from the
Source
Typical Maximum
Level (dBA) 100 Feet
from the Source
Usage Factor
Air Compressor 78 72 40%
Backhoe 78 72 40%
Bobcat Tractor 84 78 40%
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Initial Study Addendum -39- City of Escondido, California Table 4
Typical Maximum Construction Equipment Noise Levels
Equipment Onsite
Typical Maximum
Level (dBA) 50
Feet from the
Source
Typical Maximum
Level (dBA) 100 Feet
from the Source
Usage Factor
Concrete Mixer 79 73 40%
Loader 79 73 40%
Bulldozer 82 76 40%
Jack Hammer 89 83 20%
Pavement Roller 80 74 20%
Street Sweeper 82 76 10%
Man Lift 75 69 20%
Dump Truck 77 71 40%
Mobile Crane 81 75 16%
Excavator/Scraper 84 78 40%
Source: FTA Noise and Vibration Impact Assessment Manual (September 2018), Table 7-1.

Noise levels are based on actual maximum measured noise levels at 50 feet (Lmax).

Noise levels are based on a noise attenuation associated with the usage factor.

Operational Noise
Exterior Traffic Noise. Traffic is the primary noise source that would be generated by operation of the proposed project. As stated, existing noise levels were measured along the northern site boundary on April 25, 2025. The measured Leq during the 15-minute monitoring period was 62.9 dBA Leq, or approximately 63.9 dBA CNEL. Ambient conditions are less than 65 dBA; the normally compatible noise level for residences referenced in the General Plan Community Protection Element policy for exterior noise exposure to transportation related noise at residences and other sensitive properties. A doubling or halving of sound energy is required for the human ear to perceive an increase in noise levels. A change of 3 dBA is associated with the doubling or halving of sound energy; thus, the project would need to double existing volumes on Hamilton Lane and Bernardo Avenue to create a significant traffic noise impact. During monitoring, a total of 55 cars/light trucks passed the monitoring site on Bernardo Avenue and 59 cars/light trucks passed the site on Hamilton Lane. Peak hour volumes would be approximately 220 vehicles on Bernardo Avenue and 236 vehicles on Hamilton Lane. The project would add approximately 0.5 trips per hour which when added to peak hour traffic would have no noticeable effect on noise levels. Operational impacts would be less than significant. This would be consistent with the 2007 Initial Study. b) Generation of excessive groundborne vibration or groundborne noise levels? Temporary Vibration Impacts
Less than significant. The vibration velocity level for perception by humans is approximately 65 VdB. A vibration velocity of 75 VdB is the approximate dividing line between barely perceptible and distinctly perceptible levels. As stated, the California Department of Transportation uses the following standards when addressing vibration. Excessive ground-borne vibration would occur if construction-related ground-borne vibration exceeds the severe vibration annoyance potential criteria for human receptors of 0.4 inch per second PPV or the damage potential criteria to older residential structures of 0.3 inch per second PPV for continuous/frequent intermittent construction sources, as specified by Caltrans (April 2020) The PPV and accompanying VdB level associated with common construction equipment is shown in Table 5. Based on the project geotechnical study and information from the applicant, heavy impact construction methods that could generate enough vibration to damage buildings proximal to the project site (i.e., pile driving, rock breaking, drilling, blasting) would not be required for the project. 117 Attachment "3"
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Initial Study Addendum -40- City of Escondido, California Construction activity on the project site would be temporary and vibration events would be transitory occuring only during equipment pass bys. Using vibration levels associated with a large bulldozer, the piece of grading equipment with the highest vibration level, as a worst-case scenario, groundborne vibration would be approximately 0.089 PPV at 25 feet (see Table 5 below). Similarly, if a hoe ram were required to break rocks during grading, a similar PPV would be expected. The PPV generated by a heavy bulldozer or hoe ram at 25 feet are below the vibration thresholds of significance referenced above.

Table 5
Vibration Source Levels for Construction Equipment
Peak Particle Velocity
(inches/second) at 25 feet
Approximate Vibration Level
LV (dVB) at 25 feet
Pile driver (impact) 1.518 (upper range) 112

0.644 (typical) 104
Pile driver (sonic) 0.734 upper range 105

0.170 typical 93
Clam shovel drop (slurry wall) 0.202 94
Hydromill (slurry wall - soil) 0.008 in soil 66
Hydromill (slurry wall - rock 0.017 in rock 75
Vibratory Roller 0.21 94
Hoe Ram 0.089 87
Large bulldozer 0.089 87
Caisson drill 0.089 87
Loaded trucks 0.076 86
Jackhammer 0.035 79
Small bulldozer 0.003 58
Source: Transit Noise and Vibration Impact Assessment, Federal Transit Administration, September 2018.

Operational Impacts. The proposed project is a residential development. It would not generate vibration postconstruction. No operational vibration impacts would occur. This issue was not discussed in the 2007 Initial Study; however, as stated, vibration during construction and operation would be less than significant. 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? No Impact. The proposed project is located approximately 10.7 miles southeast of McClellen-Palomar Airport.

Per Exhibit III-1 of the McClellen-Palomar Airport Land Use Compatibility Plan (ALUCP), the project site is located outside the 60 dB CNEL noise contour. No impact would occur. This issue was not discussed in the 2007 Initial Study; however, as stated no impact would occur under this threshold.

Initial Study Addendum -41- City of Escondido, California

14.14 POPULATION & HOUSING. 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? 2007 Initial Study
Population within the City would incrementally increase as a result of developing the proposed five residential lots. The City's General Plan anticipates single-family residential use on the project site and the density of the proposal is consistent with the City's General Plan Land Use Designation of Estate I. The proposed development would incrementally contribute to the City's Regional Share Housing requirements. The development of the site would not be considered growth-inducing since the project site is located within an established community. Therefore, the project would not result in a significant population and housing impact.

Proposed 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)?
Less than Significant Impact. The proposed project would construct five new single-family residences and one stormwater detention basin. As stated, the number of housing units in the City was projected to be 54,910 in 2025 and 58,990 in 2035, or an increase in 4,080 housing units. Furthermore, the Citys population was projected to be 165,127 residents in 2025 and 169,122 residents in 2035, or an increase of 3,995 residents over the period. The average household size is 2.8 people per dwelling unit, which translates into approximately 14 residents for the proposed project. The proposed number of units would be within the total projected for the City of Escondido by 2035. Further, because the project is consistent with the zoning and General Plan designation, the project would not induce substantial population growth. A less than significant impact would occur. This is consistent with the 2007 Initial Study. b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No Impact. The proposed project would not require the removal existing housing, and therefore, would not necessitate the construction of replacement housing elsewhere. No impact would occur. This issue was not discussed in the 2007 Initial Study; however, no impact would occur under this threshold.

Initial Study Addendum -42- City of Escondido, California

14.15 PUBLIC SERVICES. 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:

Fire Protection?
Police Protection?
Schools?
Parks?
Other public facilities?
2007 Initial Study
Fire - The City Fire Department has indicated their ability to adequately serve the proposed project. One additional fire hydrant and a fire tum-around are to be located within the project is part of the proposal.

Law Enforcement -The City's Police Department currently serves the area and can easily included the property within a patrol beat. The Department has not expressed concerns regarding its ability to serve the site.

Schools - The site is within the Escondido Union School District and the Escondido Union High School District. Students would likely attend the new Bernardo Elementary School, Bear Valley Middle School, and San Pasqual High School. The incremental impact of the proposed residential developments on the school system would be offset by the impact fees collected upon issuance of building permits.

Proposed Project
1) Fire protection?
Less than significant. The Escondido Fire Department provides fire and emergency medical services to the City of Escondido. Fire Station 5 is the nearest station to the project site. It is located at 2319 Felicita Road approximately 800 feet northeast of the site. Given the nature of the project, demand for fire and emergency service may increase over existing conditions. The project is consistent with the land use designation for the site and would not increase the population beyond what was anticipated in the Escondido General Plan.

Further, the project would be designed and constructed consistent with applicable codes and standards for access and fire suppression infrastructure. The payment of impact fees would fund any necessary improvements to the Escondido Fire Department infrastructure to maintain or improve the efficiency of department operations. The project would not require the construction of a new fire station to maintain service ratios within the service area served by Fire Station 5. Impacts would be less than significant. This determination would be consistent with the 2007 Initial Study. 120
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Initial Study Addendum -43- City of Escondido, California 2) Police protection?
Less than significant. The Escondido Police Department provides law enforcement services to the City of Escondido. The headquarters is located at 1163 North Centre City Parkway approximately 3.2 miles north of the site. Given the nature of the project, demand for law enforcement services may increase over existing conditions. The project is consistent with the land use designation for the site and would not increase the population beyond what was anticipated in the Escondido General Plan. The payment of impact fees would fund any necessary improvements to the Escondido Police Department infrastructure to maintain or improve the efficiency of department operations. The project would not require the construction of a new police station to maintain service ratios within the service area. Impacts would be less than significant. This determination would be consistent with the 2007 Initial Study.
3) Schools?
Less than significant. The nearest school to the project site is Bernardo Elementary School located at 1222 Mountain Heights Drive approximately 0.23 miles south of the site. The proposed project would likely provide housing for school-aged children; thus, affecting demand for school services. The applicant would be required to pay a developer fee of $4.46 per square foot (or current rate at the time of assessment) of assessable residential space to support ongoing development of school facilities. Impacts would be less than significant.

This determination would be consistent with the 2007 Initial Study. 4) Parks?
Less than significant. Felicita County Park is the most directly accessible park from the project site. It is located approximately 0.3 miles south of the project site along the east side of Park Drive. The increase in population living in the area is not expected to impact demand for park facilities. The project would not remove park or recreational facilities that would require replacement elsewhere. This issue was not addressed in the 2007 Initial Study; however, as stated, impacts would be less than significant. 5) Other public facilities?
Less than significant. Other public facilities include streets, libraries, senior centers, community centers, and pools, all of which are intended to serve the general public. No impacts to other public facilities are anticipated to occur with the construction and operation of the proposed project. This issue was not addressed in the 2007 Initial Study; however, as stated, impacts would be less than significant.

14.16 RECREATION. Would the project:
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?
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Initial Study Addendum -44- City of Escondido, California 2007 Initial Study
Development of the area would result in an incremental demand on the City's recreational facilities. However, the development fees paid by this project would offset the anticipated impact on the existing facilities. The proposed project would not affect existing recreational opportunities since the site is not used for recreational activities; consequently no significant impact to recreational resources would occur as a result of the project.

Proposed Project
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? No Impact. Implementation of the proposed project will not affect any existing park facilities nor increase the demand for additional recreational facilities to the extent that it would result in or increase physical deterioration of the facility. No impact would occur. This is consistent with the 2007 Initial Study. a) 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? No Impact. No additional recreational facilities that could potentially result in an adverse impact on the environment would be constructed. No impact would occur. This is consistent with the 2007 Initial Study.

