Accordingly, the potential for liquefaction induced lateral spreading and seismic induced settlement is also considered to be very low. Furthermore, the project will implement all remedial grading and drainage recommendations contained within Chapters 7 and 9 of the geotechnical report (Appendix G of EIR). Therefore, the project would not result in seismic- related ground failure, including liquefaction. Impacts would be
less than significant.
Threshold #4: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides?
The project site consists of a northwest trending drainage with moderate to steep slopes along the flanks. Elevations range from 710 feet AMSL in the southeast portion of the site to 650 feet AMSL in the northwest portion. The project site is identified as having Low Susceptibility for soil slip, surficial
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landslides, or debris flow per Figure 6 -1 of the Safety Element of the City’s General Plan (City of San Marcos 2012).
According to the geotechnical investigation, the risk associated with landslide hazards at the site is low. In addition, the California Department of Conservation – California Geological Survey, Geologic Map of the Oceanside 30’x 60’ Quadrangle (Kennedy & Tan 2007) does not indicate previously mapped landslide deposits on or near the property ( See Figure 2 of Preliminary Geotechnical Report GEOCON 2020) . Therefore, the potential of seismically -induced landsliding or slope instabil ity is considered to be low at the project site. Therefore, the project would not directly or indirectly cause potentially substantial adverse effects, including the risk of loss, injury or death involving landslides.
Impacts would be less than significant.
Threshold #5: Result in substantial soil erosion or the loss of topsoil? Proposed site improvements require grading and soil import of approximately 46,400 cy of import material. The project would be under the State Water Resources Control Board (SWRCB) General Construction Permit, which prohibits sediment or pollutant release from the project site and requires preparation of a Stormwater Pollution Prevention Plan (SWPPP) and imple mentation of best management practices (BMPs) that would incorporate erosion and sediment control measures during and after grading operations to stabilize these areas. Furthermore, the project will implement all landscape maintenance and drainage recommen dations contained within Chapter 7 of the geotechnical report (Appendix G of EIR).
Therefore, the proposed project would incorporate BMPs and recommendations that would minimize erosion and loss of topsoil. The proposed project would not result in substant ial soil erosion of the loss of topsoil. Impacts would be less than significant.
Threshold #6: 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?
According to the geotechnical investigation prepared by GEOCON (2020), the surficial soil types consist of undocumented fill, topsoil, alluvium and colluvium overlain atop of Cretaceous-age granitic rock. In general, these soil types are unsuitable for support of settlement - sensitive structures and improvements and will require removal and compaction . Specifically, the undocumented fill consists of loose, moist, silty sand, with some minor trash debris and will require complete removal and compaction. It is estimated that the undocumen ted fill is confined to a relatively small area in the north-central portion of the project site . The topsoil is characterized as loose, damp to moist, silty fine- to medium- grained sand and will require removal and compaction . The upper portion of the alluvial/colluvial deposits are poorly consolidated and compressible, and will require removal and compaction during grading. Based on laboratory testing, the lower portion of these deposits are generally suitable in their present condition for support of str uctural fill and settlement -sensitive structures. Excavations into the granitic rock will require special handling and placement.
Site preparation and fill material replacement will be completed consistent with Chapter 7 of the geotechnical investigation (GEOCON 2020) . Specifically, grading will be accomplished under the observation and testing of the project geotechnical engineer and engineering geologist or their authorized representative in accordance with the recommendations and earthwork specifications of the geotechnical investigation and the current grading ordinance of the City of San Marcos.
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In summary, the proposed project would incorporate techniques and recommendations that would minimize the potential for unstable conditions that could result in on- or off -site, lateral spread, subsidence, liquefaction, or collapse. Impacts would be less than significant.
Threshold #7: Be located on expansive soil, as defined in Table 18 -1-B of the Uniform Building Code (1994), creating substantial risks to life or property? According to the geotechnical investigation prepared by GEOCON (2020), the soils encountered are considered to be both non -expansive and expansive (expansion index greater than 20 as defined by 2019 CBC Section 1803.5.3). The predominant material encountered was silty sand, with some clayey sands, and exhibit a low expansion potential . As such, these materials are susceptible to volume changes with variations in their moisture content, expanding with the introduction of water and shrinking as the soil dries. However, the expansion potential of these materials is not considered to pose a hazard for the proposed project. With adherence to the geotechnical report recommendations, which include removal and compaction during grading, impacts rel ated to expansive soils would be
less than significant.
Threshold #8 : Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
The proposed project site lies within the Peninsular Ranges Geomorphic Province of southern California. This province consists of a series of ranges separated by northwest trending valleys; subparallel to branches of the San Andreas Fault (CGS 2002) . The Peninsular Ranges geomorphic province is one of the largest geomorphic units in wester n North America, extends from the Transverse Ranges geomorphic province and the Los Angeles Basin, south to Baja California . It is bound on the west by the Pacific Ocean, on the south by the Gulf of California and on the east by the Colorado Desert Provinc e. Peninsular Ranges are essentially a series of northwest -southeast oriented fault blocks (CGS 2002) . Major fault zones and subordinate fault zones found in the Peninsular Ranges Province typically trend in a northwest-southeast direction.
According to th e Preliminary Geotechnical Evaluation prepared for the project (GEOCON 2020 ), the geologic conditions underlying the site consist of undocumented artificial soils (Qudf), and Quaternary-aged colluvial and alluvium deposits (Qcol and Qal)). Cretaceous -age g ranitic rock underlies the surficial deposits throughout the property. Colluvial deposits were encountered along the entire length of the northwest trending drainage and adjacent hillsides, and vary in thickness from approximately 3 to 11 feet thick. The Quaternary Period is divided into two epochs: the Pleistocene (2.588 million years ago to 11.7 thousand years ago) and the Holocene (11.7 thousand years ago to today).
According to the San Marcos General Plan EIR (page 3.12 -1), older Pleistocene-age alluvial deposits have the potential to yield “Ice -age” fossils. In composition, these deposits consist of “moderately well consolidated, poorly sorted, permeable, commonly slightly desiccated gravel, sand, silt, and clay- bearing alluvium.” These Pleistocene allu vial deposits are locally capped by Holocene alluvium and artificial fill, and at depth, are underlain by Cretaceous and older igneous rocks. Pleistocene old alluvial flood plain deposits are found in northern San Diego County and include recorded fossil collecting localities in Vista, Carlsbad, and Oceanside. These localities have yielded fossils of terrestrial plants, freshwater and terrestrial invertebrates such as clams and snails, and terrestrial mammals such as ground sloth, rodents, horse, tapir, camel, llama, deer, mastodon, and mammoth.
Given that no fossils have been recovered from the sediments mapped as old alluvial flood plain deposits in the City, it is suggested that these deposits have an unproven and/or undetermined paleontological sensitivity. Due to the fact that the Pleistocene old alluvial floodplain deposits have
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an unproven/undetermined sensitivity there is a potential that the site could contain paleontological resources that could be disturbed during grading activities for the project . This represents a potentially significant impact (Impact GEO-1) and mitigation is required. • Impact GEO-1: Project grading may result in disturbance of previously unknown paleontological resources.
3.6.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, r egional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to geology and soils, the cumulative analysis is bas ed upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts on related to geology and soils. All of the cumulative projects identified in Table 2 -3 are considered in this cumulative analysis.
Due to the l ocalized nature of geology and soils, cumulative projects would address potential impacts to geology and soils on a project -by-project basis, as potential geologic hazards and soil composition varies by site. Each cumulative project would be required to as sess individual and site - specific geologic conditions, which would inform construction and development of each site. All cumulative development would be subject to similar requirements to those imposed and implemented for the proposed project and would be required to adhere to applicable regulations, standards, and procedures.
Further, as discussed in Section 3.6.4, the project site has the potential to yield paleontological resources. Thus, impacts to paleontological resources from implementation of the pr oject would be potentially significant. Some of the projects on the cumulative list are located in areas that support alluvial soils. Certain types of alluvial soils have the potential to contain paleontological resources.
Similar to the project, the prese nce of these resources is typically unknown until earthwork activities commence for project construction. It is expected that cultural resources studies would be prepared for all cumulative projects to assess potential impacts. For the cumulative projects that are within sensitive areas for paleontological resources, the expectation is that mitigation measures would be included to require consultation with a paleontologist or a construction monitor to ensure that impacts to this resource to do not occur. As such, the proposed project would not result in significant cumulative impacts for geology and soils. Impacts would be less than significant.
3.6.6 Mitigation Measures
Due to the fact that the Pleistocene old alluvial floodplain deposits have an unproven/undetermined sensitivity there is a potential that the site could contain paleontological resources that could be disturbed during grading activities for the project. The following mitigation is required.
Unknown Paleontological Resources (Impact GEO-1)
MM-GEO-1 Prior to project grading the project applicant shall retain a qualified paleontologist to review the proposed project area to determine the potential for paleontological
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resources to be encountered. If there is a potential for pale ontological resources to occur, the paleontologist shall identify the area(s) where these resources are expected to be present, and a qualified paleontological monitor shall be retained to monitor the initial cut in any areas that have the potential to con tain paleontological resources.
3.6.7 Conclusion
Based upon the analysis presented in Sections 3.6.3 and 3.6.4, impacts associated with seismicity, liquefaction, landslides, erosion/loss of topsoil, compressible soils, and expansive soils, were determined to be less than significant. The project will adhere to all recommendations in the preliminary geotechnical investigation prepared for the project (GEOCON 2020). Due to the fact that Pleistocene old alluvial floodplain deposits have an unproven/undetermined sens itivity, there is a potential that the site could contain paleontological resources that could be disturbed during grading activities for the project. Incorporation of MM - GEO-1 would require a paleontologist to identify areas where paleontological resources may be present and to monitor the initial cut in any areas that may have the potential to contain paleontological resources.
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3.7 Greenhouse Gas
Introduction
This section analyzes the potential for the proposed project to have impacts related to greenhouse gas (GHG) emissions. This section analyzes short -term construction impacts and long -term operational impacts and determines whether the proposed project woul d conform to the City of San Marcos Climate Action Plan (CAP). This section is based upon the following report, which is included as Appendix H.1 of this document7:
• Greenhouse Gas Assessment, East Barham Residential Development Project , prepared by Ldn Consulting, November 16, 2021 (LDN 2021)
The project’s Climate Action Plan Consistency Review Checklist (CAP Checklist) is included as Appendix H.2. A discussion of the project’s consistency with the requirements of the CAP Checklist is provided later in th is section. The CAP is available on the City’s web site. 8 Table 3.7-1 summarizes the project- and cumulative-level GHG impacts, by threshold.
Table 3.7-1. Greenhouse Gas Emissions Summary of Impacts Threshold of Significance Project Direct
Impact
Project Cumulative
Impact
Impact After
Mitigation
#1 - Generate greenhouse gas
emissions, either directly or
indirectly, that may have a
significant impact on the
environment
Less than
Significant
Less than
Significant
Less than
Significant
#2 - Conflict with an applicable
plan, policy, or regulation
adopted for the purpose of
reducing the emissions of
greenhouse gases.
Less than
Significant
Less than
Significant
Less than
Significant
3.7.1 Existing Conditions
Global Climate Change
Climate change refers to any significant change in measures of climate, such as temperature, precipitation, or wind patterns, lasting for an extended period of time (decades or longer). The Earth's temperature depends on the balance between energy entering and leaving the planet’s system.
Many factors, both natural and human, can cause changes in Earth’s energy balance, including variations in the sun’s energy reaching Earth, changes in the reflectivity of Earth’s atmosphere and surface, and changes in the greenhouse effect, which affects the amount of heat retained by Earth’s atmosphere.
7 Full references for documents cited in this section are included in Chapter 7, References, of this EIR. 8 http://www.san-marcos.net/departments/development-services/planning/climate-action-plan
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The greenhouse effect is the trapping and build -up of heat in the atmosphere near the Earth’s surface. This natural process contributes to regulating the Earth’s temperatur e and creates a pleasant, livable environment on the Earth. Human activities that emit additional GHGs into the atmosphere increase the amount of infrared radiation that gets absorbed before escaping into space, thus enhancing the greenhouse effect and causing the Earth’s surface temperature to rise.
GHG is any gas that absorbs infrared radiation in the atmosphere; in other words, GHGs trap heat in the atmosphere and contribute to the greenhouse effect. GHGs include, but are not limited to, carbon dioxide ( CO2), methane (CH 4), nitrous oxide (N 2O), ozone (O 3), water vapor, hydrofluorocarbons (HFCs), hydrochlorofluorocarbons (HCFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF
6). Some GHGs, such as CO 2, CH4, and N 2O, occur naturally and are emitted to the atmosphere through natural processes and human activities. To simplify greenhouse gas calculations, both CH 4 and N2O are converted to an equivalent amount of carbon dioxide, or CO 2e.
CO2e is calculated by multiplying the calculated levels of CH 4 and N2O by a Global Warming Potential (GWP). GWPs for both CH 4 and N 2 are presented within the 2007 Intergovernmental Panel on Climate Change (IPCC) report as being 25 and 298, respectively (IPCC 2007).
A brief description of each GHG follows:
Carbon Dioxide . CO2 is a naturally occurring gas and a by -product of human activities. It is the principal anthropogenic GHG that affects the Earth’s radiative balance. Natural sources of CO 2 include, but are not limited to, respiration of bacteria, plants, animals, and f ungi; volcanic out - gassing; and decomposition of dead organic matter. Human activities that generate CO2 are from the combustion of fuels such as coal, oil, natural gas, and wood and changes in land use.
Methane. CH4 is produced through both natural and hu man activities. CH4 is a flammable gas and is the main component of natural gas. CH 4 is produced through anaerobic (without oxygen) decomposition of waste in landfills, flooded rice fields, animal digestion, decomposition of animal wastes, production and d istribution of natural gas and petroleum, coal production, and incomplete fossil fuel combustion.
Nitrous Oxide . N 2O is produced through natural and human activities, mainly through agricultural activities and natural biological processes, although fuel bu rning and other processes also create N2O. Sources of N 2O include soil cultivation practices (microbial processes in soil and water), especially the use of commercial and organic fertilizers, manure management, industrial processes (such as in nitric acid production, nylon production, and fossil -fuel-fired power plants), vehicle emissions, and using N
2O as a propellant (such as in rockets, racecars, and aerosol sprays).
3.7.2 Regulatory Setting
The following section provides a general description of the applicabl e regulatory requirements pertaining to GHGs, including federal, state, and local guidelines.
Federal
The United States Environmental Protection Agency (USEPA) is the federal agency responsible for implementing the federal Clean Air Act (CAA). The Supreme Court of the United States ruled on April 2, 2007 that CO 2 is an air pollutant as defined under the CAA, and that USEPA has the authority to regulate emissions of GHGs.
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Proposed Endangerment and Cause or Contribute Findings for GHG under the CAA On December 7, 2009, USEPA signed two distinct findings regarding GHGs under section 202(a) of the CAA:
• Endangerment Finding: The Administrator finds that the current and projected concentrations of the six key well -mixed GHGs—carbon dioxide (CO2), methane (CH4), nitrous oxide (N 2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)—in the atmosphere threaten the public health and welfare of current and future generations; and
• Cause or Contribute Finding: The Administr ator finds that the combined emissions of these well-mixed GHGs from new motor vehicles and new motor vehicle engines contribute to the GHG pollution which threatens public health and welfare. These findings do not themselves impose any requirements on ind ustry or other entities; however, this action is a prerequisite to finalizing USEPA’s proposed GHG emission standards for light -duty vehicles, which USEPA proposed in a joint proposal including the Department of Transportation's (DOT) proposed CAFE standards on September 15, 2009.
Energy Independence and Security Act . The Energy Independence and Security Act of 2007 (December 2007), among other key measures, would do the following, which would aid in the reduction of national GHG emissions:
1. Increase the sup ply of alternative fuel sources by setting a mandatory Renewable Fuel Standard requiring fuel producers to use at least 36 billion gallons of biofuel in 2022.
2. Set a target of 35 miles per gallon for the combined fleet of cars and light trucks by model year 2020 and direct National Highway Traffic Safety Administration (NHTSA) to establish a fuel economy program for medium - and heavy -duty trucks and create a separate fuel economy standard for work trucks.
3. Prescribe or revise standards affecting regional efficiency for heating and cooling products and procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances.
State
The statewide GHG emissions regulatory framework is summarized below by category: state climate change targets, building energy, mobile sources, renewable energy procurement, water, solid waste, and water.
State Climate Change Targets
Executive Order S-3-05. Executive Order (EO) S-3-05 (June 2005) established the following statewide goals: GHG emissions should be reduced to 2000 levels by 2010, GHG emissions should be reduced to 1990 levels by 2020, and GHG emissions should be reduced to 80% below 1990 levels by 2050.
Assembly Bill 32. In furtherance of the goals established in EO S -3-05, the legislature enacted AB 32 (Núñez and Pavley). The bill is referred to as the California Global Warming Solutions Act of 2006 (September 27, 2006). AB 32 provided initial di rection on creating a comprehensive multiyear
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program to limit California’s GHG emissions at 1990 levels by 2020 and initiate the transformations required to achieve the state’s long-range climate objectives.
California Air Resources Board’s Climate Change Scoping Plan. Under AB 32, the California Air Resources Board (CARB) is responsible for and is recognized as having the expertise to carry out and develop the programs and regulations necessary to achieve the GHG emissions reduction mandate of AB 32. The refore, in furtherance of AB 32, CARB adopted regulations requiring the reporting and verification of GHG emissions from specified sources, such as industrial facilities, fuel suppliers and electricity importers (see Health & Safety Code Section 35830; Cal . Code Regs., tit. 17, §§95100 et seq.). CARB is also required to adopt rules and regulations to achieve the maximum technologically feasible and cost-effective GHG emission reductions. AB 32 authorized CARB to adopt market -based compliance mechanisms to m eet the specified requirements. Finally, CARB is ultimately responsible for monitoring compliance and enforcing any rule, regulation, order, emission limitation, emission reduction measure, or market-based compliance mechanism adopted.
In 2007, CARB approved a limit on the statewide GHG emissions level for year 2020 consistent with the determined 1990 baseline (427 million metric tons (MMT) CO 2e). CARB’s adoption of this limit is in accordance with Health and Safety Code Section 38550.
Further, in 2008, CAR B adopted the Climate Change Scoping Plan: A Framework for Change (2008 Scoping Plan) in accordance with Health and Safety Code Section 38561. The 2008 Scoping Plan established an overall framework for the measures to be implemented to reduce California’s GHG emissions for various emission sources/sectors to 1990 levels by 2020. The 2008 Scoping Plan evaluated opportunities for sector-specific reductions, integrated all CARB and Climate Action Team9 early actions and additional GHG reduction features by both entities, identified additional measures to be pursued as regulations, and outlined the role of a cap-and-trade program.
In the 2008 Scoping Plan, CARB determined that achieving the 1990 emissions level in 2020 would require a reduction in GHG emissions of approximately 28.5 percent from the otherwise projected 2020 emissions level; i.e., those emissions that would occur in 2020, absent GHG-reducing laws and regulations (referred to as “Business -As-Usual” [BAU]). For purposes of calculating this percent reduction, CARB assumed that all new electricity generation would be supplied by natural gas plants, no further regulatory action would impact vehicle fuel efficiency, and building energy efficiency codes would be held at 2005 standards.
In the 2011 Final Supplement to the 2008 Scoping Plan’s Functional Equivalent Document, CARB revised its estimates of the projected 2020 emissions level in light of the economic recession and the availability of updated information about GHG reduction regulations. Based on the new economic data, CARB determined that achieving the 1990 emissions level by 2020 would require a reduction in GHG emissions of 21.7 percent (down from 28.5 percent) from the BAU conditions. When the 2020 emissions level projection was updated to account for newly implemented regulatory measures, including Pavley I (model years 2009 –2016) and the Renewables Portfolio Standard (12 percent to 20 percent), CARB determined that achieving the 1990 emissions level in 2020 would require a reduction in GHG emi ssions of 16 percent (down from 28.5 percent) from the BAU conditions.
9 The Climate Action Team is comprised of state agency secretaries and heads of state agencies, boards, and departments; these members work to coordinate statewide efforts to implement GHG emissions reduction programs and adaptation programs.
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In 2014, CARB approved the first update to the Scoping Plan. The First Update to the Climate Change Scoping Plan: Building on the Framework (First Update) defined the state’s GHG emissi on reduction priorities for the next 5 years and laid the groundwork to start the transition to the post - 2020 goals set forth in EO S- 3-05 and EO B-16-2012. The First Update found that California was on track to meet the 2020 emissions reduction mandate es tablished by AB 32, noted that California could reduce emissions further by 2030 to levels squarely in line with those needed to stay on track to reduce emissions to 80 percent below 1990 levels by 2050 if the state realizes the expected benefits of existing policy goals.
Executive Order B -30-15. EO B -30-15 (April 2015) identified an interim GHG reduction target in support of targets previously identified under EO S-3-05 and AB 32. EO B-30-15 set an interim target goal of reducing statewide GHG emissions to 40% below 1990 levels by 2030 to keep California on its trajectory toward meeting or exceeding the long -term goal of reducing statewide GHG emissions to 80% below 1990 levels by 2050, as set forth in EO S- 3-05. To facilitate achievement of this goal, EO B-30-15 calls for an update to CARB’s Scoping Plan to express the 2030 target in terms of MMT CO2e. The EO also calls for state agencies to continue to develop and implement GHG emission reduction programs in support of the reduction targets. Sector -specific agencies in transportation, energy, water, and forestry were required to prepare GHG reduction plans by September 2015, followed by a report on action taken in relation to these plans in June 2016.