14.17 TRANSPORTATION/TRAFFIC. Would the project:
a. Conflict with 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?
2007 Initial Study
The project's private street (36' R-O-W) serving four of the proposed lots would connect with Hamilton Lane at a point nearly 300 feet east of the existing intersection of Bernardo Avenue and Hamilton Lane and directly across from the existing intersection of Hamilton Lane and Rancho Diego Court. Hamilton Lane is currently a Local Collector (63' R-O-W). Traffic from the newly proposed private street would either continue west or eastbound on Hamilton Lane. The fifth proposed lot would have access via a proposed driveway connected to Bernardo Avenue approximately 60 feet south of the intersection of Bernardo Avenue and Hamilton Lane.

The project will potentially add traffic to the existing intersection of Bernardo Avenue and Hamilton Lane 122
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Initial Study Addendum -45- City of Escondido, California (County). Based on San Diego Association of Governments' (SANDAG) traffic generation rates for the San Diego region, the proposed subdivision would generate approximately 12 trips per dwelling unit, or approximately 60 new ADTs. The City's Engineering Department indicated that the increase of 60 additional trips onto this segment of Hamilton Lane will not significantly impact the existing Levels of Service on the adjacent streets and intersections. Stable traffic flow is maintained along the segment and ability to maneuver within the vicinity of the project and along the Hamilton Lane segment is not significantly restricted. The City's Engineering Department further indicated the proposed project is not anticipated to have any significant individual or cumulative impacts to the circulation system or degrade the LOS (Levels of Service) on any of the adjacent roadways or intersections.

Proposed Project
Information in this section is summarized from the Scoping Agreement for Transportation Studies, prepared by Mizuta Traffic Consulting, Inc., March 2025 and provided as Appendix G. a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
No Impact. The project would provide five new single-family residences and one stormwater basin. The project would generate approximately 80 daily trips. The project would not require any improvements to either Bernardo Avenue or Hamilton Lane. There is no existing transit proximal to the site; thus, transit would not be affected by the project. The project would provide curb/gutter/sidewalk frontage improvements which would address existing pedestrian deficiencies in the project area. No bicycle lanes are currently provided; thus, none would be affected by the project. The project would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities. This issue was not addressed in the 2007 Initial Study; however, no impact would occur under this threshold. b) Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)? Less than Significant Impact. As stated, the project would generate 80 new daily vehicle trips. The Scoping Agreement for Transportation Studies states that the project would screen out of the need to provide a complete Vehicle Miles Traveled (VMT) analysis because it does not exceed 200 daily trips. The project would not conflict with CEQA Guidelines Section 15064.3, subdivision (b). A less than significant impact would occur. This is consistent with the impact determination in the 2007 Initial Study. c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? No Impact. The project would provide five new residences and a stormwater basin. The project would not modify the existing transportation system or introduce incompatible uses. This issue was not addressed in the 2007 Initial Study; however, no impact would occur under this threshold. e) Result in inadequate emergency access?
No Impact. While the project would increase traffic by 80 daily trips, it would not adversely impact emergency access by providing inadequate site access or otherwise impacting use of local streets by emergency vehicles.

This issue was not addressed in the 2007 Initial Study; however, no impact would occur under this threshold.

Initial Study Addendum -46- City of Escondido, California

14.18 TRIBAL CULTURAL RESOURCES. 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 California Native American tribe, and that is:
i. 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
ii. 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 Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe. 2007 Initial Study
An evaluation of tribal cultural resource impacts per AB 52 was not required under Appendix G of the CEQA Guidelines when the 2007 Initial Study was prepared.

Proposed Project
i)) 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 California Native American tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? No impact. As stated in Section 14.5, Cultural Resources; the SCIC records search identified three cultural resources studies (SD-8588, -8596, and -10211) that were conducted within the project site and an additional 42 studies within a 0.5-mile radius. None identified any historic resources on-site that are listed or eligible for listing on the NRHP or CRHR. Further, no historic resources were identified. No impact to historic resources would occur.
ii) 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 California Native American tribe, and that is 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 Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe)? Less than Significant. As stated in Section 4.15, no Tribal Cultural Resources were identified within the project site through Native American scoping. However, the Native American scoping identified the project 124
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Initial Study Addendum -47- City of Escondido, California vicinity as highly sensitive for prehistoric/Native American resources. This sensitivity is supported by the five previously recorded resources with prehistoric components within 0.5-mile of the project site, including the CRHR/NRHP-listed multicomponent site P-37-000570 within Felicita Park, which contains a large prehistoric habitation component.

Given the presence of a previously recorded archaeological site within the project site and evidence of archaeological sensitivity indicated by the records search results and responses from tribal contacts, archaeological and Native American monitoring of all project-related earth disturbing activities is recommended as a Condition of Approval (CUL-1) for addressing any discoveries of cultural resources. The discovery of human remains would be addressed by complying with State Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98. With implementation of existing regulations addressing the discovery of human remains, impacts to cultural resources would be less than significant.

14.19 UTILITIES AND SERVICE SYSTEMS. Would the project:
a. Require or result in the relocation or construction of new or expanded water or wastewater treatment or storm water 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 projects projected demand in addition to the providers existing commitments?
d. Generate solid waste is excess of State or local standards, or in excess of the capacity of local infrastructures, 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?
2007 Initial Study
Sewer Service. There currently exists a public sewer line in City streets immediately off-site that would accommodate the site's needs. City Public Utilities staff has confirmed that adequate treatment capacity exists to serve the project site.

Water Service. The site is within the Rincon Water District's Improvement District #1. Currently, adequate water delivery is available from water lines in adjacent streets.

Storm Water/Refuse Collection. The proposed project is required to comply with latest National Pollution Discharge Elimination System (NPDES) standards, City of Escondido's post-construction storm water treatment measures, and meet all City of Escondido Storm Water Management Standards thereafter to meet state and federal requirements.
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Initial Study Addendum -48- City of Escondido, California Escondido Disposal currently provides solid waste service to the area and the project would not result in a significant increase in solid waste. The proposal would not result in any individual or cumulative impacts to utilities and service systems.

Streets. The annexation will include the portion of Bernardo Avenue west of the project, the portion of Hamilton Lane north of the project (to the centerline plus ten feet) and the intersection of Bernardo Avenue and Hamilton Lane. Road maintenance responsibilities will fall either on the City or the County and it is anticipated that no significant impacts to services will result.

Proposed Project
a) Require or result in the relocation or construction of new or expanded, water or wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction of which could cause significant environmental effects?
No Impact. The project would connect to existing water/sewer and telecommunication infrastructure located adjacent to the site. No utility extensions, other than what is required to connect the project to adjacent offsite infrastructure would be required. The project would not require the expansion of existing water, wastewater or other utility systems, the construction of which could cause significant environmental effects.

No impact would occur. This would be consistent with the 2007 Initial Study. b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
Less than Significant. The project site is located within the City of Escondido Water Department service area. The City owns, operates, and maintains approximately 44 miles of pipeline, 11 reservoirs, five pump stations, and two dams (and associated lakes). These resources are used to provide potable water to approximately 27,170 metered potable connections. As reported in the 2020 Urban Water Management Plan, the supply reliability assessment considered factors that could limit the expected quantity of current and projected water sources through 2045. The Citys water service reliability assessment and Drought Risk Assessment results indicate that no water shortages are anticipated within the next 25 years under normal, single-dry, and multiple dry years conditions.

The proposed project would have an annual water demand of approximately 996,273 gallons (both indoor use and outdoor irrigation demand) or 3.05-acre feet. As stated, the project would be consistent with zoning; thus, water demand has been incorporated into demand projections. No new or expanded entitlements would be required with implementation of the proposed project. Water supply impacts would be less than significant.

This would be consistent with the 2007 Initial Study.
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 projects projected demand in addition to the providers existing commitments?
No Impact. As stated in threshold a, the project would connect to existing sewer infrastructure located adjacent to the site. The City owns and operates the Hale Avenue Resource Recovery Facility (HARRF), which has a design flow capacity of 18 million gallons per day (MGD) and the capacity to handle instantaneous flows of up to 36 MGD. Assuming sewer demand is 60 percent of indoor water demand (462 gallons daily), the daily sewer demand would be 277 gallons per day which is well within the daily treatment capacity of the HARRF. No new or expanded entitlements for wastewater treatment would be required with implementation of the proposed project. No impact would occur. This would be consistent with the 2007 Initial Study.
d) Generate solid waste is excess of State or local standards, or in excess of the capacity of local 126
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Initial Study Addendum -49- City of Escondido, California infrastructures, or otherwise impair the attainment of solid waste reduction goals? No Impact. The City contracts solid waste collection services with Escondido Disposal. Waste is disposed at the Miramar Landfill in the City of San Diego. The Miramar Landfill is permitted to accept up to a maximum of 2,250 tons of waste per day. According to CalEEMod 2022.1 projections, the daily project demand would be 18 pounds or 3.32 tons annually. Project operation would not generate solid waste; and thus, would not 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. No impact would occur. This would be consistent with the 2007 Initial Study.
e) Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
No Impact. The proposed project would be subject to the Citys Solid Waste and Recycling Code (Chapter 14 of the Citys Municipal Code and 2022 Calgreen section 5.408) which will require that construction debris be recycled. The project would not 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. No impact would occur. This issue was not discussed in the 2007 Initial Study; no impact would occur under this threshold.

14.20 WILDFIRE. 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 wildlife risks, and thereby expose project occupants to pollutant concentrations from a wildlife 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?
2007 Initial Study
This issue was not discussed in the 2007 Initial Study. As stated in Section 14.9, Hazards and Hazardous Materials, the area will not expose people or structures to a significant risk of loss, injury or death involving wildfires since the site is in a suburban setting and once developed much of the property surrounding structures will be irrigated.

Proposed Project
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Initial Study Addendum -50- City of Escondido, California a-d) No Impact. The project site is located in an urbanized area in southern Escondido and within a Local Responsibility Area under the jurisdiction of the Escondido Fire Department. There are no wildlands located on or within proximity of the project site. No wildland fires would occur in the project area; thus, thresholds a-d would not be applicable. No impact would occur. This is consistent with the 2007 Initial Study determination.

6. MITIGATION MONITORING AND REPORTING PROGRAM COMPLIANCE As stated above, the following mitigation measures were identified and incorporated into the Mitigation Monitoring and Reporting Program (MMRP) as part of the 2007 Initial Study. The proposed project would be required to comply with applicable measures. The follow summarizes the mitigation measures and applicability to the proposed project.

Air Quality
2007 Initial Study Mitigation. Prior to construction and issuance of grading and building permits, a sitespecific analysis shall be prepared to determine equipment and methods necessary to protect adjacent properties.

Proposed Project. A project-specific air quality analysis was prepared for the project and provided as part of the discussion in Section 14.3, Air Quality. The proposed project would have no adverse effect on air quality.

This mitigation measure has been satisfied.

Biological Resources
2007 Initial Study Mitigation. To address direct impacts to non-native grasslands and coastal sage scrub, the proposed mitigation ratio is 0.25:1 through the purchase of habitat credits from an approved mitigation bank for non-native grassland. For impacts to 0.02 acres of coastal sage scrub, U.S. Fish and Wildlife and California Department of Fish and Game approval would be required.

Proposed Project. No non-native grassland or coastal sage scrub vegetation was reported in the Biological Resources Memorandum prepared by Tierra Data, Inc., July 2024. These habitat types no longer occur on the site. However, as stated, mitigation from the 2007 Initial Study pertaining to non-native grassland and coastal sage scrub remains applicable and would be enforced at the Citys discretion. 2007 Initial Study Mitigation. Impacts to native Live Oaks trees will be mitigated by relocating the four Live Oaks on-site and planting four new Live Oak trees on-site.

Proposed Project. As stated, multiple trees would be removed; however, the Project would be in compliance with Citys Municipal Code requirements for trees. Regardless, for each Live Oak tree removed, the tree would be replaced on-site and one additional tree would be planted on-site as so stated in the 2007 Initial Study.
2007 Initial Study Mitigation. A qualified biologist must inspect trees for nests prior to any brushing, grading, tree relocation or construction within close proximity to, or within the existing Oaks discussed in the Biological Report's addendum of 2/14/07. If any active nests of sensitive species are found, no impacts will be allowed until all younq have fledqed.

Proposed Project. As stated, multiple trees would be removed to accommodate the proposed project. A preconstruction nesting survey would be required consistent with the 2007 Initial Study. 2007 Initial Study Mitigation. The applicant shall provide funding to the satisfaction of the City for the five128 Attachment "3"
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Initial Study Addendum -51- City of Escondido, California year monitoring of the oak trees with sufficient reserve for the replacement of any dead/dying stock.

Proposed Project. The proposed project would replace Live Oak trees removed during construction at a 1:1 ratio on-site and plant one additional Live Oak tree as mitigation for impacts to Live Oak tree impacts.

Hazardous Materials
2007 Initial Study Mitigation. Monitoring well MW57 is to remain onsite and be accessible to the Chatham Brothers RP Group for monitoring purposes until officially released. Upon release, it is to be removed per Regional Board and City of Escondido standards. Alternately, if a new replacement well is installed nearby and approved by the Regional Board and Department of Toxic Substances Control (DTSC), existing well MW57 can also then be released and removed per Regional Board and City of Escondido standards.

Proposed Project. Monitoring Well MW57 has been removed from the site as documented in the May 21, 2009, letter provided by the Chatham Site PRP Group. This mitigation measure has been satisfied.

Hydrology/Water Quality
2007 Initial Study Mitigation. No drinking water wells are to be drilled on-site and no excavations shall be allowed on-site without proper permits.

Proposed Project. Potable water would be provided by the City of Escondido Water Department. No wells would be drilled on-site. This mitigation measure is no longer applicable.

7. SPECIFIC MMRP ISSUE AREA CONDITIONS/REQUIREMENTS
The project applicant would be required to implement mitigation measures from the 2007 Initial Study that pertain to site conditions and project impacts as defined herein, as well as, current Conditions of Approval that apply to the proposed project. No new significant or adverse environmental impacts requiring mitigation were identified for the proposed project. Implementation of Condition of Approval CUL-1 at the Citys discretion, would address Native American monitoring recommendations during grading and ground disturbance activities.

8. SIGNIFICANT UNMITIGATED IMPACTS
No significant unmitigated impacts were identified in the 2007 Initial Study or the proposed project. The proposed project would not result in any additional significant impacts nor would it result in an increase in the severity of impacts from that described in the previously adopted 2007 Initial Study.

9. CERTIFICATION
Copies of the addendum, the 2007 Initial Study and Addendum, the Mitigation Monitoring and Reporting Program, and associated project-specific technical appendices, may be reviewed by appointment in the City of Escondido Planning Department office.