Senate Bill 32 and Assembly Bill 197. SB 32 and AB 197 ( enacted in 2016) are companion bills that set a new statewide GHG reduction target; make changes to CARB’s membership and increase legislative oversight of CARB’s climate change -based activities; and expand dissemination of GHG and other air quality -related emissions data to enhance transparency and accountability. More specifically, SB 32 codified the 2030 emissions reduction goal of EO B -30-15 by requiring CARB to ensure that statewide GHG emissions are reduced to 40% below 1990 levels by 2030. AB 197 established the Joint Legislative Committee on Climate Change Policies, consisting of at least three members of the Senate and three members of the Assembly, in order to provide ongoing oversight over implementation of the state’s climate policies. AB 197 also added two memb ers of the Legislature to CARB as nonvoting members; requires CARB to make available and update (at least annually via its website) emissions data for GHGs, criteria air pollutants, and toxic air contaminants (TACs) from reporting facilities; and requires CARB to identify specific information for GHG emissions reduction measures when updating the scoping plan.
2017 Climate Change Scoping Plan (November 2017). In November 2017, CARB released California’s 2017 Climate Change Scoping Plan for public review an d comment (CARB, 2017). This update includes CARB’s strategy for achieving the state’s 2030 GHG target as established in Senate Bill (SB) 32 (discussed below). The strategy includes continuing the Cap -and-Trade Program through 2030,10 inclusive policies and broad support for clean technologies, enhanced industrial efficiency and competitiveness, prioritization of transportation sustainability, continued leadership on clean energy, putting waste resources to beneficial use, suppor ting resilient agricultural and rural economics and natural and working lands, securing California’s water supplies, and cleaning the air and public health. When discussing project -level GHG emissions reduction actions and thresholds, the 2017 Scoping Plan states “[a]chieving no net additional increase in GHG emissions, resulting in no contribution to GHG impacts, is an appropriate overall objective for new development.” However, the 2017 Scoping Plan also recognizes that such an achievement “may not be fea sible or appropriate for every project and the inability of a project to mitigate its GHG emissions to net zero
10 In July 2017, AB 398 was enacted into law, thereby extending the legislatively -authorized lifetime of the Cap-and-Trade Program to December 31, 2030.
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does not imply the project results in a substantial contribution to the cumulatively significant environmental impact of climate change under CE QA.” CARB’s Governing Board adopted the 2017 Scoping Plan in December 2017.
Executive Order B-55-18. EO B-55-18 (September 2018) establishes a statewide policy for the state to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter. The goal is an addition to the existing statewide targets of reducing the state’s GHG emissions. CARB will work with relevant state agencies to ensure that future scoping plans identify and recommend measures to achieve the carbon neutrality goal.
California Building Standards
Part 6 of Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and regulate California’s building standards. Part 6 establishes energy efficiency standards for residential and non -residential buildings constructed in California to reduce energy demand and consumption. Part 6 is updated periodically to incorporate and consider new energy efficiency technologies and methodologies. The 2016 Title 24 building energy efficiency standards, which became effective on January 1, 2017, further reduce energy used in the state. In general, single family homes built to the 2016 standards are anticipated to use approximately 28% less energy for lighting, heating, cooling, ventilation, and water heating than those built to the 2013 standards (CEC 2015). The current version of CalEEMod used in this analysis employs, as a default parameter, the 2016 Title 24 standards to estimate GHG emissions.
The 2019 Tit le 24 standards were approved and adopted by the California Building Standards Commission in December 2018. The 2019 standards became effective January 1, 2020. The standards require that all low -rise residential buildings shall have a photovoltaic system meeting the minimum qualification requirements such that annual electrical output is equal to or greater than the dwelling’s annual electrical usage. Notably, net energy metering rules limit residential rooftop solar generation to produce no more electricity than the home is expected to consume on an annual basis. Single -family homes built with the 2019 standards will use about 7% less energy due to energy efficiency measures versus those built under the 2016 standards, while new nonresidential buildings will use about 30% less energy mainly to lighting upgrades (CEC 2018).
The 2022 Building Energy Efficiency Standards (Energy Code) will improve upon the 2019 Energy Code for new construction of, and additions and alterations to, residential and nonresidentia l buildings. Workshops will be held to present revisions and obtain public comment. Proposed standards will be adopted in 2021 with an effective date of January 1, 2023. The California Energy Commission (CEC) updates the standards every three years.
Title 24, Part 11. In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as CALGreen and establishes minimum mandatory standards as well as voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conser vation, and interior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground -up, new construction of commercial, low -rise residential and state-owned buildings and schools and hospitals. The CALGreen 2016 standards became effective on January 1, 2017. The mandatory standards require mandatory reduction in indoor and outdoor water use, diversion of demolition waste, mandatory inspections of energy systems, inclusion o f electric vehicle charging stations for designated parking spaces and use of low -pollutant-emitting
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exterior and interior finish materials. At the time this GHG analysis was conducted, the 2019 standards were applicable and went into effect on January 1, 2020. The 2019 standards include mandatory measures for planning and design, energy efficiency, water and conservation efficiency, material and resource conservation as well as environmental quality. One of the most notable changes in the 2019 standards is the requirement for the installation of rooftop solar on residential buildings (California Energy Commission, 2017) . It should be noted that the State updates these regulations every three years. Thus, throughout Project const ruction, buildings will need comply with the most recently adopted standards.
Title 20 of the California Code of Regulations requires manufacturers of appliances to meet state and federal standards for energy and water efficiency. Performance of appliances must be certified through the CEC to demonstrate compliance with standards. New appliances regulated under Title 20 include: refrigerators, refrigerator -freezers and freezers; room air conditioners and room air - conditioning heat pumps; central air conditi oners; spot air conditioners; vented gas space heaters; gas pool heaters; plumbing fittings and plumbing fixtures; fluorescent lamp ballasts; lamps; emergency lighting; traffic signal modules; dishwaters; clothes washers and dryers; cooking products; electric motors; low voltage dry -type distribution transformers; power supplies; televisions and consumer audio and video equipment; and battery charger systems. Title 20 presents protocols for testing for each type of appliance covered under the regulations an d appliances must meet the standards for energy performance, energy design, water performance and water design. Title 20 contains three types of standards for appliances: federal and state standards for federally regulated appliances, state standards for f ederally regulated appliances, and state standards for non -federally regulated appliances.
Mobile Sources
State Vehicle Standards. AB 1493 requires CARB to set GHG emission standards for passenger vehicles and EO S -1-07 sets a declining Low Carbon Fuel Sta ndard to reduce the carbon intensity of California passenger vehicle fuels. The Advanced Clean Cars Program is an emissions control program to reduce smog-forming pollution, GHG emissions, promote clean cars, and provide fuels for clean cars. EO B -16-12 su pports and facilitates development and distribution of Zero Emissions Vehicles. As explained under the “Federal Vehicle Standards” description above, USEPA and NHTSA approved the SAFE Vehicles Rule Part One, which revoked California’s authority to set its own GHG emissions standards and set zero- emission vehicle mandates in California. As the USEPA rule is the subject of pending legal challenges, and no GHG adjustment factors have been issued for EMFAC by CARB, this analysis continues to utilize the best av ailable information at this time, as set forth in EMFAC.
Senate Bill 375 (2008) addresses GHG emissions associated with the transportation sector through regional transportation and sustainability plans. SB 375 required CARB to adopt regional GHG reduction targets for the automobile and light -truck sector for 2020 and 2035. Regional metropolitan planning organizations are then responsible for preparing a Sustainable Communities Strategy (SCS) within their Regional Transportation Plan (RTP). The goal of the SCS is to establish a forecasted development pattern for the region that, after considering transportation measures and policies, will achieve, if feasible, the GHG reduction targets. If an SCS is unable to achieve the GHG reduction target, a metropolitan planning organization must prepare an Alternative Planning Strategy demonstrating how the GHG reduction target would be achieved through alternative development patterns, infrastructure, or additional transportation measures or policies.
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Pursuant to Califo rnia Government Code Section 65080(b)(2)(K), a sustainable communities strategy does not (1) regulate the use of land; (2) supersede the land use authority of cities and counties; or (3) require that a city’s or county’s land use policies and regulations, including those in a general plan, be consistent with it. Nonetheless, SB 375 makes regional and local planning agencies responsible for developing those strategies as part of the federally required metropolitan transportation planning process and the state-mandated housing element process.
In 2010, CARB adopted the SB 375 targets for the regional metropolitan planning organizations. The targets adopted for SANDAG in 2010 are a 7% reduction in per capita passenger vehicle GHG emissions by 2020 and a 13% red uction by 2035, measured relative to 2005 GHG emissions. In 2018, CARB adopted the second round of SB 375 reduction targets, and increased SANDAG’s 2020 target to a 15% reduction in per capita passenger vehicle GHG emissions and the 2035 target to a 19% reduction, using the same 2005 baseline (CARB 2021b).
In October 2015, SANDAG adopted San Diego Forward: The Regional Plan, which contains the region’s current SCS. In December 2015, CARB, by resolution, accepted SANDAG’s GHG emissions quantification analysis and determination that, if implemented, the SCS would achieve CARB’s 2020 and 2035 GHG emissions reduction targets for the region. More specifically, as set forth in CARB Executive Order G -15-075, CARB determined that SANDAG’s SCS would achieve a 15 percent per capita reduction by 2020 and a 21 percent per capita reduction by 2035.
In 2018, CARB updated the SB 375 targets. For purposes of SANDAG, the updated targets include a 15 percent reduction in emissions per capita by 2020 and a 19 percent reduction by 2035. SANDAG is in the process of preparing its next SCS, which will consider whether and how the region could attain these reduction targets.
Currently SANDAG is working on the 2021 Regional Plan. The current Draft Plan provides a big picture vision for how the San Diego region will grow through 2050 and beyond with an implementation program to help make the plan a reality. Within the Draft Plan, SANDAG introduced a transformative vision for transportation in San Diego County that completely reimagines how people and goods could move throughout the region in the 21st century. The plan outlines the “5 Big Moves” which are: Complete Corridors, Transit Leap, Mobility Hubs, Flexible Fleets, and the Next OS.
The SANDAG Board of Directors will be asked to adop t the 2021 Regional Plan in late 2021. Once adopted, it will become the region’s long -term plan to be implemented incrementally through the Regional Transportation Improvement Program (RTIP) (SANDAG, 2021).
Advanced Clean Cars Program. In January 2012, CARB approved the Advanced Clean Cars program, a new emissions -control program for model years 2015 through 2025 (CARB 2012). The program combines the control of smog - and soot -causing pollutants and GHG emissions into a single coordinated package. The package includes elements to reduce smog-forming pollution, reduce GHG emissions, promote clean cars, and provide the fuels for clean cars. To improve air quality, CARB also has implemented new emission standards to reduce smog -forming emissions beginning with 2015 model year vehicles. It is estimated that, in 2025, cars will emit 75 percent less smog -forming pollution than the average new car sold today. To reduce GHG emissions, CARB, in conjunction with the USEPA and the NHTSA, also has adopted new GHG standard s for model year 2017 to 2025 vehicles; the new standards are estimated to reduce GHG emissions by 34 percent in 2025 (CARB 2021a).
EO B-16-12 (March 2012) directs state entities under the Governor’s direction and control to support and facilitate development and distribution of ZEVs. This EO also sets a long -term target of reaching
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1.5 million zero-emission vehicles on California’s roadways by 2025. On a statewide basis, EO B -16- 12 also establishes a GHG emissions reduction target from the transportation sector equaling 80 percent less than 1990 levels by 2050. In furtherance of this EO, the Governor convened an Interagency Working Group on Zero -Emission Vehicles that has published multiple reports regarding the progress made on the penetration of ZEVs in the statewide vehicle fleet.
Senate Bill 350. In 2015, SB 350 – the Clean Energy and Pollution Reduction Act – was enacted into law. As one of its elements, SB 350 establishes a statewide policy for widespread electrification of the transportation sector, recognizing that such electrification is required for achievement of the state’s 2030 and 2050 reduction targets (see California Public Utilities Code, Section 740.12).
Renewable Energy Procurement
SB 1078 (2002) established the Renewables Portfolio Standard (RPS) program, which requires an annual increase in renewable generation by the utilities equivalent to at least 1 percent of sales, with an aggregate goal of 20 percent by 2017. This goal was subsequently acc elerated, requiring utilities to obtain 20 percent of their power from renewable sources by 2010.
SB X1 2 (2011) expanded the RPS by establishing that 20 percent of the total electricity sold to retail customers in California per year by December 31, 2013, and 33 percent by December 31, 2020, and in subsequent years be secured from qualifying renewable energy sources. Under the bill, a renewable electrical generation facility is one that uses biomass, solar thermal, photovoltaic, wind, geothermal, fuel cells using renewable fuels, small hydroelectric generation of 30 megawatts or less, digester gas, municipal solid waste conversion, landfill gas, ocean wave, ocean thermal, or tidal current, and that meets other specified requirements with respect to its loca tion. In addition to the retail sellers previously covered by the RPS, SB X1 2 added local, publicly owned electric utilities to the RPS.
SB 350 (2015) further expanded the RPS by establishing that 50 percent of the total electricity sold to retail custome rs in California per year by December 31, 2030 be secured from qualifying renewable energy sources. In addition, SB 350 includes the goal to double the energy efficiency savings in electricity and natural gas final end uses (such as heating, cooling, light ing, or class of energy uses on which an energy -efficiency program is focused) of retail customers through energy conservation and efficiency.
SB 100 (2018) has further accelerated and expanded the RPS, requiring achievement of a 50 percent RPS by December 31, 2026 and a 60 percent RPS by December 31, 2030. SB 100 also established a new statewide policy goal that calls for eligible renewable energy resources and zero - carbon resources to supply 100 percent of electricity retail sales within the State of Cali fornia by December 31, 2045.
Water
EO B-29-15. In response to drought -related concerns, EO B -29-15 (April 2015) set a goal of achieving a statewide reduction in potable urban water usage of 25 percent relative to water use in 2013. The term of the EO exte nded through February 28, 2016, although many of the directives have since become permanent water -efficiency standards and requirements. The EO includes specific directives that set strict limits on water usage in the state. In response to EO B -29-15, the California Department of Water Resources has modified and adopted a revised version of the Model Water Efficient Landscape Ordinance that, among other changes, significantly increases the
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requirements for landscape water use efficiency and broadens its app licability to include new development projects with smaller landscape areas.
Solid Waste
AB 939 and AB 341. AB 939 (1989), known as the Integrated Waste Management Act (Public Resources Code Sections 40000 et seq.), was passed because of the increase in wa ste stream and the decrease in landfill capacity. The statute established the California Integrated Waste Management Board, which oversees a disposal reporting system. AB 939 mandated a reduction of waste being disposed where jurisdictions were required to meet diversion goals of all solid waste through source reduction, recycling, and composting activities of 25 percent by 1995 and 50 percent by the year 2000.
AB 341 (2011) amended the California Integrated Waste Management Act of 1989 to include a provision declaring that it is the policy goal of the state that not less than 75 percent of solid waste generated be source-reduced, recycled, or composted by the year 2020, and annually thereafter. In addition, AB 341 required the California Department of Resou rces Recycling and Recovery (CalRecycle) to develop strategies to achieve the state’s policy goal. CalRecycle has conducted multiple workshops and published documents that identify priority strategies that CalRecycle believes would assist the state in reaching the 75 percent goal by 2020.
Increasing the amount of commercial solid waste that is recycled, reused, or composted will reduce GHG emissions primarily by 1) reducing the energy requirements associated with the extraction, harvest, and processing of r aw materials and 2) using recyclable materials that require less energy than raw materials to manufacture finished products. Increased diversion of organic materials (green and food waste) will also reduce GHG emissions (CO
2 and CH 4) resulting from decompo sition in
landfills by redirecting this material to processes that use the solid waste material to produce vehicle fuels, heat, electricity, or compost.
Local
City of San Marcos Climate Action Plan
Consistent with AB 32, the City adopted a CAP in September 2013 as a long -range plan to reduce GHG emissions and mitigate climate change impacts associated with City government operations and with implementation of the City’s General Plan. An updated CAP was adopted on December 8, 2020.
The CAP outlines strategies and measures that the City will undertake to achieve its proportional share of State GHG emissions reduction targets. The CAP is a plan for the reduction of GHG emissions in accordance with California Environmental Quality Act (CEQA) Guidelines Section 15183.5. Pursuant to CEQA Guidelines Sections 15064(h)(3), 15130(d), and 15183(b), a project’s incremental contribution to a cumulative GHG emissions effect may be determined not to be cumulatively considerable if it complies with the requirements of the CAP (City of San Marcos 2020).
The City has also developed a Climate Action Plan Consistency Review Checklist (CAP Checklist), in conjunction with the CAP, to provide a streamlined review process for proposed new development projects that are subject to discretionary review and trigger environmental review pursuant to CEQA.
The CAP Consistency Guidance Memo dated July 15, 2020 summarizes the methodology and application of a GHG screening threshold which is set at 500 metric tons carbon dioxide equiva lent [MTCO
2e] per year as outlined int the CAP (Ascent 2020). Projects that are projected to emit fewer
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than 500 MTCO2e annually would not make a considerable contribution to the cumulative impact of climate change and would not need to provide additional analysis to demonstrate consistency with the CAP. This screening threshold is for new development projects consistent with the City’s General Plan. When such a project exceeds the screening threshold, the project would be required to demonstrate consistency with the CAP through the CAP Checklist.
In most cases, compliance with the CAP Checklist would provide the CEQA streamlining path to allow project specific environmental documents, if eligible, to tier from and/or incorporate by reference the CAP’s programmatic review of GHG impacts. Projects that are consistent with the General Plan and implement CAP Checklist GHG reduction measures may incorporate by reference the CAP’s cumulative GHG analysis. The City’s CAP meets the requirements under Section 15183.5 of the CEQA Guidelines as a qualified plan for the reduction of GHG emissions for use in cumulative impact analysis pertaining to development projects.
If a project is consistent with the existing General Plan land use designation(s), it can be determined to be consistent with the CAP projections and can move forward to Step 2 of the CAP Checklist.
For projects seeking a General Plan Amendment, such as the proposed project, the CAP Checklist requires a comparative analysis to determine if the General Plan Amendment results in an equivalent or less GHG -intensive project when compared to the existing designations. In addition to providing evidence to support the conclusion that the project would generate fewer emissions than existing designations, these proje cts would demonstrate consistency with the CAP through completion of Step 2 of the CAP Checklist.
If a General Plan Amendment results in a more GHG -intensive project, the project is required to prepare a quantitative GHG analysis based on applicable sections of the CEQA Guidelines.
City of San Marcos General Plan
Land Use and Community Design Element
• Goal LU-2: Promote development standards and land use patterns that encourage long -term environmental sustainability.
o Policy LU -2.1: Promote compact developmen t patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use. o Policy LU -2.3: Require the incorporation of green building practices, technologies, and strategies into development projects per code standards. o Policy LU-2.7: Promote the instillation of trees to reduce the urban heat -island effect and green infrastructure to reduce storm water runoff.
The Conservation and Open Space Element of the City of San Marcos General Plan identifies one goal and two policies regarding GHGs that are applicable to the proposed project:
• Goal COS -4: Improve regional air quality and reduce GHG emissions that contribute to climate change.
o Policy COS-4.3: Participate in regional efforts to reduce GHG emissions.
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o Policy COS-4.4: Quantify community-wide and municipal GHG emissions, set a reduction goal, identify and implement measures to reduce GHG emissions as required by governing legislation.
o Policy COS-4.5: Encourage energy conservation and the use of alternative energy sources within the community.
o Policy COS-4.6: Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure, and equipment.
Additionally, the Mobility Element of the City of San Marcos General Plan identifies one goal and associated policy that addresses GHG emission reductions through minimized vehicle miles traveled and reduced fuel consumption:
• Goal M-3: Promote and encourage use of alternative tra nsportation modes, including transit, bicycles, neighborhood electric vehicles (NEVs), and walking, within the City. o Policy M-3.1: Develop an integrated, multimodal circulation system that accommodates transit, bicycles, pedestrians, and vehicles; provides opportunities to reduce air pollution and GHG emissions; and reinforces the role of the street as a public space that unites the City.
The project’s consistency with applicable General Plan goals and policies is discussed in Section
3.10, Land Use and Pla nning. As detailed in Table 3.10 -5 in Section 3.10, the project is consistent with the applicable goals and policies pertaining to greenhouse gas emissions.
3.7.3 Thresholds of Significance
Appendix G of the State CEQA Guidelines identifies two evaluation criter ia to determine the significance of GHG emissions. A significant impact would be identified if the project would:
• Threshold #1: Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; or
• Threshold #2: Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing greenhouse gases.
The Cit y developed a CAP Checklist, in conjunction with the CAP, to provide a streamlined review process for proposed new development projects that are subject to discretionary review and trigger environmental review pursuant to CEQA.
The CAP Consistency Guidance Memo summarizes the methodology and application of a GHG screening threshold which is set at 500MTCO
2e per year (Ascent 2020). Projects that are projected
to emit fewer than 500 MTCO 2e annually would not make a considerable contribution to the cumulative impact of climate change and would not need to provide additional analysis to demonstrate consistency with the CAP. This screening threshold is for new development projects consistent with the City’s General Plan. When such a project exceeds the screening threshold, the project would be required to demonstrate consistency with the CAP through the CAP Checklist.