Melissa DiMarzo, Assistant Planner II
Date
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Appendix A California Emission Estimator
Model Output File
Exhibit C
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Hamilton Lane Escondido Detailed Report, 3/6/2025 1 / 75 Hamilton Lane Escondido Detailed Report Table of Contents 1. Basic Project Information 1.1. Basic Project Information 1.2. Land Use Types 1.3. User-Selected Emission Reduction Measures by Emissions Sector 2. Emissions Summary 2.1. Construction Emissions Compared Against Thresholds 2.2. Construction Emissions by Year, Unmitigated 2.3. Construction Emissions by Year, Mitigated 2.4. Operations Emissions Compared Against Thresholds 2.5. Operations Emissions by Sector, Unmitigated 2.6. Operations Emissions by Sector, Mitigated 3. Construction Emissions Details 3.1. Demolition (2026) - Unmitigated 3.2. Demolition (2026) - Mitigated 3.3. Site Preparation (2026) - Unmitigated Exhibit C 131
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Hamilton Lane Escondido Detailed Report, 3/6/2025 2 / 75 3.4. Site Preparation (2026) - Mitigated 3.5. Grading (2026) - Unmitigated 3.6. Grading (2026) - Mitigated 3.7. Building Construction (2026) - Unmitigated 3.8. Building Construction (2026) - Mitigated 3.9. Building Construction (2027) - Unmitigated 3.10. Building Construction (2027) - Mitigated 3.11. Paving (2027) - Unmitigated 3.12. Paving (2027) - Mitigated 3.13. Architectural Coating (2027) - Unmitigated 3.14. Architectural Coating (2027) - Mitigated 4. Operations Emissions Details 4.1. Mobile Emissions by Land Use 4.1.1. Unmitigated 4.1.2. Mitigated 4.2. Energy 4.2.1. Electricity Emissions By Land Use - Unmitigated 4.2.2. Electricity Emissions By Land Use - Mitigated Exhibit C 132
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Hamilton Lane Escondido Detailed Report, 3/6/2025 3 / 75 4.2.3. Natural Gas Emissions By Land Use - Unmitigated 4.2.4. Natural Gas Emissions By Land Use - Mitigated 4.3. Area Emissions by Source 4.3.1. Unmitigated 4.3.2. Mitigated 4.4. Water Emissions by Land Use 4.4.1. Unmitigated 4.4.2. Mitigated 4.5. Waste Emissions by Land Use 4.5.1. Unmitigated 4.5.2. Mitigated 4.6. Refrigerant Emissions by Land Use 4.6.1. Unmitigated 4.6.2. Mitigated 4.7. Offroad Emissions By Equipment Type 4.7.1. Unmitigated 4.7.2. Mitigated 4.8. Stationary Emissions By Equipment Type Exhibit C 133
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Hamilton Lane Escondido Detailed Report, 3/6/2025 4 / 75 4.8.1. Unmitigated 4.8.2. Mitigated 4.9. User Defined Emissions By Equipment Type 4.9.1. Unmitigated 4.9.2. Mitigated 4.10. Soil Carbon Accumulation By Vegetation Type 4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated 4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated 4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated 4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated 4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated 4.10.6. Avoided and Sequestered Emissions by Species - Mitigated 5. Activity Data 5.1. Construction Schedule 5.2. Off-Road Equipment 5.2.1. Unmitigated 5.2.2. Mitigated 5.3. Construction Vehicles Exhibit C 134
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Hamilton Lane Escondido Detailed Report, 3/6/2025 5 / 75 5.3.1. Unmitigated 5.3.2. Mitigated 5.4. Vehicles 5.4.1. Construction Vehicle Control Strategies 5.5. Architectural Coatings 5.6. Dust Mitigation 5.6.1. Construction Earthmoving Activities 5.6.2. Construction Earthmoving Control Strategies 5.7. Construction Paving 5.8. Construction Electricity Consumption and Emissions Factors 5.9. Operational Mobile Sources 5.9.1. Unmitigated 5.9.2. Mitigated 5.10. Operational Area Sources 5.10.1. Hearths 5.10.1.1. Unmitigated 5.10.1.2. Mitigated 5.10.2. Architectural Coatings Exhibit C 135
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Hamilton Lane Escondido Detailed Report, 3/6/2025 6 / 75 5.10.3. Landscape Equipment 5.10.4. Landscape Equipment - Mitigated 5.11. Operational Energy Consumption 5.11.1. Unmitigated 5.11.2. Mitigated 5.12. Operational Water and Wastewater Consumption 5.12.1. Unmitigated 5.12.2. Mitigated 5.13. Operational Waste Generation 5.13.1. Unmitigated 5.13.2. Mitigated 5.14. Operational Refrigeration and Air Conditioning Equipment 5.14.1. Unmitigated 5.14.2. Mitigated 5.15. Operational Off-Road Equipment 5.15.1. Unmitigated 5.15.2. Mitigated 5.16. Stationary Sources Exhibit C 136
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Hamilton Lane Escondido Detailed Report, 3/6/2025 7 / 75 5.16.1. Emergency Generators and Fire Pumps 5.16.2. Process Boilers 5.17. User Defined 5.18. Vegetation 5.18.1. Land Use Change 5.18.1.1. Unmitigated 5.18.1.2. Mitigated 5.18.1. Biomass Cover Type 5.18.1.1. Unmitigated 5.18.1.2. Mitigated 5.18.2. Sequestration 5.18.2.1. Unmitigated 5.18.2.2. Mitigated 6. Climate Risk Detailed Report 6.1. Climate Risk Summary 6.2. Initial Climate Risk Scores 6.3. Adjusted Climate Risk Scores 6.4. Climate Risk Reduction Measures Exhibit C 137
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Hamilton Lane Escondido Detailed Report, 3/6/2025 8 / 75 7. Health and Equity Details 7.1. CalEnviroScreen 4.0 Scores 7.2. Healthy Places Index Scores 7.3. Overall Health & Equity Scores 7.4. Health & Equity Measures 7.5. Evaluation Scorecard 7.6. Health & Equity Custom Measures 8. User Changes to Default Data Exhibit C 138
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Hamilton Lane Escondido Detailed Report, 3/6/2025 9 / 75 1. Basic Project Information 1.1. Basic Project Information Data Field Value Project Name Hamilton Lane Escondido Construction Start Date 3/2/2026 Operational Year 2026 Lead Agency Land Use Scale Project/site Analysis Level for Defaults County Windspeed (m/s) 2.20 Precipitation (days) 26.6 Location 33.089247938234934, -117.08811878755569 County San Diego City Escondido Air District San Diego County APCD Air Basin San Diego TAZ 6294 EDFZ 12 Electric Utility San Diego Gas & Electric Gas Utility San Diego Gas & Electric App Version 2022.1.1.29 1.2. Land Use Types Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft) Special Landscape Area (sq ft) Population Description Single Family Housing 5.00 Dwelling Unit 1.62 9,750 58,564 14.0 Exhibit C 139
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Hamilton Lane Escondido Detailed Report, 3/6/2025 10 / 75 1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector # Measure Title Construction C-2* Limit Heavy-Duty Diesel Vehicle Idling Water W-7 Adopt a Water Conservation Strategy * Qualitative or supporting measure. Emission reductions not included in the mitigated emissions results. 2. Emissions Summary 2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Unmit. 1.46 12.9 14.5 0.02 0.58 2.85 3.43 0.53 1.36 1.89 2,548 2,548 0.10 0.02 0.33 2,558 Mit. 1.46 12.9 14.5 0.02 0.58 2.85 3.43 0.53 1.36 1.89 2,548 2,548 0.10 0.02 0.33 2,558 %Reduced Daily, Winter (Max) Unmit. 6.22 13.0 15.1 0.02 0.51 2.51 3.01 0.47 1.19 1.65 2,604 2,604 0.11 0.02 0.01 2,614 Mit. 6.22 13.0 15.1 0.02 0.51 2.51 3.01 0.47 1.19 1.65 2,604 2,604 0.11 0.02 0.01 2,614 %Reduced Average Daily (Max) Unmit. 0.64 5.40 6.29 0.01 0.19 0.06 0.25 0.17 0.03 0.20 1,138 1,138 0.05 0.01 0.03 1,143 Mit. 0.64 5.40 6.29 0.01 0.19 0.06 0.25 0.17 0.03 0.20 1,138 1,138 0.05 0.01 0.03 1,143 Exhibit C 140
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Hamilton Lane Escondido Detailed Report, 3/6/2025 11 / 75 %Reduced Annual (Max) Unmit. 0.12 0.99 1.15 < 0.005 0.03 0.01 0.05 0.03 < 0.005 0.04 188 188 0.01 < 0.005 0.01 189 Mit. 0.12 0.99 1.15 < 0.005 0.03 0.01 0.05 0.03 < 0.005 0.04 188 188 0.01 < 0.005 0.01 189 %Reduced 2.2. Construction Emissions by Year, Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily - Summer (Max) 2026 1.46 12.9 14.5 0.02 0.58 2.85 3.43 0.53 1.36 1.89 2,548 2,548 0.10 0.02 0.33 2,558 Daily - Winter (Max) 2026 1.44 13.0 15.1 0.02 0.51 2.51 3.01 0.47 1.19 1.65 2,604 2,604 0.11 0.02 0.01 2,614 2027 6.22 8.28 9.98 0.02 0.26 0.11 0.28 0.24 0.02 0.25 1,829 1,829 0.07 0.02 0.01 1,836 Average Daily 2026 0.64 5.40 6.29 0.01 0.19 0.06 0.25 0.17 0.03 0.20 1,138 1,138 0.05 0.01 0.03 1,143 2027 0.21 0.37 0.49 < 0.005 0.01 < 0.005 0.02 0.01 < 0.005 0.01 84.0 84.0 < 0.005 < 0.005 0.01 84.4 Annual 2026 0.12 0.99 1.15 < 0.005 0.03 0.01 0.05 0.03 < 0.005 0.04 188 188 0.01 < 0.005 0.01 189 2027 0.04 0.07 0.09 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 13.9 13.9 < 0.005 < 0.005 < 0.005 14.0 2.3. Construction Emissions by Year, Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Exhibit C 141
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Hamilton Lane Escondido Detailed Report, 3/6/2025 12 / 75 Year ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily - Summer (Max) 2026 1.46 12.9 14.5 0.02 0.58 2.85 3.43 0.53 1.36 1.89 2,548 2,548 0.10 0.02 0.33 2,558 Daily - Winter (Max) 2026 1.44 13.0 15.1 0.02 0.51 2.51 3.01 0.47 1.19 1.65 2,604 2,604 0.11 0.02 0.01 2,614 2027 6.22 8.28 9.98 0.02 0.26 0.11 0.28 0.24 0.02 0.25 1,829 1,829 0.07 0.02 0.01 1,836 Average Daily 2026 0.64 5.40 6.29 0.01 0.19 0.06 0.25 0.17 0.03 0.20 1,138 1,138 0.05 0.01 0.03 1,143 2027 0.21 0.37 0.49 < 0.005 0.01 < 0.005 0.02 0.01 < 0.005 0.01 84.0 84.0 < 0.005 < 0.005 0.01 84.4 Annual 2026 0.12 0.99 1.15 < 0.005 0.03 0.01 0.05 0.03 < 0.005 0.04 188 188 0.01 < 0.005 0.01 189 2027 0.04 0.07 0.09 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 13.9 13.9 < 0.005 < 0.005 < 0.005 14.0 2.4. Operations Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Unmit. 0.45 0.18 1.79 < 0.005 0.01 0.32 0.32 0.01 0.08 0.09 2.13 476 479 0.24 0.02 1.31 490 Mit. 0.45 0.18 1.79 < 0.005 0.01 0.32 0.32 0.01 0.08 0.09 2.06 474 476 0.23 0.01 1.31 488 %Reduced 3% < 0.5% < 0.5% 3% 1% Daily, Winter (Max) Unmit. 0.42 0.19 1.41 < 0.005 0.01 0.32 0.32 0.01 0.08 0.09 2.13 459 461 0.24 0.02 0.10 472 Exhibit C 142
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Hamilton Lane Escondido Detailed Report, 3/6/2025 13 / 75 Mit. 0.42 0.19 1.41 < 0.005 0.01 0.32 0.32 0.01 0.08 0.09 2.06 457 459 0.23 0.02 0.10 470 %Reduced 3% < 0.5% < 0.5% 3% 1% Average Daily (Max) Unmit. 0.43 0.19 1.52 < 0.005 0.01 0.30 0.31 0.01 0.08 0.08 2.13 454 456 0.24 0.02 0.59 467 Mit. 0.43 0.19 1.52 < 0.005 0.01 0.30 0.31 0.01 0.08 0.08 2.06 452 454 0.23 0.02 0.59 465 %Reduced 3% < 0.5% 1% 3% 1% Annual (Max) Unmit. 0.08 0.03 0.28 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.02 0.35 75.2 75.5 0.04 < 0.005 0.10 77.4 Mit. 0.08 0.03 0.28 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.02 0.34 74.8 75.2 0.04 < 0.005 0.10 77.0 %Reduced 3% < 0.5% 1% 3% 1% 1% 2.5. Operations Emissions by Sector, Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Mobile 0.20 0.14 1.49 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 369 369 0.02 0.01 1.24 375 Area 0.25 < 0.005 0.28 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.76 0.76 < 0.005 < 0.005 0.76 Energy < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 95.2 95.2 0.01 < 0.005 95.5 Water 0.34 11.1 11.4 0.04 < 0.005 12.6 Waste 1.79 0.00 1.79 0.18 0.00 6.26 Refrig. 0.07 0.07 Total 0.45 0.18 1.79 < 0.005 0.01 0.32 0.32 0.01 0.08 0.09 2.13 476 479 0.24 0.02 1.31 490 Exhibit C 143
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Hamilton Lane Escondido Detailed Report, 3/6/2025 14 / 75 Daily, Winter (Max) Mobile 0.19 0.16 1.40 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 353 353 0.02 0.01 0.03 358 Area 0.23 Energy < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 95.2 95.2 0.01 < 0.005 95.5 Water 0.34 11.1 11.4 0.04 < 0.005 12.6 Waste 1.79 0.00 1.79 0.18 0.00 6.26 Refrig. 0.07 0.07 Total 0.42 0.19 1.41 < 0.005 0.01 0.32 0.32 0.01 0.08 0.09 2.13 459 461 0.24 0.02 0.10 472 Average Daily Mobile 0.19 0.15 1.37 < 0.005 < 0.005 0.30 0.31 < 0.005 0.08 0.08 347 347 0.02 0.01 0.52 353 Area 0.24 < 0.005 0.14 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.37 0.37 < 0.005 < 0.005 0.38 Energy < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 95.2 95.2 0.01 < 0.005 95.5 Water 0.34 11.1 11.4 0.04 < 0.005 12.6 Waste 1.79 0.00 1.79 0.18 0.00 6.26 Refrig. 0.07 0.07 Total 0.43 0.19 1.52 < 0.005 0.01 0.30 0.31 0.01 0.08 0.08 2.13 454 456 0.24 0.02 0.59 467 Annual Mobile 0.03 0.03 0.25 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 57.5 57.5 < 0.005 < 0.005 0.09 58.4 Area 0.04 < 0.005 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.06 0.06 < 0.005 < 0.005 0.06 Energy < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 15.8 15.8 < 0.005 < 0.005 15.8 Water 0.06 1.84 1.89 0.01 < 0.005 2.08 Waste 0.30 0.00 0.30 0.03 0.00 1.04 Refrig. 0.01 0.01 Total 0.08 0.03 0.28 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.02 0.35 75.2 75.5 0.04 < 0.005 0.10 77.4 2.6. Operations Emissions by Sector, Mitigated Exhibit C 144
Attachment "3"
422
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 15 / 75 Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Mobile 0.20 0.14 1.49 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 369 369 0.02 0.01 1.24 375 Area 0.25 < 0.005 0.28 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.76 0.76 < 0.005 < 0.005 0.76 Energy < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 95.2 95.2 0.01 < 0.005 95.5 Water 0.27 8.87 9.14 0.03 < 0.005 10.1 Waste 1.79 0.00 1.79 0.18 0.00 6.26 Refrig. 0.07 0.07 Total 0.45 0.18 1.79 < 0.005 0.01 0.32 0.32 0.01 0.08 0.09 2.06 474 476 0.23 0.01 1.31 488 Daily, Winter (Max) Mobile 0.19 0.16 1.40 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 353 353 0.02 0.01 0.03 358 Area 0.23 Energy < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 95.2 95.2 0.01 < 0.005 95.5 Water 0.27 8.87 9.14 0.03 < 0.005 10.1 Waste 1.79 0.00 1.79 0.18 0.00 6.26 Refrig. 0.07 0.07 Total 0.42 0.19 1.41 < 0.005 0.01 0.32 0.32 0.01 0.08 0.09 2.06 457 459 0.23 0.02 0.10 470 Average Daily Mobile 0.19 0.15 1.37 < 0.005 < 0.005 0.30 0.31 < 0.005 0.08 0.08 347 347 0.02 0.01 0.52 353 Area 0.24 < 0.005 0.14 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.37 0.37 < 0.005 < 0.005 0.38 Energy < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 95.2 95.2 0.01 < 0.005 95.5 Water 0.27 8.87 9.14 0.03 < 0.005 10.1 Waste 1.79 0.00 1.79 0.18 0.00 6.26 Refrig. 0.07 0.07 Exhibit C 145
Attachment "3"
423
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 16 / 75 Total 0.43 0.19 1.52 < 0.005 0.01 0.30 0.31 0.01 0.08 0.08 2.06 452 454 0.23 0.02 0.59 465 Annual Mobile 0.03 0.03 0.25 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 57.5 57.5 < 0.005 < 0.005 0.09 58.4 Area 0.04 < 0.005 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.06 0.06 < 0.005 < 0.005 0.06 Energy < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 15.8 15.8 < 0.005 < 0.005 15.8 Water 0.04 1.47 1.51 < 0.005 < 0.005 1.67 Waste 0.30 0.00 0.30 0.03 0.00 1.04 Refrig. 0.01 0.01 Total 0.08 0.03 0.28 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.02 0.34 74.8 75.2 0.04 < 0.005 0.10 77.0 3. Construction Emissions Details 3.1. Demolition (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Daily, Winter (Max) Off-Road Equipment1.39 12.9 14.6 0.02 0.51 0.51 0.47 0.47 2,494 2,494 0.10 0.02 2,503 Demoliti on 0.00 0.00 0.00 0.00 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Exhibit C 146
Attachment "3"
424
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 17 / 75 137 < 0.005 0.01 137 137 0.03 0.03 0.03 0.03 < 0.005 0.80 0.71 0.08 Off-Road Equipment Demoliti on 0.00 0.00 0.00 0.00 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Off-Road Equipment0.01 0.13 0.15 < 0.005 0.01 0.01 < 0.005 < 0.005 22.6 22.6 < 0.005 < 0.005 22.7 Demoliti on 0.00 0.00 0.00 0.00 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite Daily, Summer (Max) Daily, Winter (Max) Worker 0.04 0.04 0.48 0.00 0.00 0.11 0.11 0.00 0.02 0.02 110 110 0.01 < 0.005 0.01 111 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Worker < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 6.07 6.07 < 0.005 < 0.005 0.01 6.16 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.00 1.00 < 0.005 < 0.005 < 0.005 1.02 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Exhibit C 147
Attachment "3"
425
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 18 / 75 3.2. Demolition (2026) - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Daily, Winter (Max) Off-Road Equipment1.39 12.9 14.6 0.02 0.51 0.51 0.47 0.47 2,494 2,494 0.10 0.02 2,503 Demoliti on 0.00 0.00 0.00 0.00 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Off-Road Equipment0.08 0.71 0.80 < 0.005 0.03 0.03 0.03 0.03 137 137 0.01 < 0.005 137 Demoliti on 0.00 0.00 0.00 0.00 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Off-Road Equipment0.01 0.13 0.15 < 0.005 0.01 0.01 < 0.005 < 0.005 22.6 22.6 < 0.005 < 0.005 22.7 Demoliti on 0.00 0.00 0.00 0.00 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite Exhibit C 148
Attachment "3"
426
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 19 / 75 Daily, Summer (Max) Daily, Winter (Max) Worker 0.04 0.04 0.48 0.00 0.00 0.11 0.11 0.00 0.02 0.02 110 110 0.01 < 0.005 0.01 111 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Worker < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 6.07 6.07 < 0.005 < 0.005 0.01 6.16 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.00 1.00 < 0.005 < 0.005 < 0.005 1.02 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.3. Site Preparation (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Off-Road Equipment1.24 11.0 11.7 0.02 0.51 0.51 0.47 0.47 2,065 2,065 0.08 0.02 2,072 Dust From Material Movement 2.44 2.44 1.17 1.17 Exhibit C 149
Attachment "3"
427
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 20 / 75 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) Off-Road Equipment1.24 11.0 11.7 0.02 0.51 0.51 0.47 0.47 2,065 2,065 0.08 0.02 2,072 Dust From Material Movement 2.44 2.44 1.17 1.17 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Off-Road Equipment0.01 0.06 0.06 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 11.3 11.3 < 0.005 < 0.005 11.4 Dust From Material Movement 0.01 0.01 0.01 0.01 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Off-Road Equipment< 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.87 1.87 < 0.005 < 0.005 1.88 Dust From Material Movement < 0.005 < 0.005 < 0.005 < 0.005 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite Daily, Summer (Max) Exhibit C 150
Attachment "3"
428
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 21 / 75 Worker 0.03 0.02 0.32 0.00 0.00 0.06 0.06 0.00 0.01 0.01 69.7 69.7 < 0.005 < 0.005 0.24 70.8 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) Worker 0.03 0.02 0.29 0.00 0.00 0.06 0.06 0.00 0.01 0.01 65.8 65.8 < 0.005 < 0.005 0.01 66.7 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.36 0.36 < 0.005 < 0.005 < 0.005 0.37 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.06 0.06 < 0.005 < 0.005 < 0.005 0.06 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.4. Site Preparation (2026) - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Off-Road Equipment1.24 11.0 11.7 0.02 0.51 0.51 0.47 0.47 2,065 2,065 0.08 0.02 2,072 Exhibit C 151
Attachment "3"
429
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 22 / 75 1.17 1.17 2.44 2.44 Dust From Material Movement Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) Off-Road Equipment1.24 11.0 11.7 0.02 0.51 0.51 0.47 0.47 2,065 2,065 0.08 0.02 2,072 Dust From Material Movement 2.44 2.44 1.17 1.17 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Off-Road Equipment0.01 0.06 0.06 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 11.3 11.3 < 0.005 < 0.005 11.4 Dust From Material Movement 0.01 0.01 0.01 0.01 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Off-Road Equipment< 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.87 1.87 < 0.005 < 0.005 1.88 Dust From Material Movement < 0.005 < 0.005 < 0.005 < 0.005 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite Exhibit C 152
Attachment "3"
430
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 23 / 75 Daily, Summer (Max) Worker 0.03 0.02 0.32 0.00 0.00 0.06 0.06 0.00 0.01 0.01 69.7 69.7 < 0.005 < 0.005 0.24 70.8 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) Worker 0.03 0.02 0.29 0.00 0.00 0.06 0.06 0.00 0.01 0.01 65.8 65.8 < 0.005 < 0.005 0.01 66.7 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.36 0.36 < 0.005 < 0.005 < 0.005 0.37 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.06 0.06 < 0.005 < 0.005 < 0.005 0.06 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.5. Grading (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Off-Road Equipment1.42 12.9 14.0 0.02 0.58 0.58 0.53 0.53 2,455 2,455 0.10 0.02 2,463 Exhibit C 153
Attachment "3"
431
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 24 / 75 Dust From Material Movement 2.76 2.76 1.34 1.34 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) Average Daily Off-Road Equipment0.02 0.14 0.15 < 0.005 0.01 0.01 0.01 0.01 26.9 26.9 < 0.005 < 0.005 27.0 Dust From Material Movement 0.03 0.03 0.01 0.01 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Off-Road Equipment< 0.005 0.03 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 4.45 4.45 < 0.005 < 0.005 4.47 Dust From Material Movement 0.01 0.01 < 0.005 < 0.005 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite Daily, Summer (Max) Worker 0.04 0.03 0.43 0.00 0.00 0.08 0.08 0.00 0.02 0.02 93.0 93.0 < 0.005 < 0.005 0.33 94.4 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Exhibit C 154
Attachment "3"
432