In most cases, compliance with the CAP Checklist would provide a streamlined CEQA review path to allow project specific environmental doc uments, if eligible, to tier from and/or incorporate by
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reference the CAP’s programmatic review of GHG impacts. Projects that are consistent with the General Plan and implement CAP GHG reduction measures may incorporate by reference the CAP’s cumulative GH G analysis. The City’s CAP meets the requirements under Section 15183.5 of the CEQA Guidelines as a qualified plan for the reduction of GHG emissions for use in cumulative impact analysis pertaining to development projects.
If a project is consistent with the existing General Plan land use designation(s), it can be determined to be consistent with the CAP projections and can move forward to Step 2 of the CAP Checklist.
For projects seeking a General Plan Amendment, such as the proposed project, the CAP Chec klist requires a comparative analysis to determine if the amendment results in an equivalent or less GHG - intensive project when compared to the existing designations. In addition to providing evidence to support the conclusion that the project would genera te fewer emissions than existing designations, these projects would demonstrate consistency with the CAP through completion of Step 2 of the CAP Checklist.
If a land use designation amendment results in a more GHG -intensive project, the project is required to prepare a quantitative GHG analysis based on applicable sections of the CEQA Guidelines.
3.7.4 Project Impact Analysis
GHGs related to construction and daily operations were calculated using the latest CalEEMod 2020.4.0 GHG model. The purpose of this analysi s is to complete a comparison between the proposed Project and the MU3 General Plan Buildout scenario. The construction module in CalEEMod was used to calculate the emissions associated with the construction of the project. The CalEEMod input/output model is shown in Attachments A and B of the GHG report in Appendix H1 of this document.
The project would start grading late 2022 with residential construction to start shortly thereafter.
Grading will consist of approximately 39,711 cubic yards (CY) of cut mat erial and 86,052 CY of fill material requiring an import of approximately 46,341 CY of fill material. Emissions generated by earthwork activities associated with grading were analyzed within CalEEMod using a “Grading Equipment Passes” methodology which ha s been approved by the South Coast Air Quality Management District (SCAQMD) As noted in the CalEEMod documentation, this methodology was approved by CAPCOA (CAPCOA 2021). Since CalEEMod was used for GHG emissions estimation from construction, this methodology was assumed.
Per the Project Engineer, during grading operations, a standalone rock crusher similar to a Terex 4242SR 310 horsepower (HP)+/ - would be onsite for ancillary crushing needs if necessary. An example of the crusher modeled within CalEEMod is shown in Attachment C of Appendix H1.
Construction of all residential units would be expected sometime in 2024. As previously discussed, the project’s blasting-related activities would not generate GHG emissions.
Threshold #1: Generate greenhouse gas emi ssions, either directly or indirectly, that may have a significant impact on the environment
The following analysis presents the anticipated emissions for the proposed project and for a development project that would be consistent with the existing General Plan designation of Mixed Use 3 (MU3).
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Proposed Project Construction Emissions
Construction-related GHG emissions include emissions from heavy construction equipment, blasting, rock crushing, truck traffic, soils import activities, and worker trips. Emiss ions for construction of the proposed project were calculated based on emission factors from the latest CalEEMod 2020.4.0 GHG model. The project would start grading late 2022 with residential construction to start shortly thereafter. Earthwork activities f or the project include an import of 46,341 CY of soil and would include a rock crusher during the grading operations. The project also may require some blasting - related activities; as such, the project’s air quality study estimated the criteria air polluta nts associated with blasting. Blasting -related activities would utilize ammonium nitrate with fuel oil (ANFO) based explosives. When ANFO detonates, the blast would produce both CO and NOx which are not considered GHGs (USEPA 1995).
After all the earthwork activities are complete, paving would occur and then home construction.
Construction of all residential units would be expected sometime in 2024. Table 3.7-2 presents the anticipated construction emissions for the proposed project. As shown in Table 3.7 -2, anticipated construction-related GHG emissions for the proposed project are estimated at 881.55 MT of CO 2e over the construction life of the project. Per guidance from SCAQMD, the construction -related emissions are amortized over a 30 -year period because impacts from construction activities occur over a relatively short-term period of time and they contribute a relatively small portion of the overall lifetime project GHG emissions (SCAQMD 2008). SDAPCD does not have guidance on this topic and SCAQMD’s rec ommended methodology has been widely accepted throughout the State. This amortized figure estimates project construction would contribute 29.38 MT per year of CO2e.
Table 3.7-2. Expected Annual Construction CO2e Emissions Summary (Proposed Project) Year Bio-CO2 NBio-CO2 Total CO2 CH4 N2O
Total CO2e
(metric
tons/year)
2022 0.00 164.80 164.80 0.02 0.02 170.08
2023 0.00 570.74 570.74 0.09 0.02 579.61
2024 0.00 130.56 130.56 0.02 0.00 131.86
Total Construction Emissions 881.55
Yearly Average Construction Emissions (Metric Tons/year over 30 years) 29.38 Source: Ldn Consulting 2021b.
Note: Expected Construction emissions are based upon CalEEMod modeling assumptions for equipment and durations listed in Table 4.1 of the GHG Report (Ldn 2021b).
Operational Emissions
Proposed Project Operational Emissions
Once construction is completed the proposed project would generate GHG emissions from daily operations which would include sources such as area, energy, mobile, solid waste, and water use s, which are calculated within CalEEMod. Area sources include consumer products, landscaping, and architectural coatings as part of regular maintenance. Energy sources would be from electricity and
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natural gas use. Mobile sources are from vehicular traffic . Solid waste generated in the form of trash is also considered as decomposition of organic material breaks down to form GHGs. Water sources include standard residential uses including landscaping activities. GHGs from water are also indirectly generated t hrough the conveyance of the resource via pumping throughout the state and as necessary for wastewater treatment. For consistency with the CAP, the project was analyzed under the 2030 year scenario. Also, no hearth (fireplace) options were included in the modeling. A design feature has been included in the project description to indicate exclusion of fireplaces from the project.
Electrical energy-intensity factors were updated in CalEEMod 2020.4.0 to reflect San Diego Gas and Electric’s (SDG&E) latest emiss ions rates which SDG&E provided to CAPCOA for the model update.
CalEEMod 2016.3.2 (the model prior to 2020.4.0) was based on default emissions from 2009 which included a 10.5 percent RPS factor as indicated by the California Public Utilities Commissions (CPUC) (CPUC 2016). The default CalEEMod 2020.4.0 emissions are now 540 pounds per megawatt hour (lbs/MWh) which when compared with the defaults is 2016.2 represents a 33 percent achievement for RPS in 2020 which is consistent with SBX1 -2. In accordance with SB 100, SDG&E will achieve an RPS of 60 percent in 2030.
Table 3.7-3 identifies the what the emissions in 2030 will be assuming a 60 percent RPS is achieved as required by current law.
Table 3.7-3. SDG&E Energy Intensity Factors
GHG
2009 Factors
(lbs/MWh) w/10.5%
RPS
Current RPS Factors
2020 33% Achieved
(lbs/MWh)
Current RPS Factors
2030 60% Achieved
(lbs/MWh)
Carbon Dioxide
(CO2) 720.49 539.98 322.38
Methane (CH4) 0.029 0.033 0.0197
Nitrous Oxide
(N2O) 0.006 0.004 0.0024
The project traffic engineer estimated that the project would generate 1,208 daily trips (LLG 2021).
These traffic numbers were utilized within the CalEEMod analysis. In addition, the project traffic study estimated that the MU3 General Plan Buildout scenario would generate 5 ,410 trips (LLG 2021). This GHG analysis uses a 5.4 mile trip distance which is consistent with the project’s air quality assessment which uses methodologies looking at EMFAC total vehicle miles traveled (VMT) divided by the total number of trips within Sa n Diego County (Ldn Consul ting, 2021a). It should be noted that the air quality assessment used a 2025 scenario and the VMT per trip may be slightly different in 2030. Since the project comparison would utilize the same year regardless, any changes in VMT per trip would be inconsequential. This trip distance was used for the illustrative comparative analysis only.
Additionally, it was assumed that an average of 10% of the structural surface area will be re -painted each year. The operational modeling results for the proposed project and the MU3 General Plan Buildout scenario can also be seen in Attachments A and B to the GHG Report in Appendix H.1 (LDN 2021b).
since the proposed project seeks a General Plan amendment, the proposed project’s analysis is based on a comparison between estimated emissions from the proposed use(s) and what would otherwise be approved under the existing General Plan. If a project’s proposed amendment to the
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General Plan would result in lower GHG emissions than development under the General Plan, the project would be required to implement the applicable CAP measures identified in Step 2 of the CAP Consistency Review Checklist. Table 3.7 -4 describes the CAP measures that are applicable to a multi-family residential project and how the proposed project will comply.
Table 3.7-4. Project Consistency with Applicable CAP Checklist Measures CAP Consistency Review Checklist Measures Project Compliance Electric Vehicle Charging Stations (Measure T-2)
Will the project install electric vehicle charging
stations (Level 2 or better) in at least five
percent of the total parking space provided on-
site?
The project has 56 guest parking spaces and
would include three Level 2 electric vehicle
charging stations. The project has been
designed to meet the requirements of Measure
T-2.
Transportation Demand Management (Measure
T-9)
Will the project develop and implement a TDM
plan that includes, at minimum, all of the TDM
strategies listed below?
Provide discounted monthly transit pass or
provide at least 25 percent transit fare subsidy
to residents/employees.
Provide designated car-share, carpool, vanpool,
and/or park-and-ride parking spaces.
Provide pedestrian connections between all
internal uses and to all existing or planned
external streets around the project site(s).
Provide secure bicycle parking spaces or bicycle
racks, showers, and clothes lockers.
Encourage telecommuting for employees (allow
one telecommute day per week or compressed
work weeks) or provide a telecommute work
center with common office space and equipment
available to residents.
Transit Discount: The HOA manager will provide
transit information to the owners and make a
good faith effort in offering discounted transit
fares. The HOA will provide a newsletter to
inform the residents there are options for
reduced transit passes.
Designated Parking: The project will provide
designated car-share, carpool, vanpool, EV
and/or park-and-ride spaces on site.
Pedestrian Connections: The project design
includes pedestrian connections within the
project and to connect to the sidewalk on
Barham.
Bicycle Spaces: The project will provide bicycle
racks and additional secure bicycle storage is
available within each of the garages attached to
the homes. Residents will have access to
showers in their homes.
Telecommuting: The project will have space
available in the community room for residents to
telecommute. Each residence will also have a
suitable area for telecommuting.
The project has been designed to meet the
requirements of Measure T-9.
Water Heaters (Measure E-1)
Will the project install one of, or a combination
of, the following water heater types in place of
natural gas heaters?
The project will install electric tank water heaters
within all units. Natural gas water heaters will
not be used. The project has been designed to
meet Measure E-1.
Landscaping Water Use (Measure W-1) The project will comply with the City’s Water Efficient Landscape Ordinance. The project has
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CAP Consistency Review Checklist Measures Project Compliance Will the project comply with the City’s Water
Efficient Landscape Ordinance?
been designed to meet Measure W-1.
Urban Tree Canopy (Measure C-2)
For multi-family residential, if the project is
provided more than 10 parking spaces, will the
project plant at least one tree per five parking
spaces provided?
The project proposes 66 parking spaces of
which 10 are reserved for residents. Per the
landscape concept plan, the project will plant
243 trees. The project exceeds the requirements
of Measure C-2.
Table 3.7-5 presents the proposed project’s operational emissions summary. As shown in Table 3.7 - 5, the project would generate 954.74 MT CO 2e per year without incorporating any CAP measures.
The project would be required to implement all of the applicable CAP measures identified in Table
3.7-4 and these measures would further reduce GHG emissions. Since the intent of this analysis is to compare the propose d project with the MU3 General Plan Buildout scenario, not all CAP measures were calculated as a GHG reduction. Including the GHG reduction associated with CAP Measure T -2, the provision of three Level 2 electric vehicle charging stations, the project woul d generate 949.79 MT CO2e/Year.
Table 3.7-5. Proposed Project Operational Emissions Summary (MT/Year) Source Bio-CO2 NBio-CO2 Total CO2 CH4 N2O CO2e (MT/Yr)
Area 0.00 1.83 1.83 0.00 0.00 1.88
Energy 0.00 216.47 216.47 0.01 0.00 217.48
Mobile 0.00 618.74 618.74 0.05 0.03 628.77
Waste 14.10 0.00 14.10 0.83 0.00 34.93
Water 3.12 28.81 31.93 0.32 0.01 42.30
Operations Total 925.36
Construction Emissions (See Table 3.7-2 above) 29.38
Construction and Operations 954.74
CAP Measure T-2: EV Charger Reduction -4.95
Project GHG Emissions 949.79
Source: Ldn Consulting 2021b.
Note: The data is presented in decimal format and may have rounding errors.
MU3 General Plan Buildout Emissions
The MU3 General Plan Buildout scenario is assumed to have a similar construction footprint as the proposed project. A similar construction model was prepared based on default settings though did include manual updates similar to the project to reflect iden tical cut/fill/import as well as rock breaking activities. The equipment list and durations are identical for the MU3 General Plan Buildout scenario as shown in Table 4.1 of the GHG report (Appendix H1).
Table 3.7 -6 presents the
construction emissions from the MU3 General Plan Buildout scenario.
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Table 3.7-6. MU3 General Plan Buildout Scenario - Annual Construction CO2e Emissions Summary Year Bio-CO2 NBio-CO2 Total CO2 CH4 N2O CO2e
(MT)
2022 0.00 166.10 166.10 0.02 0.02 171.39
2023 0.00 874.39 874.39 0.10 0.06 893.28
2024 0.00 205.28 205.28 0.03 0.01 208.95
Total Construction Emissions 1,273.62
Yearly Average Construction Emissions (Metric Tons/year over 30 years) 42.45 Source: Ldn Consulting 2021b.
Once construction is completed the MU3 General Plan Buildout scenario would generate GHG emissions from daily operations which would include sources such as area, energy, mobile, solid waste, and water uses which are calculated in CalEEMod. The traffic study estimated that buildout of the MU3 General Plan Buildout scenario would generate 5,410 trips (LLG 2021). Under this scenario, different CAP Checklist measures would apply since it would be a non -residential project.
The CAP measures required for the non-residential development would include:
• Electric Vehicle Charging Stations (Measure T -2) – The MU3 General Plan Buildout scenario would have 879 parking locations and would include 44 Electric Vehicle Charging Stations. • Transportation Demand Management (Me asure T -9) – The MU3 General Plan Buildout scenario would implement all of the TDM strategies identified in Measures T-9. • Photovoltaic Installation (Measure E -2) – The MU3 General Plan Buildout scenario would install photovoltaic systems with a minimum cap acity of two watts per square foot of gross floor area.
• Urban Tree Canopy (Measure C -2) – The MU3 General Plan Buildout scenario would plant at least one tree per five parking spaces provided for a minimum of 176 trees.
Table 3.7 -7presents the operational emissions summary for the MU3 General Plan Buildout scenario. As shown in Table 3.7 -7, the MU3 General Plan Buildout scenario would generate 3,964.92 MT CO 2e per year without incorporating any CAP measures. This scenario would be required to implement all of the applicable CAP measures identified above and these measures would further reduce GHG emissions. When reduction for CAP Measures T -2 and E-2 are considered, the MU3 General Plan Buildout scenario would generate 3,269.10 MT CO2e per year.
Table 3.7-7. MU3 General Plan Buildout Scenario Operational Emissions Summary (MT/Year) Source Bio-CO2 NBio-CO2 Total CO2 CH4 N2O CO2e
(MT/Yr)
Area 0.00 0.02 0.02 0.00 0.00 0.02
Energy 0.00 1069.60 1069.60 0.05 0.01 1074.25
Mobile 0.00 2453.97 2453.97 0.20 0.12 2495.21
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Source Bio-CO2 NBio-CO2 Total CO2 CH4 N2O CO2e
(MT/Yr)
Waste 55.84 0.00 55.84 3.30 0.00 138.34
Water 15.94 145.71 161.65 1.65 0.04 214.65
Operations Total 3,922.47
Construction Emissions (See Table 3.7-5) 42.45
Construction and Operations 3,964.92
CAP Measure T-2: EV Charger Reduction -400.40
CAP Measures E-2: Solar PV Installation -295.42
MU3 General Plan Buildout Scenario Project GHG Emissions 3,269.10 Source: Ldn Consulting 2021b.
Comparison of the Proposed Project and the MU3 General Plan Buildout Scenario When the proposed project’s GHG emissions are compared to the GHG emissions under the MU3 General Plan Buildout scenario, it is estimated that the proposed project would result in 70% lower GHG emissions (949.79 MT CO 2e per year comp ared to 3,269.10 MT CO 2e per year) compared to a General Plan (MU3 General Plan Buildout scenario. This is driven largely by the reduced number of vehicle trips that would occur under the proposed project compared to buildout under the General Plan. The project will also impleme nt all of the CAP Checklist measures that are applicable to multi- family housing. Projects that propose a General Plan Amendment and have GHG emissions that are less than would be anticipated for a project that would be consistent with the General Plan and implement CAP GHG reduction measures may incorporate by reference the CAP’s cumulative GHG analysis. The City’s CAP meets the requirements under Section 15183.5 of the CEQA Guidelines as a qualified plan for the reduction of GHG emissions for use in cumul ative impact analysis pertaining to development projects. The CAP Checklist provides a streamlined review process for the GHG emissions analysis of proposed new development projects that are subject to discretionary review and trigger environmental review pursuant to CEQA. As such, the proposed project would not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. Impacts would be
less than significant.
Threshold #2: Conflict with an applic able plan, policy, or regulation adopted for the purpose of reducing GHGs
The proposed project will emit GHGs directly through the burning of carbon -based fuels such as gasoline as well as indirectly through usage of electricity, natural gas, water, and fr om wastewater treatment as well as the anaerobic bacterial breakdown of organic solid waste. The analysis above considered the GHG emissions of the proposed project in comparison to the emissions that would be anticipated from a project that was consisten t with the existing General Plan (MU3 General Plan Buildout scenario). When the proposed project’s GHG emissions are compared to the GHG emissions under the MU3 General Plan Buildout scenario, the project results in a 70% reduction in GHG emissions (949.79 MT CO
2e per year compared to 3,269.10 MT CO2e per year) compared to an MU3 General Plan Buildout scenario. This is driven largely by the reduced number of vehicle trips that would occur under the proposed project compared to buildout under the General Pla n. The project
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will also implement all of the CAP Checklist measures that are applicable to multi-family housing. The proposed project would be consistent with the City’s CAP.
In addition to the City’s CAP, the General Plan include goals and policies relat ed to GHG emission, as detailed in Section 3.7.2. The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10, Land Use and Planning. As detailed in Table 3.10 -5 in Section 3.10, the project is consistent with the applicable goals and policies pertaining to greenhouse gas emissions.
In summary, the project will not conflict with any applicable plan, policy or regulation adopted for the purpose of reducing GHGs and impacts will be less than significant.
3.7.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate di scussion of a project’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future projects producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect.
The CAP outlines strategies and measures that the City will undertake to achieve its proportional share of S tate GHG emissions reduction targets. The CAP is a plan for the reduction of GHG emissions in accordance with California Environmental Quality Act (CEQA) Guidelines Section 15183.5. Pursuant to CEQA Guidelines Sections 15064(h)(3), 15130(d), and 15183(b), a project’s incremental contribution to a cumulative GHG emissions effect may be determined not to be cumulatively considerable if it complies with the requirements of the CAP (City of San Marcos 2020).
As presented in Section 3.7.4, the project complies with the City’s CAP. Therefore, the project’s incremental contribution to a cumulative GHG emissions effect is determined not to be cumulatively considerable and impacts would be less than significant.
3.7.6 Mitigation Measures
Based upon the analysis presented in Sections 3.7.4 and 3.7.5, project and cumulative greenhouse gas impacts would be less than significant. Therefore, no mitigation measures are necessary.
3.7.7 Conclusion
The analysis above considered the GHG emissions of the proposed project in comparison to the emission that would be anticipated from a project that was consistent with the existing General Plan (MU3 General Plan Buildout scenario). When the proposed project’s GHG emissions are compared to the GHG emissions under the MU3 General P lan Buildout scenario, the project results in a 70% reduction in GHG emissions (949.79 MT CO
2e per year compared to 3,269.10 MT CO 2e per year)
compared to an MU3 General Plan Buildout scenario. This is driven largely by the reduced number of vehicle trips that would occur under the proposed project compared to buildout under the General Plan. The project will also implement all of the CAP Checklist measures that are applicable to multi- family housing. The proposed project would be consistent with the City’s CAP. In addition to the City’s CAP, the General Plan include goals and policies related to GHG emission, as detailed in Section
3.7.2. The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10, Land Use and Pla nning. As detailed in Table 3.10 -5 in Section 3.10, the project is consistent with the applicable goals and policies pertaining to greenhouse gas emissions.
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In summary, the project will not conflict with any applicable plan, policy or regulation adopted for the purpose of reducing GHGs and impacts would be less than significant.