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 25 / 75 Daily, Winter (Max) Average Daily Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.97 0.97 < 0.005 < 0.005 < 0.005 0.98 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.16 0.16 < 0.005 < 0.005 < 0.005 0.16 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.6. Grading (2026) - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Off-Road Equipment1.42 12.9 14.0 0.02 0.58 0.58 0.53 0.53 2,455 2,455 0.10 0.02 2,463 Dust From Material Movement 2.76 2.76 1.34 1.34 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) Average Daily Exhibit C 155
Attachment "3"
433
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 26 / 75 Off-Road Equipment0.02 0.14 0.15 < 0.005 0.01 0.01 0.01 0.01 26.9 26.9 < 0.005 < 0.005 27.0 Dust From Material Movement 0.03 0.03 0.01 0.01 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Off-Road Equipment< 0.005 0.03 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 4.45 4.45 < 0.005 < 0.005 4.47 Dust From Material Movement 0.01 0.01 < 0.005 < 0.005 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite Daily, Summer (Max) Worker 0.04 0.03 0.43 0.00 0.00 0.08 0.08 0.00 0.02 0.02 93.0 93.0 < 0.005 < 0.005 0.33 94.4 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) Average Daily Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.97 0.97 < 0.005 < 0.005 < 0.005 0.98 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.16 0.16 < 0.005 < 0.005 < 0.005 0.16 Exhibit C 156
Attachment "3"
434
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 27 / 75 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.7. Building Construction (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Off-Road Equipment1.01 8.57 9.96 0.02 0.29 0.29 0.27 0.27 1,801 1,801 0.07 0.01 1,807 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) Off-Road Equipment1.01 8.57 9.96 0.02 0.29 0.29 0.27 0.27 1,801 1,801 0.07 0.01 1,807 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Off-Road Equipment0.53 4.48 5.20 0.01 0.15 0.15 0.14 0.14 941 941 0.04 0.01 944 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Off-Road Equipment0.10 0.82 0.95 < 0.005 0.03 0.03 0.03 0.03 156 156 0.01 < 0.005 156 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite Exhibit C 157
Attachment "3"
435
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 28 / 75 Daily, Summer (Max) Worker 0.01 < 0.005 0.08 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 16.7 16.7 < 0.005 < 0.005 0.06 17.0 Vendor < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 13.1 13.1 < 0.005 < 0.005 0.03 13.7 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) Worker 0.01 0.01 0.07 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 15.8 15.8 < 0.005 < 0.005 < 0.005 16.0 Vendor < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 13.1 13.1 < 0.005 < 0.005 < 0.005 13.7 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Worker < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 8.33 8.33 < 0.005 < 0.005 0.01 8.45 Vendor < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 6.86 6.86 < 0.005 < 0.005 0.01 7.17 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.38 1.38 < 0.005 < 0.005 < 0.005 1.40 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.14 1.14 < 0.005 < 0.005 < 0.005 1.19 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.8. Building Construction (2026) - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Off-Road Equipment1.01 8.57 9.96 0.02 0.29 0.29 0.27 0.27 1,801 1,801 0.07 0.01 1,807 Exhibit C 158
Attachment "3"
436
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 29 / 75 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) Off-Road Equipment1.01 8.57 9.96 0.02 0.29 0.29 0.27 0.27 1,801 1,801 0.07 0.01 1,807 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Off-Road Equipment0.53 4.48 5.20 0.01 0.15 0.15 0.14 0.14 941 941 0.04 0.01 944 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Off-Road Equipment0.10 0.82 0.95 < 0.005 0.03 0.03 0.03 0.03 156 156 0.01 < 0.005 156 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite Daily, Summer (Max) Worker 0.01 < 0.005 0.08 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 16.7 16.7 < 0.005 < 0.005 0.06 17.0 Vendor < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 13.1 13.1 < 0.005 < 0.005 0.03 13.7 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) Worker 0.01 0.01 0.07 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 15.8 15.8 < 0.005 < 0.005 < 0.005 16.0 Vendor < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 13.1 13.1 < 0.005 < 0.005 < 0.005 13.7 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Exhibit C 159
Attachment "3"
437
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 30 / 75 Average Daily Worker < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 8.33 8.33 < 0.005 < 0.005 0.01 8.45 Vendor < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 6.86 6.86 < 0.005 < 0.005 0.01 7.17 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.38 1.38 < 0.005 < 0.005 < 0.005 1.40 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.14 1.14 < 0.005 < 0.005 < 0.005 1.19 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.9. Building Construction (2027) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Daily, Winter (Max) Off-Road Equipment0.97 8.25 9.91 0.02 0.26 0.26 0.24 0.24 1,801 1,801 0.07 0.01 1,807 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Off-Road Equipment0.03 0.23 0.27 < 0.005 0.01 0.01 0.01 0.01 49.3 49.3 < 0.005 < 0.005 49.5 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Exhibit C 160
Attachment "3"
438
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 31 / 75 8.20 < 0.005 < 0.005 8.17 8.17 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.05 0.04 < 0.005 Off-Road Equipment Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite Daily, Summer (Max) Daily, Winter (Max) Worker 0.01 0.01 0.06 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 15.5 15.5 < 0.005 < 0.005 < 0.005 15.7 Vendor < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 12.9 12.9 < 0.005 < 0.005 < 0.005 13.4 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.43 0.43 < 0.005 < 0.005 < 0.005 0.44 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.35 0.35 < 0.005 < 0.005 < 0.005 0.37 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.07 0.07 < 0.005 < 0.005 < 0.005 0.07 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.06 0.06 < 0.005 < 0.005 < 0.005 0.06 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.10. Building Construction (2027) - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Exhibit C 161
Attachment "3"
439
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 32 / 75 Daily, Winter (Max) Off-Road Equipment0.97 8.25 9.91 0.02 0.26 0.26 0.24 0.24 1,801 1,801 0.07 0.01 1,807 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Off-Road Equipment0.03 0.23 0.27 < 0.005 0.01 0.01 0.01 0.01 49.3 49.3 < 0.005 < 0.005 49.5 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Off-Road Equipment< 0.005 0.04 0.05 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 8.17 8.17 < 0.005 < 0.005 8.20 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite Daily, Summer (Max) Daily, Winter (Max) Worker 0.01 0.01 0.06 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 15.5 15.5 < 0.005 < 0.005 < 0.005 15.7 Vendor < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 12.9 12.9 < 0.005 < 0.005 < 0.005 13.4 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.43 0.43 < 0.005 < 0.005 < 0.005 0.44 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.35 0.35 < 0.005 < 0.005 < 0.005 0.37 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Exhibit C 162
Attachment "3"
440
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 33 / 75 Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.07 0.07 < 0.005 < 0.005 < 0.005 0.07 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.06 0.06 < 0.005 < 0.005 < 0.005 0.06 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.11. Paving (2027) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Daily, Winter (Max) Off-Road Equipment0.46 4.30 6.49 0.01 0.17 0.17 0.16 0.16 992 992 0.04 0.01 995 Paving 0.00 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Off-Road Equipment0.01 0.12 0.18 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 27.2 27.2 < 0.005 < 0.005 27.3 Paving 0.00 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Off-Road Equipment< 0.005 0.02 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 4.50 4.50 < 0.005 < 0.005 4.51 Paving 0.00 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Exhibit C 163
Attachment "3"
441
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 34 / 75 Offsite Daily, Summer (Max) Daily, Winter (Max) Worker 0.04 0.04 0.45 0.00 0.00 0.11 0.11 0.00 0.02 0.02 108 108 0.01 < 0.005 0.01 109 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.98 2.98 < 0.005 < 0.005 < 0.005 3.02 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.49 0.49 < 0.005 < 0.005 < 0.005 0.50 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.12. Paving (2027) - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Daily, Winter (Max) Off-Road Equipment0.46 4.30 6.49 0.01 0.17 0.17 0.16 0.16 992 992 0.04 0.01 995 Exhibit C 164
Attachment "3"
442
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 35 / 75 Paving 0.00 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Off-Road Equipment0.01 0.12 0.18 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 27.2 27.2 < 0.005 < 0.005 27.3 Paving 0.00 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Off-Road Equipment< 0.005 0.02 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 4.50 4.50 < 0.005 < 0.005 4.51 Paving 0.00 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite Daily, Summer (Max) Daily, Winter (Max) Worker 0.04 0.04 0.45 0.00 0.00 0.11 0.11 0.00 0.02 0.02 108 108 0.01 < 0.005 0.01 109 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.98 2.98 < 0.005 < 0.005 < 0.005 3.02 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Exhibit C 165
Attachment "3"
443
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 36 / 75 Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.49 0.49 < 0.005 < 0.005 < 0.005 0.50 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.13. Architectural Coating (2027) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Daily, Winter (Max) Off-Road Equipment0.11 0.83 1.13 < 0.005 0.02 0.02 0.02 0.02 134 134 0.01 < 0.005 134 Architect ural Coatings 6.10 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Off-Road Equipment< 0.005 0.02 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 3.66 3.66 < 0.005 < 0.005 3.67 Architect ural Coatings 0.17 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Off-Road Equipment< 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.61 0.61 < 0.005 < 0.005 0.61 Exhibit C 166
Attachment "3"
444
Item8.