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3.8 Hazards and Hazardous Materials
This section analyzes the potential for the proposed project to have impacts related to hazards and hazardous materials. The following documents was used in the preparation of this section and are included in their entirety as Appendix I of this Environmental Impact Report (EIR):
• Phase I and Phase II Environmental Site Assessment (ESA Report), 943 Barham Drive San Marcos, California. Prepared by GEOCON Incorporated. March 9, 2020.
The Phase I Environmental Site Assessment (Phase 1 ESA) was undertaken to assess the likelihood of any recognized environmental conditions (RECs) that might be present on -site as a result of current or historical land uses or adjacent uses. The Phase 1 ESA included site reconnaissance of the project site, reconnaissance of adjoining properties, a review of the historical usage of the project site, and a review of relevant documentation provided by variou s public and private sources.
Regulatory information was also reviewed from federal, state, and local agencies through various electronic databases listing possible hazardous waste -generating facilities on and within the vicinity of the project site. A Pha se II ESA was also undertaken to assess the potential presence of contaminants of concern at the project site due to historical agricultural use at the site.
The American Society for Testing and Materials (ASTM) Designation E 1527-13 Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process defines a REC as “the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to release to the environment; (2) under con ditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment. De minimis conditions are not recognized environmental conditions” (ASTM 2013). De minimis conditions are those that generally do not present a threat to human health or the environment and that generally would not be the subject of enforcement action if brought to the attention of appropriate governmental agencies.
ASTM Designation E 1527 -13 also defines Historical RECs. They define a ‘Historical REC’ (HREC) as “A past release of any hazardous substances or petroleum products that has occurred in connection with the property and has been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted use criteria established by a regulatory authority, without subjecting the property to any required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls)” (ASTM 2013).
Table 3.8-1 summarizes the hazards/hazardous materials and cumulative -level impact analysis, by threshold, for the proposed project.
Table 3.8-1. Hazards and Hazardous Materials Summary of Impacts Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact after
Mitigation
#1: Create a significant hazard to the public
or the environment through the routine
transport, use, or disposal of hazardous
materials
Less than
Significant
Less than
Significant
Less than
Significant
#2: Create a significant hazard to the public
or the environment through reasonably
Less than
Significant
Less than
Significant
Less than
Significant
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Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact after
Mitigation
foreseeable upset and accident conditions
involving the release of hazardous
materials into the environment
#3: Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within one-quarter
mile of an existing or proposed school?
No Impact No Impact No Impact
#4: Be located on a site which is included
on a list of hazardous materials sites
compiled pursuant to Government Code
Section 65962.5 and, as a result, would it
create a significant hazard to the public or
the environment
Less than
Significant
Less than
Significant
Less than
Significant
#5: For a project located within an airport
land use plan, or, where such a plan has
not been adopted, within two miles or a
public airport or public use airport, would
the project result in a safety hazard for
people residing or working in the project
area
Less than
Significant
Less than
Significant
Less than
Significant
#6: Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan
Less than
Significant
Less than
Significant
Less than
Significant
#7: Expose people or structures to a
significant risk of loss, injury or death
involving wildland fires, including where
wildlands are adjacent to urbanized areas
or where residences are intermixed with
wildlands
Less than
Significant
Less than
Significant
Less than
Significant
3.8.1 Existing Conditions
This section describes the existing conditions on the project site and vicinity related to hazards and hazardous materials.
Historical Land Uses
Aerial photographs, topographic maps, and previous reports of the project site were reviewed for evidence of past land uses that had the potential to have impacted the project site through the use, storage, or disposal of hazardous substances and/or petroleum products. Per the Phase I ESA, the project site had been used for agricultural uses, as row crops appear to have been present across the majority of the site back in 1939 . An orchard and a rural residence also appear to have been in the northeastern portion of the site in 1939. By 1970, historical photographs indicate that the
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agricultural use of the land had ceased . By 1985 residential and farming buildings were no longer visible on site. The project site has remained vacant since approximately 1985 . The past agricultural use of the s ite from sometime prior to 1939 up until approximately 1970 suggests that pesticides may have been used on the site. If so, persistent pesticides and associated metals (arsenic) may be present in soil. Given the proposed project is a residential development, the site the former agricultural use of the site is considered a REC. This is further detailed in the Phase II ESA discussion below.
Database Review
An environmental regulatory database review of local, state, and federal regulatory databases was conducted for the project site and facilities within one mile of the p roject site. The databases track the presence of underground storage tanks (USTs), hazardous waste generation, and hazardous material releases. The complete database search is included as part of Appendix I of this EIR. The project site was not listed on a ny of the regulatory databases reviewed. There are 19 properties identified in the database search within 1/8 -mile (or 1/4 mile of the project site that were identified as having leaking underground storage tank (LUST) facilitie s). Per the Phase I ESA, non e of these facilities are likely to have caused a REC at the project site. (GEOCON 2020).
Additionally, the database review identified one orphan site, or properties whose incomplete information made plotting difficult. Because the orphan property is great er than 1/4 mile from the project site, it is not suspected of having caused a REC at the project site.
Site Reconnaissance
As presented in the Phase 1 ESA prepared for the proposed project, the project site and surrounding properties were systematically traversed on foot in February 2020 by GEOCON. The offsite survey was performed by observing adjacent properties from the project site and adjacent public streets.
The project site was observed to be undeveloped with hilly terrain. The topogr aphy is dominated by two hills; one that peaks to the south and the other that gently slopes to the west and northwest.
GEOCON observed three former building foundations located in the northeastern portion of the site that included crushed concrete and wha t appeared to be cages used for raising chickens . An abandoned irrigation line was also observed in the central northern portion of the site . No odors, pools of liquid, stained soil or distressed vegetation on site was observed . No evidence of RECs was observed at the project site or surrounding properties.
No hazardous wastes were observed at the project site. No hazardous materials and/or petroleum products were observed to be used or stored at the project site. No indications of releases of hazardous mat erials/wastes or petroleum products were noted, no electrical transformers were observed to be located at the site, and no obvious indications of wells, cisterns, pits, sumps, dry wells, or bulk storage tanks were observed at the site. Similarly, no obviou s indications of the use, storage, or generation of hazardous materials/wastes or petroleum products were observed adjacent to the project site. No California Division of Oil, Gas, and Geothermal Resources -related features were located within one mile of the project site.
Phase II ESA
GEOCON performed a Phase II ESA to assess the potential presence of organochlorine pesticides (OCPs) and arsenic in soil related to the former agricultural use of the project site. The nature and
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extent of OCPs and arsenic in soil can be used to determine if a potential health risk for future site residents exists and if further action to mitigate that risk is warranted.
In February 2020, 20 surface samples were collected for analytical testing. Surface soil at the project site was predominately moist, dark brown, silty sand. No obvious indications of contamination such as odors or soil discoloration were observed during sampling for the Phase II ESA. OCPs and arsenic were not detected at concentrations exceeding the laboratory detection limits in the soil samples. GEOCON concluded that further investigation of impacts to the site from the historical agricultural use of the site does not appear warranted at this time (GEOCON 2020).
Wildland Fire
The project site is located in a L ocal Responsibility Area with a Non -Very High Fire Hazard Severity Zone (Non-VHFHSZ) designation per CalFire’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as a Non -VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding area are not identified as a SMFPD Community Hazard Zone.
The project includes a 150 -foot onsite fuel modification buffer along the southern portion of the project site to further minimize fire risk to the proposed development . Per the Fire Marshal, offsite fuel modification is not required for the project. A discussion of fire protection services for the proposed project is discussed in Section 3.13, Public Services, and additional analysis related to wildfire is presented in Section 3.18, Wildfire, of the EIR.
3.8.2 Regulatory Setting
This section details the federal, state, and local regulations governing hazards and hazardous materials.
Federal
Chemical Accident Prevention Provision
The provisions listed under Part 68 of the Code of Federal Regulations (CFR) set forth the list of regulated substances and thresholds, the petition process for adding or deleting substances to the list of regulated substances, the requirements for owners or operators of stationary source s concerning the prevention of accident releases, and the state accidental release prevention programs approved under Section 112(r) of the Clean Air Act.
Federal Aviation Regulations, Notice of Proposed Construction or Alteration The Federal Aviation Administration (FAA), which has primary responsibility for the safety of civil aviation, imposes height restrictions in order to prevent obstructions to navigable airspace to protect flights and surrounding structures. In certain cases, the FAA should be notif ied of proposed development pursuant to Section 77.11 of Federal Aviation Regulations (FAR). The notification of proposed development enables the FAA to provide a basis for:
• Evaluating the effect of the construction or alteration on operational procedures and proposed operational procedures;
• Determinations of the possible hazardous effect of the proposed construction or alteration of air navigation;
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• Recommendations for identifying the construction or alteration in accordance with current FAA Advisory Circul ar AC 70/7460 -1K dated August 1, 2000, Obstruction Marking and Lighting;
• Determining other appropriate measures to be applied for continued safety of air navigation; and
• Charting and other notification to airmen of the construction or alteration.
Certain jurisdictions can request an FAA evaluation of proposed development when certain features appear to be potentially hazardous.
Federal Disaster Mitigation Act of 2000
The Disaster Mitigation Act of 2000 provided a new set of mitigation plan requirements for state and local jurisdictions to coordinate disaster mitigation planning and implementation. States are encouraged to complete a “Standard” or an “Enhanced” Natural Mitigation Plan. “Enhanced” plans demonstrate increased coordination of mitigation activities at the state level, and, if completed and approved, increase the amount of funding through the Hazard Mitigation Grant Program. California’s updated State Hazard Mitigation Plan was adopted in October 2010, and approved by the Federal Emergency Management Agency (FEMA) Region IX. The City of San Marcos is one of the communities covered by the County of San Diego Multi -Jurisdictional Hazard Mitigation Plan, describe d below, which is a countywide plan that identifies risks posed by natural and human-made disasters.
Hazardous Materials Transport
The U.S. Department of Transportation (USDOT) regulates transportation of hazardous materials between states. State agencies with primary responsibility for enforcing federal and state regulations and responding to hazardous materials transportation emergencies are California Highway Patrol (CHP) and the California Department of Transportation (Caltrans). Together, these agencie s determine container types used and license hazardous waste haulers for transportation of hazardous waste on public roads, including explosives that may be used for blasting.
International Fire Code
The International Fire Code (IFC), created by the Intern ational Code Council, is the primary means for authorizing and enforcing procedures and mechanisms to ensure the safe handling and storage of any substance that may pose a threat to public health and safety. The IFC regulates the use, handling, and storage requirements for hazardous materials at fixed facilities. The IFC and the International Building Code (IBC) use a hazard classification system to determine what protective measures are required for fire and life safety. These measures may include construction standards, separations from property lines, and specialized equipment. To ensure that these safety measures are met, the IFC employs a permit system based on hazard classification. The IFC is updated every 3 years.
Resource Conservation and Recovery A ct
The Resource Conservation and Recovery Act (RCRA) gives the United States Environmental Protection Agency ( USEPA) the authority to control hazardous waste from the "cradle -to-grave." This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA also set forth a framework for the management of non -hazardous solid wastes. The 1986
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amendments to RCRA enabled the EPA to address environmental problems that could result from underground tanks storing petroleum and other hazardous substances.
Hazardous and Solid Waste Amendments of 1984
The Hazardous and Solid Waste Amendments of 1984 amended the Solid Waste Disposal Act of 1965 (SWDA), as amended by the RCRA of 1976. In general, both the scope and requirements of the SWDA, as amended by RCRA, were significantly expanded and reinforced.
State
The state regulations that govern hazardous materials are equal to or more stringent than federal regulations. California has been granted primary oversight responsibility by EPA to administer and enforce hazardous waste management programs. State regulat ions have detailed planning and management requirements to ensure that hazardous wastes are handled, stored, and disposed of properly to reduce risks to human health and the environment. Several key state laws pertaining to hazardous wastes are discussed b elow. In addition, the Department of Toxic Substance Control (DTSC), the State Water Resources Control Board (SWRCB), and the Integrated Waste Management Act also regulate the generation of hazardous materials, also described below.
California Emergency Services Act
The California Emergency Services Act provides the basic authority for conducting emergency operations following a proclamation of emergency by the governor and/or appropriate local authorities. Local government and district emergency plans are considered to be extensions of the California Emergency Plan, established in accordance with the Emergency Services Act.
California Fire Code
The California Fire Code (CFC) is Chapter 9 of CCR Title 24. It is created by the California Building Standards Commission and is based on the IFC created by the International Code Council, described above. It is the primary means for authorizing and enforcing procedures and mechanisms to ensure the safe handling and storage of any substance that may pose a threat to public health and safety.
The CFC regulates the use, handling, and storage requirements for hazardous materials at fixed facilities. The CFC and the CBC use a hazard classification system to determine what protective measures are required to protect fire a nd life safety. These measures may include construction standards, separations from property lines, and specialized equipment. To ensure that these safety measures are met, the CFC employs a permit system based on hazard classification. The CFC is updated every 3 years. The CFC is adopted by reference as Chapter 17.64 –California Fire Code for the San Marcos Fire Department.
California Health and Safety Code, Hazardous Materials Release Response Plans and Inventory Two programs found in the California Health and Safety Code (H&SC) Chapter 6.95 are directly applicable to the CEQA issue of risk due to hazardous substance release. In San Diego County, these two programs are referred to as the Hazardous Materials Business Plan (HMBP) program and the California Accidental Release Program (CalARP), which is the state adaptation of CFR Part 68, described above. The Department of Environmental Health (DEH) is responsible for the implementation of the HMBP program and CalARP in San Diego County. The HMBP and CalARP programs provide threshold quantities for regulated hazardous substances. When the indicated quantities are exceeded, an HMBP or Risk Management Plan (RMP) is required pursuant to the
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regulation. Congress requires USEPA Region 9 to make RMP information availa ble to the public through the USEPA’s Envirofacts Data Warehouse.
California Integrated Waste Management Act
This act requires the development and implementation of household hazardous waste disposal plans. The Department of Resources Recycling and Recover y (CalRecycle), formerly the California Integrated Waste Management Board, oversees compliance with this act and enforces operational plans for solid waste facilities.
Emergency Response to Hazardous Materials Incidents
California has developed an emergency response plan to coordinate emergency services provided by federal, state, and local governments and private agencies. Response to hazardous material incidents is one part of this plan. The plan is managed by the California Emergency Management Agency, which coordinates the responses of other agencies, including the California Environmental Protection Agency (Cal/EPA), CHP, the California Department of Fish and Wildlife (CDFW), and the Regional Water Quality Control Board (RWQCB).
Emergency Services Act
Under the Emergency Services Act (California Government Code Section 8850 et seq.), the state developed an emergency response plan to coordinate emergency services provided by federal, state, and local agencies. Quick response to incidents involving hazardous materials or hazardous waste is a key element of this plan. The Governor’s Office of Emergency Services administers the plan, coordinating the responses of other agencies, including EPA, CHP, RWQCBs, air quality management districts, and county disaster response offices.
Government Code Section 65962.5 (Cortese List)
The provisions of Government Code Section 65962.5 are commonly referred to as the Cortese List.
The Cortese List is a planning document used by the state and local agencies to provide inform ation about hazardous materials release sites. Government Code Section 65962.5 requires Cal/EPA to develop an updated Cortese List annually, at minimum. DTSC is responsible for a portion of the information contained in the Cortese List. Other California st ate and local government agencies are required to provide additional hazardous material release information for the Cortese List.
Hazardous Waste Control Act
The Hazardous Waste Control Act is implemented by regulations contained in California Code of Regulations (CCR) Title 26 that describe requirements for the proper management of hazardous wastes. The act created the state hazardous waste management program, which is similar to but more stringent than the federal RCRA program. The Hazardous Waste Control Act and Title 26 regulations list more than 800 potentially hazardous materials and establish criteria for identifying, packaging, transporting, and disposing of such wastes. Under these regulations, the generator of hazardous waste material must complete a manifest that accompanies the material from the point of generation to transportation to the ultimate disposal location, with copies of the manifest filed with the DTSC.
Unified Program
Cal/EPA delegates to qualifying local agencies oversight and permitting responsibility for certain state programs pertaining to hazardous waste and hazardous materials. This is achieved through the
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Unified Program, created by state legislation in 1993 to consolidate, coordinate, and make consistent the administrative requirements, permits, inspections, and enforcement activities for the following emergency and management programs:
• Hazardous materials release response plans and inventories (business plans); • California Accidental Release Prevention Program (CalARP); • Underground Storage Tank Program;
• Aboveground Petroleum Storage Act Requirements for Spill Prevention, Control and Countermeasure plans;
• Hazardous Waste Generator and On -site Hazardous Waste Treatm ent (tiered permitting) Programs; and
• California Uniform Fire Code: Hazardous material management plans and hazardous material inventory statements.
The County of San Diego is the designated certified unified program agency for all local jurisdictions within the San Diego region, including San Marcos.
State Responsibility Area Fire Safe Regulations (Title 14 Natural Resources, Department of Forestry Fire Protection)
These regulations constitute the basic wildland fire protection standards of the California Board of Forestry. They have been prepared and adopted for the purpose of establishing minimum wildfire protection standards in conjunction with building, construction, and development in State Responsibility Areas (SRAs). Title 14 regulates that the futur e design and construction of structures, subdivisions, and developments in an SRA shall provide for basic emergency access and perimeter wildfire protection measures.
Local
Airport Land Use Commission and Airport Land Use Compatibility Plans Airport Land Use Commissions assist local agencies in ensuring compatible land uses in the vicinity of existing or proposed airport; coordinate planning at state, regional and local levels; prepare and adopt airport land use policies; review plans or regulations submitt ed by local agencies; and review and makes recommendation regarding the land use, building heights, and other issues related to air navigation safety and the promotion of air commerce. The San Diego County Regional Airport Authority is the ALUC for the San Diego region.
The closest public airport to the project site is the McClellan -Palomar Airport located in the City of Carlsbad, approximately 7.5 miles west of the project site. The McClellan -Palomar Airport Land Use Compatibility Plan (ALUCP) contains pol icies to promote land use compatibility between the McClellan-Palomar Airport and the adjacent and proximate land uses, to the extent these areas are not already developed with existing uses, and protect the public health, safety, and welfare ( San Diego County Regional Airport Authority 2011). Using airport -related forecasts and background data approved by the California Department of Transportation, Division of Aeronautics, the plan reflects anticipated growth of the airport over a 20 -year horizon. The pla n includes land use compatibility criteria and identifies policies applicable to the airport and surrounding land uses.
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According to the McClellan-Palomar ALUCP and Figure 6-5 of the Safety Element of the City’s General Plan, the project site lies within R eview Area 2 of the airport influence area. The influence area is regulated by the ALUC, which regulates land uses in the area to be compatible with airport -related noise, safety, airspace protection, and over -flight factors through review of development p roposals within the airport influence area. Review Area 2 consists of limits on heights of structures in areas of high terrain. Residential development in Review Area 2 may be subject to annoyances commonly associated with proximity to airports, such as noise, vibration, and overflights.
County of San Diego Multi-Jurisdictional Hazard Mitigation Plan To comply with the Disaster Mitigation Act of 2000, the County of San Diego prepared the Multi - Jurisdictional Hazard Mitigation Plan. The plan serves as both a county-wide plan and a plan for local jurisdictions that identifies risks posed by natural and human -made disasters before a hazard event occurs. The plan includes overall goals and objectives shared by many jurisdictions, as well as specific goals, objectives, and mitigation action items for each of the participating jurisdictions to help minimize the effects of the specified hazards that could potentially affect their jurisdiction.
Goals, objectives, and action items for the City of San Marcos are included in this plan.
San Marcos Fire Department Hazard Risk Analysis and Wildland Urban Interface Community Wildfire Protection Plan
The CWPP, adopted in December 2007, was developed by the San Marcos Fire Department (SMFD) with guidance from the County of San Diego, California Department of Forestry and Fire Protection and the United States Forest Service. The CWPP supplements San Diego County, Department of Planning and Land use documents. Supplemental to the CWPP, the SMFD published the Hazard Risk Analysis (HRA) for internal City use, incorporating new and existing information relating to wildfire risk within the City to better quantify true risk and management needs. The HRA quantifies, clarifies, and manages the wildland urban interface (WUI) responsibility and meets the requirements of the federal Healthy Forests Restoration Act (HFRA) of 2003 for community fire planning.
City of San Marcos, Ordinance 2003-1216
The City Ordinance 2003 -1216 amends Chapter 17.64 of the Municipal Code to adopt the most recent version of the California Fire Code. Concurrently, this ordinance requires all buildings or structures to provide and maintain an effective fuel modification zone of 150 feet.
City of San Marcos General Plan Safety Element
The Safety Element of the San Marcos General Plan contains several goals and policies pertaining to hazards and hazardous materials. The following goals and policies apply to the proposed project:
• Goal S -3: Minimize injury, loss of life, and damage to property results from structure or wildland fire hazards.
o Policy S -3.1: Require development to be located, designed, and constructed to provide adequate defensibility and reduce the risk of structural loss and life resulting from wildland fires. Development will consider hazard s relative to terrain, topography, accessibility, and proximity to vegetation. One such provision for development to minimize the risk of structural loss and life shall be the inclusion of overhead fire sprinklers.
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o Policy S-3.2: Provide sufficient level of fire protection service to reduce risk from urban and wildland fire. Advocate and support regional coordination among fire protection and emergency service providers.
o Policy S-3.3: Require development to provide additional access roads when necessary to provide for safe access of emergency equipment and civilian evacuation concurrently. o Policy S-3.4: Coordinate with fire protection and emergency service providers to assess fire hazards before and after wildfire events to adjust fire prevention and suppress ion needs, as necessary, commensurate with both short - and long -term fire prevention needs.
• Goal S-4: Protect life, structures, and the environment from the harmful effects of hazardous materials and waste.
o Policy S -4.1: Promote and support the proper disp osal, handling, transport, delivery, treatment, recovery, recycling, and storage of hazardous materials in accordance with applicable federal, State, and local regulations.
o Policy S-4.2: Require areas of known or suspected contamination to be assessed prior to reuse or redevelopment. Plan for reuse of contaminated areas in a manner that is compatible with the nature of the contamination and subsequent remediation efforts. o Policy S-4.3: Require that land uses using hazardous materials be located and designed to ensure sensitive uses, such as schools, hospitals, day care centers, and residential neighborhoods, are protected.
o Policy S-4.4: Avoid locating sensitive uses near established hazardous materials users or industrial areas where incompatibilities would result, except in cases where appropriate safeguards have been developed and implemented.
• Goal S -5: Establish and maintain an effective emergency response program to respond to disasters and maintain continuity-of-life support functions during an emergency. o Policy S -5.3: Develop, implement, and maintain an effective evacuation program for areas of risk in the event of a disaster.
• Goal S-7: Comply with the McClellan-Palomar Airport Land Use Compatibility Plan. o Policy S-7.1: Record an overflight notification document in association with the approval of any new residential land use within the AIA overflight notification area consistent with the ALUCP.
The project’s consistency with applicable General Plan goals and policies is discussed in Section
3.10, Land Use and Planning. The Safety Element also identifies goals and policies related to seismic, flood, and fire hazards. As detailed in Table 3.10 -5 of Section 3.10, the project is consistent with all the applicable goals and policies.
3.8.3 Thresholds of Significance
Based on the California Environmental Quality Act (CEQA) Guidelines Appendix G (VII), the following significance criteria have been developed for hazardous materials compliance. A significant impact to or resulting from hazards and hazardous mater ials would be identified if the project was determined to result in any of the following:
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• Threshold #1: Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials; • Threshold #2: Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment;
• Threshold #3: Emit hazardous emissions or handle hazardous or acutely ha zardous materials, substances, or waste within one-quarter mile of an existing or proposed school. • Threshold #4: Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a re sult, would it create a significant hazard to the public or the environment;
• Threshold #5: For a project located within an airport land use plan, or, where such a plan has not been adopted, within two miles or a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area; • Threshold #6: Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan; or
• Threshold #7: Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands.
3.8.4 Project Impact Analysis
The following analysis discusses impacts associated with the thresholds of significance identified in Section 3.8.3, Thresholds of Significance, above.
Hazardous materials include solids, liquids, or gaseous materials that, because of their quantity, concentration, or physical, chemical, or infectious characteristics, could pose a threat to human health or the environment. Hazards with all existing development include the risks associated with potential explosions, fires, or release of hazardous substances in the event of an accident or natural disaster, which may cause or contribute to an increase in mortality or serious illness, or pose substantial harm to human health or the environment.
Threshold #1: Create a significant hazard to the public or the environment through the rout ine transport, use, or disposal of hazardous materials.
During construction of the proposed project, there is a potential for accidental upset of fuels, lubricants, or various other liquids needed to operate heavy equipment on the project site. These materials include diesel fuel, gasoline, equipment fluids, concrete, cleaning solutions and solvents, lubricant oils, adhesives, human waste, and chemical toilets. Direct impacts to human health and biological resources from accidental spills of small amounts o f hazardous materials from construction equipment during construction of the buildings could occur in case of accidental spill or upset; however, existing federal and state standards are in place for the handling, storage, and transport of these materials. These include, but are not limited to, the Federal Chemical Accident Prevention Provisions (Part 68 of the Code of Federal Regulations), California Highway Patrol and California Department of Transportation container and licensing requirements for transportation of hazardous waste on public roads, the International Fire Code, The Resource Conservation and Recovery Act of 1976 as amended by the Hazardous and Solid Waste Amendments of 1984,
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California’s Hazardous Waste Control Law, the California Fire Code, California Health and Safety Code Hazardous Materials Release Response Plans and Inventory, the California Integrated Waste Management Act, regulations developed by California Occupations Safety and Health Administration, and the state Hazardous Waste Control Act.
Further, per the Phase II ESA performed for the project, contaminated soils, OCPs and arsenic were not detected at concentrations exceeding the laboratory detection limits in the soil samples.
GEOCON concluded that further investigation of impacts to the site from the historical agricultural use of the site is not warranted at this time (GEOCON 2020).
Operationally, the only hazardous materials anticipated for transport, use, or disposal associated with the proposed residential project w ould be routinely used household products such as cleaners, paint, solvents, motor oil/automotive products, batteries, and garden maintenance products. The use, handling, and disposal of these products is addressed by household hazardous waste programs that are part of the Integrated Waste Management Plan (IWMP) of the County of San Diego. The Household Hazardous Waste Element of the IWMP specifies the means by which hazardous wastes generated by households shall be collected, recycled, treated, and disposed of safely.
Because compliance with all standards is required through federal, state, county, and municipal regulations, no significant impacts to the public or the environment are expected due to the routine transport, use, or disposal of hazardous materials during project construction or operation.
Therefore, proposed project impacts would be
less than significant.
Threshold #2: Create a significant hazard to the public or the environment through reasonabl y foreseeable upset and accident conditions involving the release of hazardous materials into the environment.
As discussed under Threshold 1, above, construction of the proposed project would entail transport, use, or disposal of potentially hazardous mate rials including, but not limited to diesel fuel, gasoline, equipment fluids, concrete, cleaning solutions and solvents, lubricant oils, adhesives, human waste, and chemical toilets. Further, as discussed above, no contaminated soils, OCPs or arsenic were detected in select soil samples during the Phase II ESA. As such, although the use, transport, and disposal of hazardous materials during construction could result in accidental spill or upset, the proposed project would be required to comply with existing environmental regulations that would ensure that the public and environment are protected.
Future uses proposed within the project area are limited to multi- family residences and recreation/open space uses. These types of land uses are not typically chara cteristic of generating, releasing, or using large amounts of hazardous materials. Industrial uses are not proposed as part of the proposed project. The only hazardous materials anticipated for transport, use, or disposal associated with the completed proj ect are routinely used household products such as cleaners, paint, solvents, motor oil/automotive products, batteries, and garden maintenance products. As stated above, the use, handling, and disposal of these products are addressed by household hazardous waste programs that are part of the IWMP of the County of San Diego.
Because compliance with all standards is required through federal, state, county, and municipal regulations, no significant impacts to the public or the environment are expected due to th e release of hazardous materials. Therefore, the proposed project is not anticipated to create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Impacts are less than
significant.
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Threshold #3: Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.
The project site is not locat ed within a one -quarter mile of an existing or proposed school . The closest school to the project site is Mission Hills High School, which is located 0.35 mile north of the project site, with SR -78 and additional development between the project site and th e school .
Additionally, the uses proposed by the project would not be characterized as those that would emit hazardous emissions or handle hazardous or acutely hazardous materials or substances. No schools are located within 0.25 miles of the project site. No impact is identified for this issue area.
Threshold #4: Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment.
As part of the Phase 1 ESA prepared for the proposed project, a database search report was obtained from Environmental Data Resources, Inc., which documents various federal, state, and local regulatory database searches regarding pr operties with known or suspected releases of hazardous materials, chemical handlers, and/or polluters. The findings of the Phase I ESA concluded that the proposed project site is not located on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5.
There are 19 properties identified in the database search within 1/8 -mile (or ¼-mile for LUST facilities) of the project site. All 19 listings are related to handling and disposal of hazardous waste.
Per the Phase I ESA,” release ” refers to an unauthorized release of a petroleum product or hazardous substance to the environment - i.e., the ground surface, soil, soil vapor, groundwater, or surface water on a property. "Release -related database" refers to those which provide informa tion regarding an unauthorized release. "Non -release-related database" refers to those that may report use, storage, or disposal of hazardous substances and/or petroleum products or other environmental conditions, but do not report releases of such . None of the facilities were included in release-related databases and are located down or cross gradient to the project stie . Therefore, GEOCON concluded that the facilities are unlikely to have caused a REC at the project site (G EOCON 2020).
Aerial photographs, topographic maps, and previous reports of the project site were reviewed for evidence of past land uses that had the potential to have impacted the project site through the use, storage, or disposal of hazardous substances and/or petroleum pro ducts. Per the Phase I ESA, the project site had been used for agricultural use between 1939 up until approximately 1970 suggesting that pesticides may have been used on the site. If so, persistent pesticides and associated metals (arsenic) may be present in soil. Given the planned residential redevelopment of the site , GEOCON performed a Phase II ESA to assess the potential presence of organochlorine pesticides (OCPs) and arsenic in soil related to the former agricultural use of the project site. Per the Phase II ESA , contaminated soils, OCPs and arsenic were not detected at concentrations exceeding the laboratory detection limits in the soil samples. GEOCON concluded that further investigation of impacts to the site from the historical agricultural use of the site is not warranted at this time (GEOCON 2020).
The site reconnaissance confirmed that no obvious indications of the use, storage, or generation of hazardous materials/wastes or petroleum products were observed on or adjacent to the project site.
The Phase I and Phase II ESA prepared for the proposed project concluded there is a low likelihood that recognized environmental conditions are present at the project site as a result of the current or
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historical land uses or from a known and reported off -site source. Therefore, the proposed project is not located on a site that is included on a list of hazardous materials sites. Impacts are less than significant.
Threshold #5: For a project located within an airport land use plan, or, where such a plan has no t been adopted, within two miles or a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area.
The public airport closest to the project site is the McClellan -Palomar Airport, located approximately
7.5 miles to the west. According to Figure 6 -5 of the Safety Element of the City’s General Plan, the project site is located within of Review Area 2 of the airport influence area . Review Area 2 limits the heights of structures in areas o f high terrain. The project site would not be characterized as an area of high terrain, defined as a maximum height of 795 feet amsl or as in an area of Terrain Penetration to Airspace Surfaces. Area of higher elevation on the site are located to the north and west of the site. Site elevations range from approximately 650 to 750 feet above mean sea level. Proposed building would be a maximum of 40 feet high (three stories). The project site is outside of the 60 dBA noise contour generated by airport noise a s illustrated in the ALUCP. Nevertheless, Nevertheless, all residential development within Review Area 2 is required to record overflight notification documents as outlined in the McClellan -Palomar ALUCP and per Chapter 20.265 of the City’s Municipal Code, notifying residents of potential annoyances commonly associated with proximity to airports, such as noise, vibration, and overflights. This would be required as a condition of project approval. As such, with recording of overflight notification, impacts would be less than significant.
Threshold #6: Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.
According to the General Plan Safety Element, the San Marcos Emergency Operations Plan gover ns the operations of the City during a disaster. This plan addresses response to moderate evacuation scenarios, including the identification of evacuation points and general routes . While specific evacuation routes have not been established, several main thoroughfares would serve as primary evacuation corridors in an emergency. Additionally, San Marcos is included in the San Diego County Multi-Jurisdictional Hazard Mitigation Plan, which was developed to serve as both a county -wide plan and a plan for local jurisdictions to identify risks posed by natural and human -caused disasters before a hazardous event occurs.
Access to the project site will be via two unsignalized driveways on E. Barham Drive. The western driveway will be 40 -feet wide and serve as the primary entry to the project site and provide full access. The eastern driveway will be 26 -feet wide and will also provide full access . Based upon mitigation measures identified in Section 3.10, Land Use (MM-LU-2 and MM-LU-3), the project will be required to limit left turns out of both driveways between the PM Peak Hour (4:00 PM to 6:00 PM).
A secondary emergency -only access is provided through the western boundary of the project site at the western terminus of Street “C”. This access will connect to an existing emergency access driveway on the adjacent property which connects to Saddleback Way and then to E. Barham Drive.
This access point is for emergency vehicles only and bollards would be put in place The proposed project would not impact any roadway or staging areas that are identified in any emergency planning documents. In summary, the proposed project would not impair implementation of or physically interfere with an adopted eme rgency response plan or emergency evacuation plan.
Impacts would be
less than significant.
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Threshold #7: Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanize d areas or where residences are intermixed with wildlands.
Implementation of the proposed project would result in a developed area with roads, structures, and landscape vegetation as well as maintained parks and open spaces . The project site is located in a Local Responsibility Area with a Non -Very High Fire Hazard Severity Zone (Non -VHFHSZ) designation per CalFire’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as a Non -VHFHSZ. Further, per Figure 6 -4 of the City’s General Plan, the project site and surrounding area are not identified as a SMFPD Community Hazard Zone. The project includes a 150-foot onsite fuel modification buffer along the southern portion of the project site to further minimize fire risk to the pr oposed development. Per the Fire Marshal, offsite fire fuel modification is not required for the project. Impacts would be
less than significant.
3.8.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, r egional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to hazards, the cumulative analysis is based upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts related to hazards. All of the cumulative projects identified in Table 2 -3 are considered in this cumulative analysis.
Hazards impacts are generally site specific and thus handled on a site -by-site basis. All projects identified in Table 2 -3 would require the identification of existing hazardous materials on site, and would be required to comply with existing regulations related to use, transport, and disposal of hazardous materials. Similarly, all related projects would be required to analyze and properly mitigate any impacts to the existing evacuation plan, if impacts are identified.
With regard to wildfire hazards, all of the projects proposed within the urban/wildland interface are required to meet minimum fire fuel modification and/or clearing requirements in addition to meeting the applicable standards of the various fire codes in effect at the time of building permit issuance.
Currently that is the 2019 Consolidated Fire Code, 2019 California Building Code, San Diego County requirements for Enhanced Building Construction and California State Fire Marshal requirements for fire resistive construction. For projects within the City, these requirements are i mplemented through preparation of and compliance with a Fire Protection Plan, other project -specific design features, which are reviewed and approved by the Fire Marshal. As such, through compliance with existing regulations, cumulative impacts to hazards and hazardous materials would be less than significant.
3.8.6 Mitigation Measures
Based upon the analysis presented in Section 3. 8.4 and 3. 8.5, no impacts were identified and no mitigation measures are required.
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3.8.7 Conclusion
As discussed in Section 3.8.4, above, the project site is currently vacant and is not listed on any hazardous materials sites. Furthermore, construction and operation of the proposed project is not expected to result in the release of any significant hazard ous materials or the routine transport, use, or disposal of such materials. Development of the proposed project would not result in any safety hazards resulting from proximity to the McClellan -Palomar Airport, however, the project site is located within Re view Area 2 of the McClellan -Palomar airport influence area and, although not significant, future residents on the project site may be subject to periodic nuisance from aviation activity including noise, vibration, and overflights. Recordation of overfligh t notification documents that detail the potential disturbances that may be experienced for future homeowners would be required pursuant to the City’s Municipal Code. Further the project would not impair implementation of or physically interfere with emerg ency response or evacuation plans . Lastly, the project site is not designated as a high fire severity zone, and the project would be constructed in accordance with all applicable fire codes. As such, project - level and cumulative -level impacts due to hazar ds and hazardous materials would be
less than significant.
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3.9 Hydrology and Water Quality
Introduction
This section identifies the existing hydrologic and water quality conditions on the project site and analyzes the potential impacts of the proposed project on hydrology and water quality. The analysis in this section is based upon the following reports which are included as Appendix J.1 and J.2 of this document:11:
• Preliminary Drainage Report 943 Bar ham Drive, prepared by SB&O, June 15, 2020 (SB&O 2020a)
• Priority Development Project Stormwater Quality Management Plan (SWQMP) prepared by SB&O, June 19, 2020 (SB&O 2020b).
The preliminary drainage report and SWQMP discusses applicable hydrologic volume and storm water requirements and analyzes peak flow anticipated for preliminary design of the on -site storm drain system. The analysis in this section also considers the California Environmental Quality Act (CEQA) Guidelines Appendix G and applicable State and Local regulations, including the City of San Marcos General Plan.
In the Initial Study prepared for the proposed project ( Appendix B.1 ), the proposed project was determined to have no impact on the fol lowing hydrology/water quality -related issue area: risk release of pollutants due to project inundation in flood hazard, tsunami or seiche zones. Therefore, this issue is not discussed further in this EIR section.
Table 3.9 -1 summarizes the project - and cu mulative-level hydrology and water quality impact analysis by threshold.
Table 3.9-1. Hydrology/Water Quality Summary of Impacts Threshold of Significance Project-Level
Impact
Cumulative-
Level Impact
Impact After
Mitigation
#1: Violate any water quality standards or
waste discharge requirements or other
substantially degrade surface or groundwater
quality?
Less than
Significant
Less than
Significant
Less than
Significant
#2: Substantially deplete groundwater
supplies or interfere substantially with
groundwater recharge such that the project
may impede sustainable groundwater
management of the basin?
Less than
Significant
Less than
Significant
Less than
Significant
11 Full references for documents cited in this section are included in Chapter 7, References, of this EIR.
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Threshold of Significance Project-Level
Impact
Cumulative-
Level Impact
Impact After
Mitigation
#3: Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or river
or through the addition of impervious surfaces,
in a manner which would: result in substantial
erosion or siltation on- or off-site?
Less than
Significant
Less than
Significant
Less than
Significant
#4: 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: substantially
increase the rate or amount of surface runoff
in a manner which would result in flooding on-
or off-site?
Less than
Significant
Less than
Significant
Less than
Significant
#5: 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: create or contribute
to runoff water which would exceed the
capacity of existing or planned stormwater
drainage systems or provide substantial
additional sources of polluted runoff?
Less than
Significant
Less than
Significant
Less than
Significant
#6: 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: impede or redirect
flood flows?
Less than
Significant
Less than
Significant
Less than
Significant
#7: Conflict with or obstruct implementation of
a water quality control plan or sustainable
groundwater management plan?
Less than
Significant
Less than
Significant
Less than
Significant
#8: Result in significant alteration of receiving
water quality during or following construction?
Less than
Significant
Less than
Significant
Less than
Significant
#9: Result in an increase in pollutant
discharges to receiving waters? Consider
water quality parameters such as temperature,
dissolved oxygen, turbidity, and other typical
storm water pollutants (e.g., heavy metals,
pathogens, petroleum derivatives, synthetic
organics, sediment, nutrients, oxygen-
demanding substances, and trash).
Less than
Significant
Less than
Significant
Less than
Significant
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Threshold of Significance Project-Level
Impact
Cumulative-
Level Impact
Impact After
Mitigation
#10: Be tributary to an already impaired water
body as listed on the Clean Water Act Section
303(d) list? If so, can it result in an increase in
any pollutant for which the water body is
already impaired?
Less than
Significant
Less than
Significant
Less than
Significant
#11: Be tributary to environmentally sensitive
areas (e.g., MSCP, RARE, Areas of Special
Biological Significance, etc.)? If so, can it
exacerbate already existing sensitive
conditions?
Less than
Significant
Less than
Significant
Less than
Significant
#12: Have a potentially significant
environmental impact on surface water
quality, to either marine, fresh or wetland
waters?
Less than
Significant
Less than
Significant
Less than
Significant
3.9.1 Existing Conditions
This section details the existing hydrology, water quality and groundwater conditions on the project site.
Site Hydrology
The project site is currently vacant and includes a hillside along the southern limits. Per the drainage report, existing drainage is “natural” and generally overland toward the E. Barham Drive frontage (SB&O 2020a). Drainage patterns are generally southeast to northwest and includes run-on from the hillside above the site . The majority of site runoff is directed overland to the Barham gutter. A small depression is near the northwest corner of the site. A storm drain riser is located near t he northeast corner of the site and is connected to the public storm drain in Barham Drive.
Water Quality
The proposed project is located within the jurisdiction of the San Diego Regional Water Quality Control Board (RWQCB). The San Diego Region is divided into eleven hydrologic units. The project site is located in the Batiquitos Subarea (904.51) within the San Marcos Hydrologic Area (904.5) of the Carlsbad Watershed (Hydrologic Unit (904). The project site discharges to the Barham Drive Storm Drain (MS -4), which discharges to San Marcos Creek (passing through Lake San Marcos) to Batiquitos Lagoon (inner), which discharges to the Pacific Ocean.
The Carlsbad Watershed Management Area (WMA) is approximately 211 square miles and is formed by a group of six in dividual watersheds in northern San Diego County. The WMA is bordered by the San Luis Rey River WMA to the north and by the San Dieguito River WMA to the south. It reaches inland nearly 24 miles to just northeast of Lake Wohlford. The maximum elevation of the WMA is approximately 2,400 feet and it extends to sea level at the Pacific Ocean. The Carlsbad WMA is made up of six distinct Hydrologic Areas (HA)s: Loma Alta, Buena Vista Creek, Agua Hedionda, Encinas, San Marcos Creek, and Escondido Creek. The WMA includes the entire Cities of Carlsbad,
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San Marcos and Encinitas and portions of the cities of Oceanside, Vista, Escondido, Solana Beach, and San Diego County unincorporated areas.
The San Marcos Hydrologic Area is the second largest within the WMA. It is a bout 36,000 acres in area and comprises approximately 28% of the Carlsbad WMA. The major receiving waters within the Hydrologic Area are San Marcos Creek, Encinitas Creek, Batiquitos Lagoon, and the Pacific Ocean.
San Marcos Creek originates on the western slopes of the Merriam Mountains in west central San Diego County and discharges in to the Pacific Ocean, 14.6 miles away, via Batiquitos Lagoon.