Hamilton Lane Escondido Detailed Report, 3/6/2025 37 / 75 Architect Coatings 0.03 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite Daily, Summer (Max) Daily, Winter (Max) Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 3.11 3.11 < 0.005 < 0.005 < 0.005 3.15 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.09 0.09 < 0.005 < 0.005 < 0.005 0.09 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 0.01 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.14. Architectural Coating (2027) - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite Daily, Summer (Max) Exhibit C 167
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Hamilton Lane Escondido Detailed Report, 3/6/2025 38 / 75 Daily, Winter (Max) Off-Road Equipment0.11 0.83 1.13 < 0.005 0.02 0.02 0.02 0.02 134 134 0.01 < 0.005 134 Architect ural Coatings 6.10 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Off-Road Equipment< 0.005 0.02 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 3.66 3.66 < 0.005 < 0.005 3.67 Architect ural Coatings 0.17 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Off-Road Equipment< 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.61 0.61 < 0.005 < 0.005 0.61 Architect ural Coatings 0.03 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite Daily, Summer (Max) Daily, Winter (Max) Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 3.11 3.11 < 0.005 < 0.005 < 0.005 3.15 Exhibit C 168
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Hamilton Lane Escondido Detailed Report, 3/6/2025 39 / 75 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.09 0.09 < 0.005 < 0.005 < 0.005 0.09 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 0.01 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 4. Operations Emissions Details 4.1. Mobile Emissions by Land Use 4.1.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Single Family Housing 0.20 0.14 1.49 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 369 369 0.02 0.01 1.24 375 Total 0.20 0.14 1.49 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 369 369 0.02 0.01 1.24 375 Daily, Winter (Max) Exhibit C 169
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Hamilton Lane Escondido Detailed Report, 3/6/2025 40 / 75 358 0.03 0.01 0.02 353 353 0.08 0.08 < 0.005 0.32 0.32 < 0.005 < 0.005 1.40 0.16 0.19 Single Family Housing Total 0.19 0.16 1.40 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 353 353 0.02 0.01 0.03 358 Annual Single Family Housing 0.03 0.03 0.25 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 57.5 57.5 < 0.005 < 0.005 0.09 58.4 Total 0.03 0.03 0.25 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 57.5 57.5 < 0.005 < 0.005 0.09 58.4 4.1.2. Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Single Family Housing 0.20 0.14 1.49 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 369 369 0.02 0.01 1.24 375 Total 0.20 0.14 1.49 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 369 369 0.02 0.01 1.24 375 Daily, Winter (Max) Single Family Housing 0.19 0.16 1.40 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 353 353 0.02 0.01 0.03 358 Total 0.19 0.16 1.40 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 353 353 0.02 0.01 0.03 358 Annual Single Family Housing 0.03 0.03 0.25 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 57.5 57.5 < 0.005 < 0.005 0.09 58.4 Total 0.03 0.03 0.25 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 57.5 57.5 < 0.005 < 0.005 0.09 58.4 Exhibit C 170
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Hamilton Lane Escondido Detailed Report, 3/6/2025 41 / 75 4.2. Energy 4.2.1. Electricity Emissions By Land Use - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Single Family Housing 49.5 49.5 < 0.005 < 0.005 49.7 Total 49.5 49.5 < 0.005 < 0.005 49.7 Daily, Winter (Max) Single Family Housing 49.5 49.5 < 0.005 < 0.005 49.7 Total 49.5 49.5 < 0.005 < 0.005 49.7 Annual Single Family Housing 8.20 8.20 < 0.005 < 0.005 8.23 Total 8.20 8.20 < 0.005 < 0.005 8.23 4.2.2. Electricity Emissions By Land Use - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Exhibit C 171
Attachment "3"
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Hamilton Lane Escondido Detailed Report, 3/6/2025 42 / 75 Single Family Housing 49.5 49.5 < 0.005 < 0.005 49.7 Total 49.5 49.5 < 0.005 < 0.005 49.7 Daily, Winter (Max) Single Family Housing 49.5 49.5 < 0.005 < 0.005 49.7 Total 49.5 49.5 < 0.005 < 0.005 49.7 Annual Single Family Housing 8.20 8.20 < 0.005 < 0.005 8.23 Total 8.20 8.20 < 0.005 < 0.005 8.23 4.2.3. Natural Gas Emissions By Land Use - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Single Family Housing < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 45.7 45.7 < 0.005 < 0.005 45.8 Total < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 45.7 45.7 < 0.005 < 0.005 45.8 Daily, Winter (Max) Single Family Housing < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 45.7 45.7 < 0.005 < 0.005 45.8 Exhibit C 172
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Hamilton Lane Escondido Detailed Report, 3/6/2025 43 / 75 Total < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 45.7 45.7 < 0.005 < 0.005 45.8 Annual Single Family Housing < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 7.57 7.57 < 0.005 < 0.005 7.59 Total < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 7.57 7.57 < 0.005 < 0.005 7.59 4.2.4. Natural Gas Emissions By Land Use - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Single Family Housing < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 45.7 45.7 < 0.005 < 0.005 45.8 Total < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 45.7 45.7 < 0.005 < 0.005 45.8 Daily, Winter (Max) Single Family Housing < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 45.7 45.7 < 0.005 < 0.005 45.8 Total < 0.005 0.04 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 45.7 45.7 < 0.005 < 0.005 45.8 Annual Single Family Housing < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 7.57 7.57 < 0.005 < 0.005 7.59 Total < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 7.57 7.57 < 0.005 < 0.005 7.59 4.3. Area Emissions by Source Exhibit C 173
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Hamilton Lane Escondido Detailed Report, 3/6/2025 44 / 75 4.3.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Consum er Products 0.21 Architect ural Coatings 0.02 Landsca peEquipme nt 0.03 < 0.005 0.28 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.76 0.76 < 0.005 < 0.005 0.76 Total 0.25 < 0.005 0.28 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.76 0.76 < 0.005 < 0.005 0.76 Daily, Winter (Max) Consum er Products 0.21 Architect ural Coatings 0.02 Total 0.23 Annual Consum er Products 0.04 Architect ural Coatings < 0.005 Exhibit C 174
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Hamilton Lane Escondido Detailed Report, 3/6/2025 45 / 75 0.06 < 0.005 < 0.005 0.06 0.06 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.03 < 0.005 < 0.005 Landsca peTotal 0.04 < 0.005 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.06 0.06 < 0.005 < 0.005 0.06 4.3.2. Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Consum er Products 0.21 Architect ural Coatings 0.02 Landsca peEquipme nt 0.03 < 0.005 0.28 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.76 0.76 < 0.005 < 0.005 0.76 Total 0.25 < 0.005 0.28 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.76 0.76 < 0.005 < 0.005 0.76 Daily, Winter (Max) Consum er Products 0.21 Architect ural Coatings 0.02 Total 0.23 Annual Consum er Products 0.04 Exhibit C 175
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Hamilton Lane Escondido Detailed Report, 3/6/2025 46 / 75 Architect Coatings < 0.005 Landsca peEquipme nt < 0.005 < 0.005 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.06 0.06 < 0.005 < 0.005 0.06 Total 0.04 < 0.005 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.06 0.06 < 0.005 < 0.005 0.06 4.4. Water Emissions by Land Use 4.4.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Single Family Housing 0.34 11.1 11.4 0.04 < 0.005 12.6 Total 0.34 11.1 11.4 0.04 < 0.005 12.6 Daily, Winter (Max) Single Family Housing 0.34 11.1 11.4 0.04 < 0.005 12.6 Total 0.34 11.1 11.4 0.04 < 0.005 12.6 Annual Single Family Housing 0.06 1.84 1.89 0.01 < 0.005 2.08 Total 0.06 1.84 1.89 0.01 < 0.005 2.08 Exhibit C 176
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Hamilton Lane Escondido Detailed Report, 3/6/2025 47 / 75 4.4.2. Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Single Family Housing 0.27 8.87 9.14 0.03 < 0.005 10.1 Total 0.27 8.87 9.14 0.03 < 0.005 10.1 Daily, Winter (Max) Single Family Housing 0.27 8.87 9.14 0.03 < 0.005 10.1 Total 0.27 8.87 9.14 0.03 < 0.005 10.1 Annual Single Family Housing 0.04 1.47 1.51 < 0.005 < 0.005 1.67 Total 0.04 1.47 1.51 < 0.005 < 0.005 1.67 4.5. Waste Emissions by Land Use 4.5.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Exhibit C 177
Attachment "3"
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Hamilton Lane Escondido Detailed Report, 3/6/2025 48 / 75 Single Family Housing 1.79 0.00 1.79 0.18 0.00 6.26 Total 1.79 0.00 1.79 0.18 0.00 6.26 Daily, Winter (Max) Single Family Housing 1.79 0.00 1.79 0.18 0.00 6.26 Total 1.79 0.00 1.79 0.18 0.00 6.26 Annual Single Family Housing 0.30 0.00 0.30 0.03 0.00 1.04 Total 0.30 0.00 0.30 0.03 0.00 1.04 4.5.2. Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Single Family Housing 1.79 0.00 1.79 0.18 0.00 6.26 Total 1.79 0.00 1.79 0.18 0.00 6.26 Daily, Winter (Max) Single Family Housing 1.79 0.00 1.79 0.18 0.00 6.26 Exhibit C 178
Attachment "3"
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Hamilton Lane Escondido Detailed Report, 3/6/2025 49 / 75 Total 1.79 0.00 1.79 0.18 0.00 6.26 Annual Single Family Housing 0.30 0.00 0.30 0.03 0.00 1.04 Total 0.30 0.00 0.30 0.03 0.00 1.04 4.6. Refrigerant Emissions by Land Use 4.6.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Single Family Housing 0.07 0.07 Total 0.07 0.07 Daily, Winter (Max) Single Family Housing 0.07 0.07 Total 0.07 0.07 Annual Single Family Housing 0.01 0.01 Total 0.01 0.01 Exhibit C 179
Attachment "3"
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Hamilton Lane Escondido Detailed Report, 3/6/2025 50 / 75 4.6.2. Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Single Family Housing 0.07 0.07 Total 0.07 0.07 Daily, Winter (Max) Single Family Housing 0.07 0.07 Total 0.07 0.07 Annual Single Family Housing 0.01 0.01 Total 0.01 0.01 4.7. Offroad Emissions By Equipment Type 4.7.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme nt Type ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Exhibit C 180
Attachment "3"
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Hamilton Lane Escondido Detailed Report, 3/6/2025 51 / 75 Daily, Summer (Max) Total Daily, Winter (Max) Total Annual Total 4.7.2. Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme nt Type ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Total Daily, Winter (Max) Total Annual Total 4.8. Stationary Emissions By Equipment Type 4.8.1. Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Exhibit C 181
Attachment "3"
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Hamilton Lane Escondido Detailed Report, 3/6/2025 52 / 75 CO2e R N2O CH4 CO2T NBCO2 BCO2 PM2.5T PM2.5D PM2.5E PM10T PM10D PM10E SO2 CO NOx ROG Equipme nt Daily, Summer (Max) Total Daily, Winter (Max) Total Annual Total 4.8.2. Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme nt Type ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Total Daily, Winter (Max) Total Annual Total 4.9. User Defined Emissions By Equipment Type 4.9.1. Unmitigated Exhibit C 182
Attachment "3"
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Hamilton Lane Escondido Detailed Report, 3/6/2025 53 / 75 Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme nt Type ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Total Daily, Winter (Max) Total Annual Total 4.9.2. Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme nt Type ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Total Daily, Winter (Max) Total Annual Total 4.10. Soil Carbon Accumulation By Vegetation Type Exhibit C 183
Attachment "3"
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Hamilton Lane Escondido Detailed Report, 3/6/2025 54 / 75 4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetatio n ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Total Daily, Winter (Max) Total Annual Total 4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Total Daily, Winter (Max) Total Annual Total 4.10.3. Avoided and Sequestered Emissions by Species - UnmitigatedExhibit C 184
Attachment "3"
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Hamilton Lane Escondido Detailed Report, 3/6/2025 55 / 75 Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Avoided Subtotal Sequest ered Subtotal Remove d Subtotal Daily, Winter (Max) Avoided Subtotal Sequest ered Subtotal Remove d Subtotal Annual Avoided Subtotal Sequest ered Subtotal Exhibit C 185
Attachment "3"
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Hamilton Lane Escondido Detailed Report, 3/6/2025 56 / 75 Remove Subtotal 4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetatio n ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Total Daily, Winter (Max) Total Annual Total 4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Total Daily, Winter (Max) Total Annual Exhibit C 186
Attachment "3"
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Hamilton Lane Escondido Detailed Report, 3/6/2025 57 / 75 Total 4.10.6. Avoided and Sequestered Emissions by Species - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, Summer (Max) Avoided Subtotal Sequest ered Subtotal Remove d Subtotal Daily, Winter (Max) Avoided Subtotal Sequest ered Subtotal Remove d Subtotal Annual Avoided Exhibit C 187
Attachment "3"
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Hamilton Lane Escondido Detailed Report, 3/6/2025 58 / 75 Subtotal Sequest ered Subtotal Remove d Subtotal 5. Activity Data 5.1. Construction Schedule Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Demolition Demolition 3/2/2026 3/30/2026 5.00 20.0 Site Preparation Site Preparation 3/31/2026 4/2/2026 5.00 2.00 Grading Grading 4/3/2026 4/8/2026 5.00 4.00 Building Construction Building Construction 4/9/2026 1/14/2027 5.00 200 Paving Paving 1/15/2027 1/29/2027 5.00 10.0 Architectural Coating Architectural Coating 1/30/2027 2/13/2027 5.00 10.0 5.2. Off-Road Equipment 5.2.1. Unmitigated Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Concrete/Industrial Saws Diesel Average 1.00 8.00 33.0 0.73 Demolition Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Demolition Tractors/Loaders/Back hoes Diesel Average 3.00 8.00 84.0 0.37 Exhibit C 188
Attachment "3"