Encinitas Creek is another one of the major tributaries in the HA, originating in the hills southwest of Questhaven Road and paralleling El Camino Real before it converges with San Marcos Creek at the southeastern corner of Batiquitos Lagoon. The highest elevation within the HA is approximately 1,540 feet above mean sea level (amsl). Lake San Marcos is the largest impoundment within the HA.
The San Marcos HA is primarily located in the cities of San Marcos, Carlsbad, Encinitas, and the County of San Diego, with a small portion in Escondido.
The San Marcos HA has two distinctive areas separated by the Lake San Marcos impoundment – the Upper and Lower San Marcos HA areas. The Upper Hydrologic Area includes drainage areas in the County of San Diego, and the cities of San Marcos and Escondido, that runoff through Upper San Marcos Creek to Lake San Marcos. The Lower Hydr ologic Area consists of portions of the cities of Carlsbad, Encinitas, San Marcos, and Vista (Carlsbad Watershed Management Area 2018).
Within the Water Quality Control Plan for the San Diego Basin (San Diego Basin Plan), San Marcos Creek and Batiqu itos Lagoon, located downstream of the project site, are identified as having numerous beneficial uses. For San Marcos Creek, these beneficial uses are: Agricultural Supply (AGR), Contact Water Recreation ( REC1), Non-Contact Water Recreation ( REC2), Warm Freshwater Habitat ( WARM) and Wildlife Habitat (WILD) . For Batiquitos Lagoon , these uses are: REC1, REC2, Preservation of Biological Habitats of Special Significance (BIOL), Estuarine Habitat (EST), WILD, Rare, Threatened, or Endangered Species (RARE), Marine Habitat (MAR), Migration of Aquatic Organisms (MIGR), and Spawning, Reproduction, and/or Early Development (SPWN). The Basin Plan includes numerical and qualitative water quality objectives to protect the listed beneficial uses for each water body.
The San Marcos Creek system consists of a number of water bodies that are listed as impaired under Section 303(d) of the Clean Water Act. In accordance with Section 303(d) of the 1972 Federal Clean Water Act (CWA), the State Water Resources Control B oard (SWRCB) has established a list of “impaired water bodies.” San Marcos Creek is listed on the 201 4-2016 CWA Section 303(d) List of Impaired Water Segments as being impaired for dichlorodiphenyldichloroethylene ( DDE), phosphorus, sediment, toxicity, and selenium. Further downstream, Batiquitos Lagoon is also listed as impaired. Batiquitos Lagoon is listed as being impaired for eutrophic, indicator bacteria, sediment, siltation, and toxicity. Furthermore, San Marcos Lake was identified under Section 303(d ) of the Clean Water Act as impaired due to high concentrations of nitrogen and nutrients.
3.9.2 Regulatory Setting
This section details the applicable federal, state, and local regulations pertaining to hydrology and water quality.
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Federal
Federal Emergency Management Agency
The Federal Emergency Management Agency (FEMA) administers the National Flood Insurance Program to provide subsidized flood insurance to communities that comply with FEMA regulations limiting development in floodplains. FEMA also issues Flood Insurance Rate Maps that identify which land areas are subject to flooding. These maps provide flood information and identify flood hazard zones in the community. The standard for flood protection is established by FEMA, with the minimum level of flood p rotection for new development determined to be the one percent -annual exceedance probability (i.e., the 100 -year flood event). Per FEMA’s Flood Insurance Rate Map Number 06073C0794G, the project site is not located within a 100-year flood hazard area (FEMA 2012) Federal Clean Water Act
The Clean Water Act (CWA) establishes the basic structure for regulating discharges of pollutants into the waters of the U.S. and regulating quality standards for surface waters. The basis of the CWA was enacted in 1948 and was called the Federal Water Pollution Control Act, but the Act was significantly reorganized and expanded in 1972. “Clean Water Act” became the Act’s common name with amendments in 1977.
Under the CWA, the U.S. Environmental Protection Agency (USEPA) has i mplemented pollution control programs such as setting wastewater discharge standards for industry. The USEPA has also set water quality standards for contaminants in surface waters. The CWA made it unlawful to discharge any pollutant from a point source into navigable waters, unless a permit was obtained.
Section 303(d) of the Clean Water Act
Under Section 303(d) of the C WA, states are required to develop lists of water bodies that would not attain water quality objectives after implementation of required levels of treatment by point -source dischargers (municipalities and industries). Section 303(d) requires that the state d evelop a total maximum daily load (TMDL) for each of the listed pollutants. The TMDL is the amount of loading that the water body can receive and still be in compliance with water quality objectives. The TMDL can also act as a plan to reduce loading of a s pecific pollutant from various sources to achieve compliance with water quality objectives. The TMDL prepared by the state must include an allocation of allowable loadings to point and non -point sources, with consideration of background loadings and a margin of safety. The TMDL must also include an analysis that shows the linkage between loading reductions and the attainment of water quality objectives. The federal Environmental Protection Agency (EPA) must either approve a TMDL prepared by the state or, if it disapproves the state’s TMDL, issue its own. National Pollutant Discharge Elimination System (NPDES) permit limits for listed pollutants must be consistent with the waste load allocation prescribed in the TMDL. After implementation of the TMDL, it is a nticipated that the problems that led to placement of a given pollutant on the Section 303(d) list would be remediated.
National Pollutant Discharge Elimination System
The National Pollutant Discharge Elimination System (NPDES) permit system was establishe d in the federal CWA to regulate municipal and industrial discharges to surface waters of the U.S. Sections 401 and 402 of the CWA contain general requirements regarding NPDES permits. Section 307 of the CWA describes the factors that the federal EPA must consider in setting effluent limits for priority pollutants.
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Non-point sources are diffuse and originate from a wide area rather than from a definable point.
Non-point pollution often enters receiving waters in the form of surface runoff, but is not conveyed by way of pipelines or discrete conveyances. As defined in the federal regulations, such non -point sources are generally exempt from federal NPDES permit program requirements. However, three types of non -point source discharges are controlled by the NPDES program: non -point source discharge caused by general construction activities, the general quality of stormwater in municipal stormwater systems, and discharges associated with industrial operations. The 1987 amendments to the CWA directed the federal E PA to implement the stormwater program in two phases. Phase I addressed discharges from large (population 250,000 or above) and medium (population 100,000 to 250,000) municipalities and certain industrial activities. Phase II addresses all other discharges defined by the EPA that are not included in Phase I.
In accordance with NPDES regulations, in order to minimize the potential effects of construction runoff on receiving water quality, the State requires that any construction activity that disturbs one acre or more must obtain a General Construction Activity Stormwater Permit. Permit applicants are required to prepare a stormwater pollution prevention plan (SWPPP) and implement Best Management Practices (BMPs), such as erosion and sediment control and non -stormwater management measures, to reduce construction effects on receiving water quality.
Examples of typical BMPs implemented in SWPPPs include using temporary mulching, seeding, or other suitable stabilization measures to protect uncovered soils; storin g materials and equipment to ensure that spills or leaks cannot enter the storm drain system or surface water; developing and implementing a spill prevention and cleanup plan; installing traps, filters, or other devices at drop inlets to prevent contaminants from entering storm drains; and using barriers, such as straw bales or plastic, to minimize the amount of uncontrolled runoff that could enter drains or surface water.
State
California Water Code Division 7 (Porter-Cologne Act)
The California Water Code contains provisions regulating water and its use. Division 7 establishes a program to protect water quality and beneficial uses of the state water resources including groundwater and surface water. The SWRCB and R WQCB administer the program and are responsible for control and water quality. They establish waste discharge requirements, oversee water quality control planning and monitoring, enforce discharge permits, and establish ground and surface water quality objectives.
State Water Resources Control Board
In California, the SWRCB has broad authority over water -quality control issues for the State. The SWRCB is responsible for developing statewide water quality policy and exercises the powers delegated to the State by the Federal government under the CWA. Other State agencies with jurisdiction over water quality regulation in California include California Department of Public Health (for drinking water regulations), the California Department of Pesticide Regulation, the California Department of Fish an d Wildlife (CDFW), and the Office of Environmental Health and Hazard Assessment.
In accordance with Section 303(d) of the CWA, the State Water Resources Control Board (SWRCB) has established a list of “impaired water bodies.” Impaired water bodies in this watershed, as listed in the SWRCB 303(d) impaired waters list, include San Marcos Creek. San Marcos Creek is listed on
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the 2014 -2016 CWA Section 303(d) List of Impaired Water Segments as being impaired for DDE, phosphorus, sediment, toxicity, and selenium.
Regional Water Quality Control Board
The project site is situated within the jurisdiction of the San Diego RWQCB (Region 9). The San Diego RWQCB has the authority to implement water quality protection standards through the issuance of permits for discharges to waters at locations within its jurisdiction.
The project site is located within the Batiquitos Subarea (904.51) of the San Marcos Hydrologic Area (904.5) of the Carlsbad Watershed Hydrologic Unit (904). Water quality objectives for San Marcos Creek and Batiquitos Lagoon are specified in the Water Quality Control Plan for the San Diego Basin (Basin Plan) prepared by the RWQCB in compliance with the federal CWA and the Porter -Cologne Act.
The Basin Plan establishes water quality objectives and implement ation programs to meet stated objectives and to protect the beneficial uses of water in the lagoon and creek. Because the City of San Marcos is located within the RWQCB’s jurisdiction, all discharges to surface water or groundwater are subject to the Basin Plan requirements (RWQCB 1994).
In May 2013, the San Diego RWQCB adopted Order R9 -2013-0001, the new municipal NPDES permit for 39 municipal, county government, and special district entities located in southern Orange County, southwestern Riverside County, and San Diego County who own and operate large municipal separate storm sewer systems (MS4s) which discharge storm water runoff and non -storm water runoff to surface waters throughout the San Diego Region. This permit has requirements for development projects to minimize or eliminate the impacts of such development on water quality.
The proposed project is subject to the requirements of the municipal permit as it is implemented via the Carlsbad Watershed Jurisdictional Urban Runoff Management Program. The specific requirements include the selection of appropriate BMPs to avoid, prevent, or reduce the pollutant loads entering the storm drain system and receiving waters. The permit was amended in February 2015 by Order R9-2015-0001 and in November 2015 by Order R9-2015-0100.
Provision D.1.a of Order R9 -2013-0001 requires the San Diego Stormwater Co -permittees to continue water monitoring programs established within previous Orders and pursuant to the approved Hydromodification Management Plan (HMP) (January 2011). The City of San Marcos is one of the co-permittees.
To comply with Order R9 -2013-0001, as amended, the updated September 2020 County of San Diego BMP Design Manual was developed to provide County -specific project design and post - construction storm wa ter requirements for development projects and replace the prior San Diego Regional Model Standard Urban Stormwater Mitigation Plan (SUSMP). The City of San Marcos has adopted its own BMP Design Manual as of February 2016. The BMP Design Manual was used to recommend BMPs and low impact development (LID) features for the proposed project. LID is an approach to land development that uses multiple small -scale natural detention and filtration features to manage stormwater as close to its source as possible. LID employs principles such as preserving and re-creating natural landscape features, minimizing effective imperviousness to create functional and appealing site drainage that treats stormwater as a resource rather than a waste product.
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Local
Carlsbad Watershed Management Area Water Quality Improvement Plan The Carlsbad Watershed Management Area (WMA) Water Quality Improvement Plan (WQIP) is a requirement of stormwater regulations adopted by the R WQCB according to Order No. R9 -2013- 0001, as amended by Order Nos . R9 2015 -0001 and R9 -2015-0100. The goal of the WQIP is to protect, preserve, enhance, and restore water quality of receiving water bodies. These improvements in water quality will be accomplished through an adaptive planning and management process that identifies the highest priority water quality conditions within the watershed and implements strategies to address them. Agencies involved in the development of the WQIP include the County of San Diego and the cities of Carlsbad, Encinitas, Escondido, Ocean side, San Marcos, Solana Beach, and Vista. The purpose of the Carlsbad WMA WQIP is to guide the Responsible Agencies’ Jurisdictional Runoff Management Programs (JRMP)s toward achieving improved water quality in MS4 discharges and receiving waters. Through the WQIP, priorities and goals are established and strategies selected for implementation through the Responsible Agencies’ JRMPs to progress toward improvements in water quality. This approach establishes the WQIP as the overarching plan that each Respons ible Agency will use to develop and implement their jurisdictional programs.
Responsible Parties’ JRMPs contain the strategies, standards, and protocols by which each Responsible Agency will implement their individual program in response to the priorities and goals established in the WQIP. The WMA collective watershed strategy identifies nutrients as high priority water quality pollutants in the San Marcos Creek Hydrologic Area ( Carlsbad Watershed Management Area Responsible Agencies 2018).
The Carlsbad WMA WQIP includes several major components:
• Priority Water Quality Conditions: after assessing available data sets, the water quality conditions in the watershed were prioritized and several were identified as those on which Responsible Agencies would focus their program efforts. These are identified as highest and priority water quality conditions. This does not mean that other water quality conditions or pollutants are to be ignored. To the contrary, many water quality conditions are related to one another in terms of the strategies selected to address them. Selected strategies to address priority water quality conditions are also effective at addressing many other pollutants and water quality conditions. The highest priority water quality condition for Escondido Creek and San Elijo Lagoon are indicator bacteria.
• Numeric Goals and Schedules: the WQIP establishes goals related to the highest priority water quality conditions. Furthermore, schedules for achieving these goals are included in the WQIP. Together, the goals and schedules establish the targets that the Responsible Agencies use for both establishing their programs as well as measuring p rogress and achievement. Each highest priority water quality condition has established interim and final goals and schedules.
• Strategies and Schedules: the WQIP identifies the strategies, or activities/BMPs, that the Responsible Agencies will implement to address the priority water quality conditions to progress towards achieving the numeric goals within the schedules identified. In addition to identifying the strategies, the WQIP identifies schedules for development (in some cases) and implementation of the strategies.
The Carlsbad WQIP was originally submitted to the R WQCB in June 2015 and after revisions based on RWQCB comments, an acceptance letter from the Regional Board was issued on November 22,
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2016. A 2021 update has been initiated, primarily to incorporate an assessment of bacteria data for Agua Hedionda Lagoon and revisions noted in prior Annual Reports. The 2021 WQIP was submitted to the Regional Board in January 2021 and the Responsible Agencies are awaiting acceptance of the document.
City of San Marcos Jurisdictional Runoff Management Plan The Order (NPDES Permit CAS0109266) requires the City of San Marcos to develop and implement a Jurisdictional Runoff Management Plan (JRMP) that identifies and describes the methods that the City will use to e liminate significant pollutants from the City’s Storm Water Conveyance System. The purpose of the City’s JRMP is to implement strategies that effectively prohibit non -stormwater discharges to the MS4 and reduce the discharge of pollutants in stormwater to the maximum extent practicable (MEP). Improving the quality of the discharge from the MS4 should have beneficial effects on the local receiving water bodies (City of San Marcos 2017).
San Marcos Storm Water Standards
The City has adopted its own BMP Design Manual as of February 2016 and the proposed project must comply with the standards and regulations contained therein.
San Marcos General Plan
Conservation and Open Space Element
The following are applicable goals and policies from the City of San Marcos G eneral, Conservation and Open Space Element related to hydrology and water quality:
• Goal COS-6: Protect and restore appropriate surface water and groundwater beneficial uses through prioritizing the improvement of locally impaired water bodies within the City of San Marcos subwatersheds.
o Policy COS-6.2: Promote watershed stewardship as the community norm. • Goal COS-7: Achieve sustainable watershed protection for surface and ground water quality that balances social, economical, and environmental needs. • Goal COS -8: Require new development and redevelopment to protect the quality of water bodies and natural drainage systems through site design, source controls, storm water treatment, runoff reduction measures, BMPs, LID, hydromodification strategies consis tent with the Current San Diego RWQCB Municipal Stormwater NPDES Permit, and all future municipal stormwater permits.
o Policy COS -8.4: Require new development and redevelopment to protect the quality of water bodies and natural drainage systems through site design, source controls, storm water treatment, runoff reduction measures, BMPs, LID, hydromodification strategies consistent with the Current San Diego RWQCB Municipal Stormwater NPDES Permit, and all future municipal stormwater permits.
Safety Element
The following goal and policy in the City of San Marcos General Plan, Safety Element are applicable to flooding and flood control:
• Goal S-2: Minimize the risk to people, property, and the environment due to flooding hazards.
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o Policy S-2.2: Require existing private development to take responsibility for maintenance and repair of structures to resist flood damage.
Land Use and Community Design Element
The following goal and policies in the City of San Marcos General Plan, Land Use and Community Design Element are applicable to storm water drainage facilities:
• Goal LU-15: Flood control and storm water drainage facilities: ensure adequate flood control and storm water drainage is provided by the community.
o Policy LU -15.1: Implement activities, practices, procedures, or facilities that avoid, prevent, or reduce pollution of the San Marcos Storm Water Conveyance System and receiving waters.
o Policy LU -15.2: Improve inadequate or undersized drainage/flood control facilities to solve both small neighborhood and large regional drainage and flood control problems. o Policy LU-15.3: Avoid, to the extent possible, development in floodplain and flood prone areas.
o Policy LU-15.4: Retain drainage courses in their natural condition, to the extent possible.
Consider smalle r-scale drainage improvements to protect the environment and avoid disturbing natural drainage courses; consider detention areas and raised building pads.
The proposed project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10, Land Use and Planning. As detailed in Table 3.10 -1 in Section 3.10, the project is consistent with the applicable goals and policies.
City of San Marcos Ordinances
The Storm Water Management and Discharge Control Ordinance (San Marcos Municipal Code Chapter 14.15) requires that all new development and redevelopment activities comply with the stormwater pollution prevention requirements. These stormwater pollution prevention requirements, which are described in detail in Section 14.15.050 of the Municipal Code “Reduction of Pollutants in Storm Water,” include construction, development and redevelopment, and residential BMPs.
3.9.3 Thresholds of Significance
Appendix G of the California Environmental Quality Act (CEQA) Guidelines provides thresholds for determining significant environmental impacts related to hydrology and water quality. A project may be deemed to have a significant impact on hydrology/water quality if the project would:
• Threshold #1: Violate any water quality standards or waste discharge requirements or other substantially degrade surface or groundwater quality.
• Threshold #2 : Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin.
• Threshold #3: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: result in substantial erosion or siltation on- or off-site.
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• Threshold #4: 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: substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site. • Threshold #5: 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: create or contribute to runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.
• Threshold #6: 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: impede or redirect flood flows. • Threshold # 7: Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.
• Threshold #8: Result in significant alteration of receiving water quality during or following construction.
• Threshold #9: Result in an i ncrease in pollutant discharges to receiving waters? Consider water quality parameters such as temperature, dissolved oxygen, turbidity, and other typical storm water pollutants (e.g., heavy metals, pathogens, petroleum derivatives, synthetic organics, sediment, nutrients, oxygen-demanding substances, and trash). • Threshold #10: Be tributary to an already impaired water body as listed on the Clean Water Act Section 303(d) list? If so, can it result in an increase in any pollutant for which the water body is already impaired?
• Threshold #11: Be tributary to environmentally sensitive areas (e.g., MSCP, RARE, Areas of Special Biological Significance, etc.)? If so, can it exacerbate already existing sensitive conditions?
• Threshold #12: Have a potentially significant environmental impact on surface water quality, to either marine, fresh or wetland waters?
As identified earlier in this section, impacts related issue area: risk release of pollutants due to project inundation in flood hazard, tsunami or seiche zones are not discussed in this section.
Chapter 5.0, Environmental Issues Found Not to be Significant, provides additional information on this topic.
3.9.4 Project Impact Analysis
The following analysis discusses the potential for the proposed project to result in impacts to hydrology and water quality. A preliminary Drainage Study and Priority Development Project (PDP) Storm Water Quality Management Plan were prepared for the project by SB&O ( 2020a and 2020b ) and are included in Appendix J.1 and J.2.
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Post-Development Drainage Pattern
According to the drainage report, due to the hillside nature of the development, runoff from the steep driveway entries and frontage slopes will discharge to the Barham Drive gutter. These flow s will be intercepted by a proposed inl et on Barham Drive near the northwest corner of the site. The uphill section of the project will include manufactured cut slopes at the existing hillside. Runoff from the existing and proposed slopes will be intercepted in the bypass drainage ditches and s torm drain, then directed to the westerly limits and then conveyed to a proposed inlet near the northwest corner of the property, which is connected to the existing Barham Drive storm drain (MS-4) (SB&O 2020a).
Detention and Biofiltration
The project propo ses a surface biofiltration basin with enhanced below grade storage to provide water quality treatment and flow control for post development runoff . The surface basin has additional storage depth and an overflow structure with both a weir opening and grate d top to provide attenuation of larger storm events. A concrete lined ramp provides an emergency overflow path to the driveway and then Barham Drive. In order to ensure that post development flows do not exceed existing peak flows, detention routing analys es were prepared to determine peak outflows, and to provide adjusted discharge estimate for comparison to the existing condition (SB&O 2020a).
Nutrient sensitive media wil l be used in the biofiltration basin to provide treatment as San Marcos Creek is a 303(d) listed water body impaired by nutrient pollutant sources (SB&O 2020b).
The City of San Marcos does not allow treatment facilities in the public right -of-way. Runoff from the driveways, frontage slopes and the existing Barham Drive improvements will continue westerly to the existing curb inlet at the church driveway. Street trees will be used at the driveway to intercept and provide treatment to the flows from onsite driveways which ca nnot be captured and routed to the biofiltration basins. (SB&O 2020b). Runoff from the existing improvements on Barham Drive is not being routed to a treatment facility. Instead, the basin is being upsized appropriately to treat additional flows to compensate. Frontage slopes along Barham Drive are considered self-treating.
The biofiltration basin would be subject to regular inspection and maintenance. The property owner is required, pursuant to the City’s Municipal Code Section 14.15 and the BMP Design Man ual, to enter into a stormwater management and discharge control maintenance agreement for the installation and maintenance of permanent BMPs prior to issuance of permits. A maintenance agreement shall be recorded with the City of San Marcos, clarifying ma intenance roles and responsibilities. These comprehensive inspection and maintenance requirements will be included as conditions of approval for the proposed project.
In addition to the biofiltration features, which are considered structural BMPs, the prop osed project would also incorporate source control and site design BMPs as identified in the preliminary SWQMP for the proposed project (Appendix J.2). Source control BMPs include, but are not limited to: 1) preventing illicit discharges into the MS4 ; 2) stenciling the future on -site public road storm drain inlets; and 3) protecting trash storage areas from rainfall, run -on, runoff, and wind dispersal. Site design BMPs include , but are not limited to : 1) conserving natural areas, soils, and vegetation ; 2) minimizing impervious areas; 3) runoff collection through multiple private inlets ; and 4) landscaping with native or drought tolerant species.
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Threshold #1: Violate any water quality standards or waste discharge requirements or other substantially degrade surface or groundwater quality?
Pollutants generated by development projects could include sediments, nutrients, heavy metals, organic compounds, trash and debris, oxygen demanding substances, oil and grease, bacteria and viruses, and pesticides. These poll utants can make their way to drainages and watercourses where they can degrade surface water quality, and in some cases groundwater quality. The project would discharge to San Marcos Creek, which discharges to Batiquitos Lagoon, which discharges to the Pacific Ocean.
The proposed project would comply with all applicable water quality standards and waste discharge requirements. The proposed project includes a comprehensive water quality management approach that includes the use of biofiltration and source co ntrol and site design BMPs to ensure that there would not be an increase in pollutant discharge to receiving waters. No flow-thru treatment BMPs are proposed to be implemented on site in lieu of retention or biofiltration. The stormwater management design for the project was developed following the forms and checklists found in the BMP Design Manual for Permanent Site Design, Storm Water Treatment and Hydromodification Management (City of San Marcos 2016).
The BMP Design Manual provides the guidance necessary to comply with the performance standards presented in Order R9-2013-0001 as amended (RWQCB 2015). This order indicates that discharges from MS4s must not cause or contribute to the violation of water quality standards in any receiving water (RWQCB 2015, Page 18).
In accordance with NPDES regulations, the State requires that any construction activity that disturbs one acre or more must obtain a General Construction Activity Stormwater Permit. Permit applicants are required to prepare a SWPPP and implement BMPs, including erosion and sediment control and non-stormwater management measures, to reduce construction effects on receiving water quality.
Since the proposed project includes disturbance to more than one acre, a General Construction Activity Stormwat er Permit from the SWRCB would be required prior to the issuance of a grading permit. A SWPPP would also be developed and implemented in accordance with the appropriate Risk Level, as determined by the City Engineer. Preparation and implementation of the S WPPP would ensure compliance with the provisions of the NPDES General Permit.
As previously noted, the proposed project has been designed to comply with the land development requirements of Order R9 -2013-0001 as amended and the BMP Design Manual. These requirements were used to recommend BMPs for the proposed project to ensure there would be no impacts. Long -term water quality and HMP requirements are mitigated through appropriate design requirements for commercial, parking lot, and street land uses. The pr oposed project is therefore in compliance with the RWQCB MS4 permit.
In summary, the proposed project would not violate any water quality standards or waste discharge requirements. Impacts would be less than significant.
Threshold # 2: Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Implementation of the project would not use any groundwater. Therefore, the project would not substantially deplete groundwater supplies. The project wil l increase the amount of impervious surface on the project site; however, the project would not interfere substantially with groundwater
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recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level. Impacts are less than significant.
Threshold #3: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: result in substantial erosion or siltation on- or off-site? This section analyzes the potential for the proposed project to alter existing drainage patterns in a way that results in substantial erosion or siltation on- or off-site.
Short Term (Project Construction)
The project site is currently vacant. Grading will consist of approximately 36,394 cubic yards ( cy) of cut material and 91,526 cy of fill material requiring an import of approximately 46,341 CY of material. The proposed project would incorporate construction BMPs in compliance with the General Construction Permit and SWPPP. In addition to the biofiltration features, which are considered structural BMPs, the proposed project would also incorporate source control and site design BMPs as identified in the preliminary SWQMP for the proposed project (Appendix J.2). Source control BMPs include, but are not limited to: 1) preventing illicit discharges into the MS4, 2) stenciling the future on-site public road storm drain inlets, and 3) protecting tras h storage areas from rainfall, run -on, runoff, and wind dispersal. Site design BMPs include: 1) conserving natural areas, soils, and vegetation, 2) minimizing impervious areas, 3) runoff collection through multiple private inlets, and 4) landscaping with native or drought tolerant species. These BMPs have been designed in a manner to be consistent with the requirements of the BMP Design Manual ( City of San Marcos 2016 ) which requires that no pollutants are discharged to the MS4s. Per the BMP Design Manual ( Page 1-5) all development projects, or phases of development projects, are required to implement temporary erosion, sediment, good housekeeping, and pollution prevention BMPs to mitigate storm water pollutants during the construction phase. Short term, con struction-related impacts would be less
than significant.
Long Term (Project Operation)
The proposed project would increase the area of impervious surface on the project site. If not carefully planned for, increased runoff from impervious surface s could cause alterations to drainage courses, increases in erosion and siltation, and increases in flooding due to increased runoff.
However, the proposed project has been designed to carefully handle runoff and to meet regulatory requirements to ensure that post-development runoff quantities and rates are similar to or less than the pre-development condition.
The drainage study for the proposed project identifies the pre - and post-development conditions for runoff rates and quantities (SB&O 2020a, Pages 4 -6). The 100 -year existing/predevelopment flows from the project area are approximately 33.81 cubic feet per second (cfs). In the post development condition, the flows would increase to 60.45 cfs. However, with detention, the flows would be 27.99 cfs resulting in a 5.82 cfs decrease from existing conditions. Runoff quantities and rates are less than in the post -development condition due to the incorporation of biofiltration and source control and site design BMPs.
The post –development condition of the projec t site would include a new biofiltration area. The project proposes a surface biofiltration basin with enhanced below grade storage to provide water quality treatment and flow control for post development runoff . The surface basin has additional storage de pth and an overflow structure with both a weir opening and grated top to provide
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attenuation of larger storm events. These biofiltration features include hydromodification and water quality treatment before discharging runoff to the existing storm drain sy stem. The existing storm drain system conveys discharge to San Marcos Creek which discharges to Batiquitos Lagoon, and ultimately the Pacific Ocean.
The project boundary was compared with the areas of the County with Potential Critical Coarse Sediment Yield Areas (CCSYA). No areas of potential CCSYA are present on this project.
In summary, implementation of the proposed project would not increase the rate or quantities of runoff beyond the pre -development condition. The proposed project therefore meets the applicable peak flow discharge requirements (SB&O 2020, Page 6). The proposed project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on - or off-site (e.g., downstream). Long term impacts would be less than significant.
Threshold #4: Substantially alter the existing drainage pattern of the site or area, including through the alteration of th e course of a stream or river or through the addition of impervious surfaces, in a manner which would: substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
As identified in response to Threshold # 3, the proposed project would increase the area of impervious surface on the project site which could increase runoff flow rates or volumes . However, the proposed project has been designed to carefully handle runoff and meet regulatory requirements to ensure that post -development runoff quantities and rates are similar or less than the pre - development condition. Specifically, post -development runoff rates would be approximately 5.82 cfs less than in the pre -development condition due to the incorp oration of biofiltration, source control and site design BMPs, and the pervious surfaces located throughout the project site (SB&O 2020a,
impact to drainage patte rns due to changes in runoff flow rates or volumes. Impacts would be less
than significant.
Threshold #5: 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: create or contribute to runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
The project proposes a comprehensive approach to stormwater and drainage management. This includes a biofiltration area and source control and site design BMPs that would detain and retain stormwater flows from the project site. The treated stormwater from the biofilt ration area (water quality and hydromodification) would be discharged to the existing storm drain system. Since the runoff will be treated for hydromodification before it enters the system, no changes to downstream flow rates or storm drain capacity are expected.
As described above, the proposed project would not generate increased runoff volumes. Additionally, project-related runoff would be adequately treated prior to discharge into planned drainage systems via biofiltration and BMPs such that the propose d project would not provide substantial additional sources of polluted runoff (SB&O 2020a, Page 6). Off -site storm drains will not be adversely affected by the proposed project as the project would mitigate all storm water flows to be less than existing conditions. The proposed project would not contribute any increase in flows to existing storm drain infrastructure. The proposed project meets all current storm water and hydrology requirements,
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including hydromodification. An expansion of existing facilitie s would not be required to serve the proposed project.
Therefore, the proposed project would not create or contribute runoff water which would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff. Impacts would be less than significant.
Threshold #6: 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 surf aces, in a manner which would: impede or redirect flood flows?
As identified in response to Threshold #3, the proposed project would increase the area of impervious surface on the project site which could increase runoff flow rates or volumes; however, the project has been designed to carefully handle runoff and meet regulatory requirements to ensure that post -development runoff quantities and rates are similar or less than the pre -development condition. Specifically, post -development runoff rates would be approximately 5.82 cfs less than in the pre -development condition due to the incorporation of biofiltration, source control and site design BMPs, and the pervious surfaces located throughout the project site (SB&O 2020a, Page 6).Therefore, the proposed pro ject would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would impede or redirect flood flows. Impacts would be
less than significant.
Threshold #7: Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Short Term
The project site is currently vacant. Grading will consi st of approximately 36,394 c y of cut material and 91,526 cy of fill material requiring an import of approximately 46,341 cy of material. The proposed project would incorporate construction BMPs in compliance with the General Construction Permit and SWPPP. Potential construction -related impacts to receiving water quality could include siltation and erosion, the use of fuels for construction equipment, and the generation of trash and debris from the construction site. In accordance with NPDES regulations, the project will be required to secure a General Construction Activity Stormwater Permit, which will require the preparation of a SWPPP and implementation of BMPs. Examples of typical BMPs implemented in SWPPPs that could be applicable to the project include using temporary mulching, seeding, or other suitable stabilization measures to protect uncovered soils; storing materials and equipment to ensure that spills or leaks cannot enter the storm drain system or surface water; developing and implementing a spill prevention and cleanup plan; installing traps, filters, or other devices at drop inlets to prevent contaminants from entering storm drains; and using barriers, such as straw bales or plastic, to minimize the amount of uncontrolled runoff that could enter drains or surface water. These measures are designed to minimize the generation of pollutants, including sediment and trash/debris and would ensure that the proposed project would not result in significant alteration of receiving water quality during construction. Impacts would be less than significant.
Long Term (Project Operation)
Buildout of the proposed project would increase the amount of imperviousness at the project site; however, based upon the analysis in the preliminary SWQMP prepared for the prop osed project, the proposed project includes a comprehensive water quality management approach that incorporates
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biofiltration features and source control and site design BMPs to ensure that there would not be an increase in pollutant discharge to receiving waters. The biofiltration features and BMPs would also be subject to regular inspection and maintenance as per the preliminary SWQMP (Appendix J.2).
As identified above, impaired water bodies in the Carlsbad Watershed, within which the project site is located, include San Marcos Creek, Batiquitos Lagoon, and the Pacific Ocean. Potential pollutants to be generated by development projects include sediment, nutrients, heavy metals, organic compounds, trash/debris, oxygen demanding substances, oil/grease, and bacteria/viruses.
The BMP Design Manual (Page 2-19) requires that the pollutants of concern for each impaired water body in each watershed be treated by engineered treatment controls to a medium pollutant removal efficiency or better prior to leaving each development site. This requirement results in reductions in pollutants. Biofiltration has a high efficiency for removal of sediments, nutrients, trash, metals, oil/grease, organics, and oxygen demanding substances and has a medium efficiency for removal of bacteria. No flow -thru BMPs are proposed in lieu of retention or biofiltration BMPS. Therefore, the project’s water quality managemen t approach would effectively treat stormwater runoff prior to discharge from the site and to receiving waters. The proposed project would not result in significant alteration of receiving water quality following construction. Impacts would be less than significant.
Threshold # 8: Result in significant alteration of receiving water quality during or following construction?
As identified in response to Threshold #7, short -term, construction -related impacts resulting from siltation and erosion, the use of fuels for construction equipment, and the generation of trash and debris from the construction site would be minimized through project design features and construction-related water quality BMPs identified in the project’s SWPPP. For long -term impacts, and in compliance with the BMP Design Manual, the proposed project includes a comprehensive water quality approach, including biofiltration features and source control and site design BMPs that would pre -treat storm water discharge from impervious areas to a medium pollutant removal efficiency or better, to ensure that there would not be an increase in pollutant discharge to rece iving waters. Therefore, the proposed project would not result in an increase in pollutant discharges to receiving waters. Impacts would be
less than significant.
Threshold # 9: Result in an increase in pollutant discharges to receiving waters? Consider wat er quality parameters such as temperature, dissolved oxygen, turbidity, and other typical storm water pollutants (e.g., heavy metals, pathogens, petroleum derivatives, synthetic organics, sediment, nutrients, oxygen-demanding substances, and trash).
As identified above, impaired water bodies in the Carlsbad Watershed, within which the project site is located, include San Marcos Creek, Batiquitos Lagoon, and the Pacific Ocean. Potential pollutants to be generated by development projects include sediment, nut rients, heavy metals, organic compounds, trash/debris, oxygen demanding substances, oil/grease, and bacteria/viruses.
The proposed project includes a comprehensive water quality management approach to ensure that there would not be an increase in pollutant discharge to receiving waters. The comprehensive use of biofiltration and source control and site design BMPs would effectively treat stormwater runoff prior to discharge from the site and to receiving waters in compliance with the requirements of the BMP Design Manual. No flow -thru treatment BMPs are proposed to be implemented on site in lieu of retention or biofiltration. As identified above, biofiltration has a medium to high efficacy for pollutant removal. Therefore, the project would not result in an increase in pollutant discharges to receiving waters. Impacts would be
less than significant.
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Threshold # 10: Be tributary to an already impaired water body as listed on the Clean Water Act Section 303(d) list? If so, can it result in an increase in any pol lutant for which the water body is already impaired?
As identified above, impaired water bodies in the Carlsbad Watershed, within which the project site is located, include San Marcos Creek, Batiquitos Lagoon, and the Pacific Ocean. Potential pollutants to be generated by development projects include sediment, nutrients, heavy metals, organic compounds, trash/debris, oxygen demanding substances, oil/grease, and bacteria/viruses.
The proposed project includes a comprehensive water quality management approach to ensure that there would not be an increase in pollutant discharge to receiving waters. Nutrient sensitive media will be used in the biofiltration basin to provide treatment . The comprehensive use of biofiltration and source control and site design BMPs would effectively treat stormwater runoff prior to discharge from the site and to receiving waters in compliance with the requirements of the BMP Design Manual. As identified ab ove, biofiltration has a medium to high efficacy for pollutant removal.
Therefore, while the project site is tributary to already impaired water bodies as listed on the CWA Section 303(d) list, the project would not result in an increase in any pollutant f or which those water bodies are already impaired. Impacts would be
less than significant.
Threshold #11: Be tributary to environmentally sensitive areas (e.g., MSCP, RARE, Areas of Special Biological Significance, etc.)? If so, can it exacerbate already ex isting sensitive conditions? As discussed in Section 3.3 Biological Resources, t he project site is located within the M HCP.
However, the project site is not located within a Focused Planning area as defined in the MHCP and the draft San Marcos Subarea Plan . From a water quality and hydrology perspective, conditions in environmentally sensitive areas could be exacerbated by increases in erosion, increases in pollutants, and impacts related to hydrology and flooding.
Erosion – As identified above, w ith the proposed development and incorporation of biofiltration and BMPs, the runoff would be reduced by 5.82 cfs . The proposed biofiltration and BMPs would also minimize the potential for erosion and siltation. Thus, through a combination of reduced runoff and adequately stabilized soils as required by provisions in the NPDES General Permit, Order R9 -2013- 0001 as amended and the BMP Design Manual, the proposed project would not increase erosion on or offsite and would not exacerbate already existing sensitive condit ions at environmentally sensitive areas.
Pollutants/Water Quality – the proposed project includes a comprehensive water quality management approach to ensure that there would not be an increase in pollutant discharge to receiving waters. The use of biofiltration and source control and site design BMPs would effectively treat stormwater runoff prior to discharge from the site and to receiving waters. As identified above, biofiltration has a high efficiency for removal of sediments, nutrients, trash, metals, oil/grease, organics, and oxygen demanding substances and has a medium efficiency for removal of bacteria. The biofiltration features would be subject to regular inspection and maintenance as per the preliminary SWQMP (Appendix J.2) . Furthermore, the prope rty owner would also enter into a stormwater management and discharge control maintenance agreement for the installation and maintenance of permanent BMPs prior to issuance of permits.
Hydrology/Flooding - The proposed project has been designed such that t he proposed project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on or off site. As identified above, the runoff would
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be reduced by 5.82 cfs post -development. Therefore, the proposed project would adequately attenuate stormwater runoff during storm events and not contribute to flooding or hydrology disruptions in sensitive environments.
In conclusion, the proposed project will control of erosion, pollutants, and flooding and would not exacerbate already existing sensitive conditions at environmentally sensitive areas. Impacts would be
less than significant.
Threshold #1 2: Have a potentially significant environmental impact on surface water quality, to either marine, fresh or wetland waters?
To reduce potential impacts to marine, fresh, or wetland waters downstream, the proposed project includes a comprehensive water quality management approach that includes the use of biofiltration and source control and site design BMPs to effectively treat stormwater runoff prior to discharge into Escondido Creek and San Elijo Lagoon. Biofiltration has a high efficiency for removal of sediments, nutrients, trash, metals, oil/grease, organics, and oxygen demanding substances and a medium efficiency for remova l of bacteria. The biofiltration features would be subject to regular inspection and maintenance as per the preliminary SWQMP (Appendix J.2). Furthermore, the property owner would also enter into a stormwater management and discharge control maintenance ag reement for the installation and maintenance of permanent BMPs prior to issuance of permits. Therefore, the proposed project would not have a potentially significant environmental impact on surface water quality, to either marine, fresh, or wetland waters. Impacts would be less than significant.
3.9.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a project’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to hydrology/water quality, the cumulative analysis is based upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts on hydrology/water quality. All of the cumulative projects identified in Table 2 -3 are considered in this cumulative analysis.
Hydrology
Development of the proposed project and cumulative projects would increase the amount of impervious surfaces. This would potentially result in increased surface runoff, alteration of the regional drainage pattern, and flooding. However, like the proposed project, each individual project applicant would be required to hydrologically engineer the respective project sites to ensure that post-development surface runoff flows can be accommodated by the regional drainage system.
Runoff volume from the project site in the post -development condition is less than in the pre - development condition due to the implementation of a comprehensive drainage plan, including the use of biofiltration facilities and BMPs. Therefore, the proposed project’s contribution to a cumulative impact from a hydrology perspective is
less than significant.
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Water Quality
Development of the pro posed project, in conjunction with cumulative projects that drain to the San Marcos Hy drologic Area, has the potential to increase the concentration of pollutants in surface runoff and downstream water quality. However, all cumulatively considered projects would be subject to the same federal water quality standards and state waste discharge requirements that the proposed project is subject to. This includes preparation of project -specific SWPPPs per the NPDES permit program and implementation of associated BMPs to prevent construction -related runoff from polluting receiving waters. Addition ally, the proposed project has been designed to incorporate biofiltration and BMPs to limit the potential for water quality impacts to the greatest extent feasible.
By incorporating these features into the project design, the proposed project would not sub stantially contribute to a significant cumulative impact to water quality. Impacts would be less than significant.
3.9.6 Mitigation Measures
Based upon the analysis presented in Section 3.9.4 and 3.9.5, no impacts were identified and no mitigation measures are required.
3.9.7 Conclusion
The proposed project would increase the number of impervious surfaces at the project site; however, the project site would be hydrologically engineered such that post-development runoff would be less than in the pre -development conditio n. Therefore, hydrologic impacts resulting from the proposed project would be less than significant. Additionally, with incorporation of biofiltration and BMPs that would treat and eliminate the pollutants of concern prior to discharging to Escondido Creek , as well as implementation of a project -specific SWPPP, construction and operation of the proposed project would not result in substantial adverse water quality impacts.
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3.10 `Land Use and Planning
Introduction
This section analyzes the potential for the proposed project to have impacts related to land use and planning. This section considers consistency with applicable land use plans and habitat conservation plans. The transportation portion of the analysis is based on the following report, which is included as Appendix K of the Environmental Impact Report (EIR)12:
• Transportation Impact Analysis & Local Transportation Analysis, Hallmark Barham Specific Plan, San Marcos, California, prepared by Linscott Law & Greenspan (LLG) (May 2021).