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Hamilton Lane Escondido Detailed Report, 3/6/2025 59 / 75 Site Preparation Graders Diesel Average 1.00 8.00 148 0.41 Site Preparation Rubber Tired Dozers Diesel Average 1.00 7.00 367 0.40 Site Preparation Tractors/Loaders/Back hoes Diesel Average 1.00 8.00 84.0 0.37 Grading Graders Diesel Average 1.00 8.00 148 0.41 Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Tractors/Loaders/Back hoes Diesel Average 2.00 7.00 84.0 0.37 Building Construction Cranes Diesel Average 1.00 6.00 367 0.29 Building Construction Forklifts Diesel Average 1.00 6.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Back hoes Diesel Average 1.00 6.00 84.0 0.37 Building Construction Welders Diesel Average 3.00 8.00 46.0 0.45 Paving Cement and Mortar Mixers Diesel Average 1.00 6.00 10.0 0.56 Paving Pavers Diesel Average 1.00 6.00 81.0 0.42 Paving Paving Equipment Diesel Average 1.00 8.00 89.0 0.36 Paving Rollers Diesel Average 1.00 7.00 36.0 0.38 Paving Tractors/Loaders/Back hoes Diesel Average 1.00 8.00 84.0 0.37 Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48 5.2.2. Mitigated Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Concrete/Industrial Saws Diesel Average 1.00 8.00 33.0 0.73 Demolition Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Demolition Tractors/Loaders/Back hoes Diesel Average 3.00 8.00 84.0 0.37 Site Preparation Graders Diesel Average 1.00 8.00 148 0.41 Exhibit C 189
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Hamilton Lane Escondido Detailed Report, 3/6/2025 60 / 75 Site Preparation Rubber Tired Dozers Diesel Average 1.00 7.00 367 0.40 Site Preparation Tractors/Loaders/Back hoes Diesel Average 1.00 8.00 84.0 0.37 Grading Graders Diesel Average 1.00 8.00 148 0.41 Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Tractors/Loaders/Back hoes Diesel Average 2.00 7.00 84.0 0.37 Building Construction Cranes Diesel Average 1.00 6.00 367 0.29 Building Construction Forklifts Diesel Average 1.00 6.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Back hoes Diesel Average 1.00 6.00 84.0 0.37 Building Construction Welders Diesel Average 3.00 8.00 46.0 0.45 Paving Cement and Mortar Mixers Diesel Average 1.00 6.00 10.0 0.56 Paving Pavers Diesel Average 1.00 6.00 81.0 0.42 Paving Paving Equipment Diesel Average 1.00 8.00 89.0 0.36 Paving Rollers Diesel Average 1.00 7.00 36.0 0.38 Paving Tractors/Loaders/Back hoes Diesel Average 1.00 8.00 84.0 0.37 Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48 5.3. Construction Vehicles 5.3.1. Unmitigated Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition Demolition Worker 12.5 12.0 LDA,LDT1,LDT2 Demolition Vendor 7.63 HHDT,MHDT Demolition Hauling 0.00 20.0 HHDT Exhibit C 190
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Hamilton Lane Escondido Detailed Report, 3/6/2025 61 / 75 Demolition Onsite truck HHDT Site Preparation Site Preparation Worker 7.50 12.0 LDA,LDT1,LDT2 Site Preparation Vendor 7.63 HHDT,MHDT Site Preparation Hauling 0.00 20.0 HHDT Site Preparation Onsite truck HHDT Grading Grading Worker 10.0 12.0 LDA,LDT1,LDT2 Grading Vendor 7.63 HHDT,MHDT Grading Hauling 0.00 20.0 HHDT Grading Onsite truck HHDT Building Construction Building Construction Worker 1.80 12.0 LDA,LDT1,LDT2 Building Construction Vendor 0.53 7.63 HHDT,MHDT Building Construction Hauling 0.00 20.0 HHDT Building Construction Onsite truck HHDT Paving Paving Worker 12.5 12.0 LDA,LDT1,LDT2 Paving Vendor 7.63 HHDT,MHDT Paving Hauling 0.00 20.0 HHDT Paving Onsite truck HHDT Architectural Coating Architectural Coating Worker 0.36 12.0 LDA,LDT1,LDT2 Architectural Coating Vendor 7.63 HHDT,MHDT Architectural Coating Hauling 0.00 20.0 HHDT Architectural Coating Onsite truck HHDT 5.3.2. Mitigated Exhibit C 191
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Hamilton Lane Escondido Detailed Report, 3/6/2025 62 / 75 Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition Demolition Worker 12.5 12.0 LDA,LDT1,LDT2 Demolition Vendor 7.63 HHDT,MHDT Demolition Hauling 0.00 20.0 HHDT Demolition Onsite truck HHDT Site Preparation Site Preparation Worker 7.50 12.0 LDA,LDT1,LDT2 Site Preparation Vendor 7.63 HHDT,MHDT Site Preparation Hauling 0.00 20.0 HHDT Site Preparation Onsite truck HHDT Grading Grading Worker 10.0 12.0 LDA,LDT1,LDT2 Grading Vendor 7.63 HHDT,MHDT Grading Hauling 0.00 20.0 HHDT Grading Onsite truck HHDT Building Construction Building Construction Worker 1.80 12.0 LDA,LDT1,LDT2 Building Construction Vendor 0.53 7.63 HHDT,MHDT Building Construction Hauling 0.00 20.0 HHDT Building Construction Onsite truck HHDT Paving Paving Worker 12.5 12.0 LDA,LDT1,LDT2 Paving Vendor 7.63 HHDT,MHDT Paving Hauling 0.00 20.0 HHDT Paving Onsite truck HHDT Architectural Coating Architectural Coating Worker 0.36 12.0 LDA,LDT1,LDT2 Exhibit C 192
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Hamilton Lane Escondido Detailed Report, 3/6/2025 63 / 75 Architectural Coating Vendor 7.63 HHDT,MHDT Architectural Coating Hauling 0.00 20.0 HHDT Architectural Coating Onsite truck HHDT 5.4. Vehicles 5.4.1. Construction Vehicle Control Strategies Non-applicable. No control strategies activated by user. 5.5. Architectural Coatings Phase Name Residential Interior Area Coated (sq ft) Residential Exterior Area Coated (sq ft) Non-Residential Interior Area Coated (sq ft) Non-Residential Exterior Area Coated (sq ft) Parking Area Coated (sq ft) Architectural Coating 19,744 6,581 0.00 0.00 5.6. Dust Mitigation 5.6.1. Construction Earthmoving Activities Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Demolition 0.00 0.00 0.00 Site Preparation 1.88 0.00 Grading 4.00 0.00 Paving 0.00 0.00 0.00 0.00 0.06 5.6.2. Construction Earthmoving Control Strategies Control Strategies Applied Frequency (per day) PM10 Reduction PM2.5 Reduction Water Exposed Area 2 61% 61% 5.7. Construction Paving Exhibit C 193
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Hamilton Lane Escondido Detailed Report, 3/6/2025 64 / 75 Land Use Area Paved (acres) % Asphalt Single Family Housing 0.06 0% 5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh) Year kWh per Year CO2 CH4 N2O 2026 0.00 589 0.03 < 0.005 2027 0.00 589 0.03 < 0.005 5.9. Operational Mobile Sources 5.9.1. Unmitigated Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Single Family Housing 47.2 47.7 42.8 17,022 443 447 401 159,641 5.9.2. Mitigated Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Single Family Housing 47.2 47.7 42.8 17,022 443 447 401 159,641 5.10. Operational Area Sources 5.10.1. Hearths 5.10.1.1. Unmitigated 5.10.1.2. Mitigated Exhibit C 194
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Hamilton Lane Escondido Detailed Report, 3/6/2025 65 / 75 5.10.2. Architectural Coatings Residential Interior Area Coated (sq ft) Residential Exterior Area Coated (sq ft) Non-Residential Interior Area Coated (sq ft) Non-Residential Exterior Area Coated (sq ft) Parking Area Coated (sq ft) 19743.75 6,581 0.00 0.00 5.10.3. Landscape Equipment Season Unit Value Snow Days day/yr 0.00 Summer Days day/yr 180 5.10.4. Landscape Equipment - Mitigated Season Unit Value Snow Days day/yr 0.00 Summer Days day/yr 180 5.11. Operational Energy Consumption 5.11.1. Unmitigated Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Single Family Housing 30,706 589 0.0330 0.0040 142,585 5.11.2. Mitigated Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Single Family Housing 30,706 589 0.0330 0.0040 142,585 Exhibit C 195
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Hamilton Lane Escondido Detailed Report, 3/6/2025 66 / 75 5.12. Operational Water and Wastewater Consumption 5.12.1. Unmitigated Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Single Family Housing 175,665 1,069,677 5.12.2. Mitigated Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Single Family Housing 140,532 855,741 5.13. Operational Waste Generation 5.13.1. Unmitigated Land Use Waste (ton/year) Cogeneration (kWh/year) Single Family Housing 3.32 5.13.2. Mitigated Land Use Waste (ton/year) Cogeneration (kWh/year) Single Family Housing 3.32 5.14. Operational Refrigeration and Air Conditioning Equipment 5.14.1. Unmitigated Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Single Family Housing Average room A/C & Other residential A/C and heat pumps R-410A 2,088 < 0.005 2.50 2.50 10.0 Exhibit C 196
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Hamilton Lane Escondido Detailed Report, 3/6/2025 67 / 75 1.00 0.00 0.60 0.12 1,430 R-134a Single Family Housing Household refrigerators and/or freezers 5.14.2. Mitigated Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Single Family Housing Average room A/C & Other residential A/C and heat pumps R-410A 2,088 < 0.005 2.50 2.50 10.0 Single Family Housing Household refrigerators and/or freezers R-134a 1,430 0.12 0.60 0.00 1.00 5.15. Operational Off-Road Equipment 5.15.1. Unmitigated Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor 5.15.2. Mitigated Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor 5.16. Stationary Sources 5.16.1. Emergency Generators and Fire Pumps Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor 5.16.2. Process Boilers Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr) Exhibit C 197
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Hamilton Lane Escondido Detailed Report, 3/6/2025 68 / 75 5.17. User Defined Equipment Type Fuel Type 5.18. Vegetation 5.18.1. Land Use Change 5.18.1.1. Unmitigated Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres 5.18.1.2. Mitigated Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres 5.18.1. Biomass Cover Type 5.18.1.1. Unmitigated Biomass Cover Type Initial Acres Final Acres 5.18.1.2. Mitigated Biomass Cover Type Initial Acres Final Acres 5.18.2. Sequestration 5.18.2.1. Unmitigated Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year) 5.18.2.2. Mitigated Exhibit C 198
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Hamilton Lane Escondido Detailed Report, 3/6/2025 69 / 75 Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year) 6. Climate Risk Detailed Report 6.1. Climate Risk Summary Cal-Adapt midcentury 20402059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100. Climate Hazard Result for Project Location Unit Temperature and Extreme Heat 15.7 annual days of extreme heat Extreme Precipitation 5.10 annual days with precipitation above 20 mm Sea Level Rise meters of inundation depth Wildfire 8.89 annual hectares burned Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 20402059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi. Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi. Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (20402059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi. 6.2. Initial Climate Risk Scores Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A Extreme Precipitation N/A N/A N/A N/A Sea Level Rise N/A N/A N/A N/A Wildfire N/A N/A N/A N/A Flooding N/A N/A N/A N/A Drought N/A N/A N/A N/A Exhibit C 199
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Hamilton Lane Escondido Detailed Report, 3/6/2025 70 / 75 Snowpack Reduction N/A N/A N/A N/A Air Quality Degradation N/A N/A N/A N/A The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure. The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt. The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures. 6.3. Adjusted Climate Risk Scores Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A Extreme Precipitation N/A N/A N/A N/A Sea Level Rise N/A N/A N/A N/A Wildfire N/A N/A N/A N/A Flooding N/A N/A N/A N/A Drought N/A N/A N/A N/A Snowpack Reduction N/A N/A N/A N/A Air Quality Degradation N/A N/A N/A N/A The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure. The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt. The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures. 6.4. Climate Risk Reduction Measures 7. Health and Equity Details 7.1. CalEnviroScreen 4.0 Scores The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. Exhibit C 200
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Hamilton Lane Escondido Detailed Report, 3/6/2025 71 / 75 Indicator Result for Project Census Tract Exposure Indicators AQ-Ozone 50.5 AQ-PM 15.4 AQ-DPM 58.2 Drinking Water 60.0 Lead Risk Housing 6.84 Pesticides 57.7 Toxic Releases 10.6 Traffic 80.1 Effect Indicators CleanUp Sites 78.7 Groundwater 60.4 Haz Waste Facilities/Generators 0.00 Impaired Water Bodies 93.4 Solid Waste 35.7 Sensitive Population Asthma 7.05 Cardio-vascular 45.0 Low Birth Weights 4.54 Socioeconomic Factor Indicators Education 15.2 Housing 21.6 Linguistic 22.9 Poverty 4.02 Unemployment 8.69 7.2. Healthy Places Index Scores Exhibit C 201
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Hamilton Lane Escondido Detailed Report, 3/6/2025 72 / 75 The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state. Indicator Result for Project Census Tract Economic Above Poverty 92.64724753 Employed 58.62953933 Median HI 90.27332221 Education Bachelor's or higher 78.6603362 High school enrollment 100 Preschool enrollment 67.35531888 Transportation Auto Access 98.98626973 Active commuting 12.51122803 Social 2-parent households 98.40882844 Voting 98.8836135 Neighborhood Alcohol availability 87.56576415 Park access 35.44206339 Retail density 26.84460413 Supermarket access 21.57064032 Tree canopy 71.57705633 Housing Homeownership 97.12562556 Housing habitability 99.51238291 Low-inc homeowner severe housing cost burden 84.98652637 Low-inc renter severe housing cost burden 99.08892596 Uncrowded housing 85.268831 Health Outcomes Exhibit C 202
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Hamilton Lane Escondido Detailed Report, 3/6/2025 73 / 75 Insured adults 95.534454 Arthritis 2.5 Asthma ER Admissions 91.6 High Blood Pressure 4.8 Cancer (excluding skin) 2.0 Asthma 80.2 Coronary Heart Disease 5.6 Chronic Obstructive Pulmonary Disease 29.1 Diagnosed Diabetes 36.9 Life Expectancy at Birth 82.2 Cognitively Disabled 87.2 Physically Disabled 85.5 Heart Attack ER Admissions 83.2 Mental Health Not Good 87.0 Chronic Kidney Disease 10.6 Obesity 74.1 Pedestrian Injuries 19.6 Physical Health Not Good 66.1 Stroke 26.0 Health Risk Behaviors Binge Drinking 71.2 Current Smoker 89.7 No Leisure Time for Physical Activity 77.2 Climate Change Exposures Wildfire Risk 10.8 SLR Inundation Area 0.0 Children 95.8 Elderly 9.2 Exhibit C 203
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Hamilton Lane Escondido Detailed Report, 3/6/2025 74 / 75 English Speaking 67.3 Foreign-born 29.8 Outdoor Workers 56.8 Climate Change Adaptive Capacity Impervious Surface Cover 87.0 Traffic Density 88.6 Traffic Access 50.8 Other Indices Hardship 9.9 Other Decision Support 2016 Voting 98.1 7.3. Overall Health & Equity Scores Metric Result for Project Census Tract CalEnviroScreen 4.0 Score for Project Location (a) 12.0 Healthy Places Index Score for Project Location (b) 91.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state. 7.4. Health & Equity Measures No Health & Equity Measures selected. 7.5. Evaluation Scorecard Health & Equity Evaluation Scorecard not completed. 7.6. Health & Equity Custom Measures No Health & Equity Custom Measures created. Exhibit C 204
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Hamilton Lane Escondido Detailed Report, 3/6/2025 75 / 75 8. User Changes to Default Data Screen Justification Operations: Hearths No fireplaces or wood stoves Exhibit C 205
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Appendix B - Biological Resources
Memorandum
Exhibit C
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Escondido City CouncilJune 10, 2026

Escondido City Council
June 10, 2026