The Local Transportation Analysis focuses on automobile delay/L evel of Service (L OS), consistent with the City’s Transportation Impact Analysis Guidelines (San Marcos 2020). The LOS analysis was conducted to identify roadway deficiencies in the project study area and recommend project improvements to address such deficiencies . The Local Transportation Analysis is incorporated and addressed in this section as it relates to consistency with the City’s Mobility E lement policies in the General Plan.
In the Initial Study prepared for the project ( Appendix B.1), the proposed project was determined to have no impact related to physical division of an established community. Therefore, this issue is not discussed further in this EIR section. Section 5.0, Environmental Effects Found not to be Significant - Land Use, provides additional information on this topic.
Table 3. 10-1 summarizes the project - and cumulative -level land use impact analysis for the proposed project.
Table 3.10-1. Land Use Summary of Impacts
Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
Threshold #1: 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?
Significant Significant Significant and
Unavoidable
3.10.1 Existing Conditions
This section describes the existing planning context for the project site, including the General Plan and Zoning designations that currently apply to the site.
12 Full references for documents cited in this section are included in Chapter 7, References, of this EIR.
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Project Site
As shown in Figure 2-1 in Chapter 2, the 10.56- acre project is located at 943 E. Barham Drive, west of La Moree Road in the Barham/Discovery Community within the eastern portion of the City of San Marcos. The project vicinity is developed primarily with residential uses. To the east of the project is the Mira Lago residential development and to the southeast is the Williamsburg residential development. West of the project site is Grace Church and the Barham Park & Ride. Southwest of the project site is residential development associated with the Walnut Hills II Specific Plan. The northern boundary of the project site is E. Barham Drive and immediately north of E. Barham Drive is landscaping, a sound wall, and the State Route 78 (SR ‐78). South of the project site is preserved open space, a pri vate community park/viewpoint and additional residences within the Williamsburg residential development.
The project site is generally undeveloped but appears to have been disturbed historically based on the presence of non -native grassland distinct from a djacent habitats and visible in historical aerial photographs of the area. Based upon historical aerial photography reviews, a residential structure and associated outbuilding were constructed on the project site sometime between 1949 and 1968.
All structures and outbuilding were removed sometime between 1983 and 1996.
Elevations range from 710 feet above mean sea level (amsl) in the southeast portion of the site to 650 feet amsl in the northwest portion of the site . The majority of the project site support s non - native grassland, with Diegan coastal sage scrub habitat occurring along the southern project site boundary. A smaller area of Diegan coastal sage scrub – Baccharis dominated habitat occurs along the eastern project boundary, and disturbed land and ornamental vegetation occur scattered throughout the non -native grassland across the majority of the site. Developed, ruderal, and ornamental land border the north, east, and west project boundaries Existing General Plan Designation
The project site has an existing General Plan Land Use designation of Mixed Use 3 (MU3), which is a mixed-use non-residential designation with a maximum floor area ratio (FAR) of 1.50 . According to Table 2-3 of the Land Use Element of the City’s General Plan, this designation “Provides for a variety of commercial and office uses integrated as a cohesive development. These uses may be mixed ‘vertically’ (on separate floors of a building) or ‘ horizontally’ (on a single site or adjacent parcels).
Structured parking, while not required to achieve the maximum FAR, may be allowed. Shared parking arrangements may also be allowed consistent with the nature of mixed uses. Typical uses include retail, commercial services, administrative and office uses, institutional and government uses, business support and financial uses, restaurants, and health care facilities. To maintain a pedestrian scale and orientation, retail and other active services are encouraged at street level. This designation does not allow residential uses. A Specific Plan is required for development” (City of San Marcos 2012).
Existing Zoning Designation
The project site has a zoning designation of MU -3. According to Section 20.225.060 of the City’s Zoning Ordinance, this zone is intended to “support a job-based mixed use area combining a variety of commercial and office uses integrated as a cohesive development. This business -oriented area shall be complementary to the MU-1 and MU-2 Zones; residential uses are not permitted in the MU-3 (SP) Zone. Typical uses include commercial retail, business services, administrative and office uses, institutional and government uses, business support and financial uses, restaurants and health care facilities. Horizontal and vertical mixed use is permitted” (City of San Marco 2021).
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Surrounding Land Uses
Existing General Plan Designations
As stated above, the project site has a General Plan land use designation of MU3 (Mixed Use 3) . The properties to the west of the site are also designated MU3 . To the southwest are parcels designated OS (Open Space) and SPA (Specific Plan Area). To the s outh of the site is land designated for OS .
Parcels designated LDR (Low Density Residential) are located to the east and southeast . To the north of the site, across E. Barham Drive and SR-78 are parcels designated as LI (Light Industrial).
Existing Zoning Designations
As mentioned, t he proposed project site is zoned MU -3 (Mixed-Use-3). The properties to the west of the site are also designated MU -3. To the southwes t, the parcels are designated O -S (Open Space) and SPA (Specific Plan Area) . To the south , the land is zoned O -S. To the east, parcels are R -1-10 (PRD), Residential Low (Planned Residential Development) . To the north of the site, a cross E.
Barham Drive and SR-78 are parcels zoned LI (Light Industrial).
Roadway Circulation System
The study area includes seven intersections and four roadway segments based on guidance provided in the City of San Marcos’ Transportation Impact Analysis Guidelines (November 2020) , the anticipated distribution of the project traffic, and areas of potential effect. Figure 3.10-1 shows the existing circulation conditions in the project study area.
State Route 78 (SR -78) is an east/west freeway facility connecting Oceanside, Vista, San Marcos, and Escondido. SR -78 is generally built with three general purpose lanes in each direction. The posted speed limit in the study area is 65 MPH. In the study area, local access is provided as follows:
• Westbound SR-78
o Signalized on/off-ramps at the Nordahl Road diamond interchange o Unsignalized on/off ramps from/to Rancheros Drive
• Eastbound SR-78
o Signalized on/off-ramps at the Nordahl Road diamond interchange o Signalized off-ramp to Barham Drive (west of Woodland Parkway) o Signalized on-ramp from Barham Drive (east of Woodland Parkway) Rancheros Drive is an east/west street north of the project site on the opposite side of SR -78. It is identified as an unclassified Major Road on the City of San Marcos Mobility Element . In the project study area Rancheros Drive provides access to SR -78 and is currently built as a two -lane undivided roadway with a posted speed limit that ranges from 30 -35 mph. The distance between the SR -78 westbound ramps and Woodland Parkway is approximately 400 feet. On -street parking is generally not allowed west of Woodland Parkway, but is provided intermittently on portions of Rancheros Drive east of Woodland Parkway.
Woodland Parkway is a north-south street west of the project site. It is identified as a 4 -lane roadway on the City of San Marcos Mobility Element . In the project study area, Woodland Parkway connects Barham Drive to Rancheros Drive, which provides access to/from westbound SR -78. Between
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Barham Drive and Rancheros Drive, Woodland Parkway is approximately 400 feet in length, and provides 3 lanes (including turn lanes) in 32 feet of width. The posted speed limit in the study area is 40 mph, and on-street parking is not allowed.
E. Barham Drive is an east/west facility that is classified within the study area on the City of San Marcos Mobility Element as a 4 -Lane Arterial w/ Class II or III bicycle facilities from Woodland Parkway east to the San Marcos city limits with Escondido, just west of Meyers Avenue.
E. Barham Drive is currently built as a four -lane roadway un divided roadway (two -way left-turn lane median) from Woodland Parkway to east of La Moree Road, where it transitions to a two -lane undivided roadway with a two- way left turn lane median) to the city limits. The posted speed limit is 45 mph between Twin Oak s Valley Road and La Moree Road . The four -lane section described provides Class II bicycle lanes while the two -lane section does not provide separate bicycle facilities.
On-street parking is generally prohibited.
La Moree Road is a two-lane local collector on the City of San Marcos Mobility Element . The posted speed limit is 35 mph. and curbside parking is prohibited in both directions. No sidewalks are provided. Bicycle facilities are not provided.
Existing Level of Service for Intersections and Roadway Segments Table 3.10 -2 summarizes the LOS criteria for signalized and unsignalized intersections. Section
3.10.4 below, provides additional information regarding the level of service analysis and methodology.
Table 3.10-2. Levels of Service Criteria for Intersections LOS Signalized
Intersections
Unsignalized
Intersections Description
A <10 <10 Operations with very low delay and most vehicles do not stop.
B >10 and <20 >10 and <15 Operations with good progression but with some restricted movements.
C >20 and <35 >15 and <25 Operations where a significant number of vehicles are stopping with some backup and light congestion.
D >35 and <55 >25 and <35
Operations where congestion is noticeable, longer
delays occur, and many vehicles stop. The proportion of vehicles not stopping declines.
E >55 and <80 >35 and <50 Operations where there is significant delay, extensive queuing, and poor progression.
F >80 >50 Operations that are unacceptable to most drivers, when the arrival rates exceed the capacity of the intersection.
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Traffic Counts
LLG conducted manual hand counts at the study area intersections in September 2018 between the hours of 7:00 -9:00 AM and 4:00 -6:00 PM while schools were in session. A growth factor of 1% per year for three years (3% total) was added to the traffic counts to represent Year 2021 conditions.
Intersections
Table 3.10 -3 displays intersection LOS and average vehicle delay results for the key study area intersections under existing conditions. As seen in Table 3.10-3, all intersections are calculated to currently operate at LOS D or better during both the AM and PM peak hours, with the exception of Rancheros Drive / SR-78 WB ramps which is calculated to operate at LOS F.
Table 3.10-3. Peak Hour Intersection LOS – Existing Conditions # Intersection Control
Type Peak Hour
Existing
Avg. Delay
(seconds)(1) LOS(2)
1 E. Barham Drive/ SR-78 EB Off Ramp Signal
AM 30.0 C
PM 17.0 B
2 Rancheros Drive/ SR-78 WB Ramp AWSC(3)
AM 69.3 F
PM 55.0 F
3 Rancheros Drive/ Woodland Pkwy Signal
AM 31.3 C
PM 25.2 C
4 E. Barham Drive/ Woodland Pkwy Signal
AM 49.1 D
PM 45.6 D
5 E. Barham Drive/ Project Driveway
(West)(4) --
AM - -
PM - -
6 E. Barham Drive/ Project Driveway
(East) (4) --
AM - -
PM - -
7 E. Barham Drive/ La Moore Road Signal
AM 4.8 A
PM 4.8 A
Source: LLG 2021
Notes: (1) Average Delay expressed in seconds per vehicle (2) Level of Service
(3) AWSC = All Way Stop Control
(4) Intersection does not currently exist
Bold indicates substandard LOS E or F.
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Roadway Segments
Table 3.10 -4 shows the classification of each project area roadway and the current operating conditions for the study area roadway segment. As seen in Table 3.10-4, the study area segm ents are calculated to currently operate at acceptable LOS C.
Table 3.10-4. Roadway Segment LOS – Existing Conditions Roadway Segment Classification Capacity
(LOS E)(1) ADT(2) LOS(3) V/C(4)
E. Barham Drive
Woodland Pkwy to
Project Driveway
(West)
4-Lane Collector/
Secondary Arterial 30,000 18,025 C 0.601
Project Driveway
(West) to Project
Driveway (East)
4-Ln Collector/
Secondary Arterial 30,000 18,025 C 0.601
Project Driveway
(East) to La Moree
Road
4-Ln Collector/
Secondary Arterial 30,000 18,025 C 0.601
East of La Moree
Road
4-Ln Collector/
Secondary Arterial 30,000 18,025 C 0.601
Source: LLG 2021
Notes: (1) Capacities based on City of San Marcos’s Roadway Classification Table (2) Average Daily Traffic Volumes
(3) Level of Service
(4) Volume to Capacity
3.10.2 Regulatory Setting
This section provides an overview of the regulatory setting related to planning and land use that apply to the project, including state, regional, and local regulation and planning documents.
State
California Planning and Zoning Law
The legal framework in which California cities and counties exercise local planning and land use functions is provided in the California Planning and Zoning Law, Government Code Sections 65000 et seq. Under s tate planning law, each city and county is required to adopt a General Plan “for the physical development of the county or city, and any land outside its boundaries which bears relation to its planning” (Section 65300). The California Supreme Court has cal led the General Plan the “constitution for future development.” The General Plan expresses the community’s development goals and embodies public policy relative to the distribution of future land uses, both public and private. A General Plan consists of se veral elements, including land use, circulation, housing, conservation, open space, noise, and safety; other elements may be included at the discretion of the jurisdiction that relate to the physical development of the county or city.
Senate Bill 743
California Senate Bill (SB) 743 mandated specific types of CEQA analysis of transportation projects effective July 1, 2020. Prior to implementation of SB 743, CEQA transportation analyses of individual
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projects typically determined impacts on the circulation sy stem in terms of roadway delay and/or capacity usage at specific locations, such as street intersections or roadway segments. SB 743, signed into law in September 2013, required changes to the guidelines for CEQA transportation analysis. The changes includ e the elimination of auto delay, LOS, and other similar measures of vehicular capacity or traffic congestion as a basis for determining significant impacts. The purpose of SB 743 is to promote the reduction of greenhouse gas emissions, the development of m ultimodal transportation networks, and a diversity of land uses.
Under SB 743, a project’s effect on automobile delay shall not constitute a significant environmental impact. Therefore, LOS and other similar vehicle delay or capacity metrics may no longer serve as transportation impact metrics for CEQA analysis. The California Office of Planning and Research (OPR) has updated the CEQA Guidelines and provided a final technical advisory in December 2018, which recommends VMT as the most appropriate measure of transportation impacts under CEQA.
The California Natural Resources Agency certified and adopted the CEQA Guidelines including the Guidelines section implementing SB 743. The changes have been approved by the Office of the Administrative Law and are now in e ffect. Section 3.15 Transportation, of this EIR analyzes potential VMT impacts related to the proposed project.
While VMT is the preferred quantitative metric for assessing potentially significant transportation impacts under CEQA, it should be noted th at SB 743 does not prevent a city or county from using metrics such as LOS as part of the application of local general plan policies, municipal and zoning codes, conditions of approval, or any other planning requirements through a city’s planning approval process; cities can still ensure adequate operation of the transportation system in terms of transportation congestion measures related to vehicular delay and roadway capacity. As such, the City can continue to require congestion -related transportation ana lysis and mitigation projects through planning approval processes outside CEQA.
To comply with the requirements of SB 743, the City of San Marcos has prepared its Transportation Impact Analysis Guidelines (November 2020) to provide guidance on conducting t ransportation impact analyses in the City as follows:
• CEQA Analysis Requirements: Requirements for conducting CEQA analysis, which consists of SB 743 -consistent VMT analysis as well as assessing impacts to pedestrians, bicyclists, transit, hazards, emergency access, and other impacts (See Section 3.15 Transportation). • Local Transportation Analysis Requirements: Requirements for conducting LOS analysis, site access assessments, and other local transportation analyses for non -CEQA purposes (Section 3.10 Land Use and Planning).
This section analyzes the project’s impact to roadway capacity and roadway deficiencies as it relates to consistency with the City’s Mobility Element policies.
Regional/Local
SANDAG San Diego Forward: The Regional Plan
The Regional Comprehensive Plan (RCP), adopted in 2004 by the San Diego Association of Governments (SANDAG), laid out key principles for managing the region’s growth while preserving natural resources and limiting urban sprawl. The plan covered eight policy areas, including urban form, transportation, housing, healthy environment, economic prosperity, p ublic facilities, our borders, and social equity.
3.10 Land Use and Planning
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In 2011, SANDAG approved the 2050 Regional Transportation Plan and Sustainable Communities Strategy (RTP/SCS). This approval marked the first time SANDAG’s RTP included a sustainable communities strategy, consistent with the Sustainable Communities and Climate Protection Act of 2008, also known as Senate Bill 375. This RTP/SCS provided a blueprint to improve mobility, preserve open space, and create communities, all with transportation choices to reduce gree nhouse gas emissions and meet specific targets set by the California Air Resources Board (CARB) as required by the 2008 Sustainable Communities Act. In 2010, CARB established targets for each region in California governed by a metropolitan planning organiz ation. SANDAG is the metropolitan planning organization for the San Diego region.
The SANDAG target, as set by CARB, is to reduce the region’s per capita emissions of greenhouse gas emissions from cars and light -duty trucks by 7% by 2020, compared with a 2 005 baseline. By 2035, the target is a 13% per capita reduction. There is no target set beyond 2035. To achieve the 2020 and 2035 targets, SANDAG and other metropolitan planning organizations are required to develop a Sustainable Communities Strategy (SCS) as an element of its RTP. The SANDAG SCS integrates land use and transportation plans to achieve reductions in greenhouse gas emissions and meet the CARB-required targets.
On October 9, 2015, the SANDAG Board of Directors adopted San Diego Forward: The Re gional Plan (Regional Plan). The Regional Plan combines the two previously described existing regional planning documents: the RCP and the RTP/SCS. The Regional Plan updates growth forecasts and is based on the most recent planning assumptions considering currently adopted land use plans, including the City’s General Plan and other factors from the cities in the region and the County. SANDAG’s Regional Plan will change in response to the ongoing land use planning of the City and other jurisdictions. For exa mple, the City’s General Plan, and other local General Plans of cities, may change based on General Plan amendments initiated by the jurisdiction or landowner applicants.
The General Plan amendments may result in increases in development densities by amend ing the regional category designations or zoning classifications. Accordingly, SANDAG’s RTP/SCS latest forecasts of future development in the San Diego region, including location, must be coordinated closely with each jurisdiction’s ongoing land use planni ng because that planning is not static, as recognized by the need for updates to SANDAG’s RTP/SCS every 4 years .
In 2019, the SANDAG Board of Directors adopted the San Diego Forward: The 2019 Federal Regional Transportation Plan. It combines the big -picture vision for how the region will grow by 2050 with an implementation program to help make that vision a reality.
SANDAG is in the processing of developing San Diego Forward: The 2021 Regional Plan . The Regional Plan is updated every four years and combines three planning documents that SANDAG must complete per state and federal laws: The Regional Transportation Plan, Sustainable Communities Strategy, and Regional Comprehensive Plan. The Regional Pl an also supports other regional transportation planning and programming efforts, including overseeing which projects are funded under the Regional Transportation Improvement Program and the TransNet program.
SANDAG is applying data -driven strategies, innov ative technologies, and stakeholder input to create a future system that is faster, fairer, and cleaner. Part of this data -driven approach includes the implementation of five key transportation strategies referred to as the 5 Big Moves. These strategies provide the framework for the Regional Plan and consider policies and programs, changes in land use and infrastructure, take advantage of the existing transportation highway and transit networks, and leverage trends in technology to optimize use of the trans portation system. Together, these initiatives will create a fully integrated, world -class transportation system that offers efficient and
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equitable transportation choices, meets state climate targets, and supports local jurisdictions’ achievements of Climate Action Plan goals.
Multiple Habitat Conservation Program
The Multiple Habitat Conservation Program ( MHCP) is a comprehensive conservation planning process that addresses the needs of multiple plant and animal species in northwestern San Diego County. Th e MHCP encompasses the cities of Carlsbad, Encinitas, Escondido, Oceanside, San Marcos, Solana Beach, and Vista. Its goal is to conserve approximately 19,000 acres of habitat, of which roughly 8,800 acres (46%) are already in public ownership and contribut e toward the habitat preserve system for the protection of more than 80 rare, threatened, or endangered species.
The City of San Marcos began preparing a draft of the City Subarea Plan of the MHCP in December 1999 and although the Subarea Plan has not yet been approved by the U.S. Fish and Wildlife Service (USFWS) and California Department of Fish and Wildlife (CDFW), the plan is a component of the adopted MHCP and is currently being used as a guide for open space design and preservation within the City. Th e intent of the City’s Draft Subarea Plan is to identify a citywide preserve system that meets local and regional biological goals while minimizing fiscal and economic impacts to the City and adverse impacts on private property owners. To help achieve this goal, certain areas, known as FPAs, have been designated with parcel -level preserve goals which would contribute to achieving local and regional conservation goals while minimizing adverse effects on property rights and property values. The project site is not located within an FPA.
San Diego County Regional Airport Authority/Airport Land Use Commission The nearest public airport is the McClellan -Palomar Airport, which is located approximately five miles southwest of the project site. The McClellan -Palomar Airport Land Use Compatibility Plan (ALUCP) contains policies to promote land use compatibility between the McClellan -Palomar Airport and adjacent and proximate land uses, to the extent these areas are not already developed with existing uses, and to prot ect the public health, safety, and welfare. Using airport -related forecasts and background data approved by the California Department of Transportation, Division of Aeronautics, the plan reflects anticipated growth of the airport over a 20 -year horizon. The plan includes land use compatibility criteria and identifies policies applicable to the airport and surrounding land uses.
According to the McClellan -Palomar ALUCP, the project site partially lies within Review Area 2 of the airport influence area. The influence area is regulated by the Airport Land Use Commission (ALUC), which regulates land uses in the area to be compatible with airport -related noise, safety, airspace protection, and over -flight factors through review of development proposals within the airport influence area. Review Area 2 consists of limits on heights of structures in areas of high terrain.
Residential development in Review Area 2 may be subject to annoyances commonly associated with proximity to airports, such as noise, vibration, and overflights.
City of San Marcos General Plan
The San Marcos General Plan consists of the following elements:
• Land Use and Community Design Element - Describes the desired future physical composition of the planning area in terms of location, type, and intensity of new development and open space to ensure balanced development that maximizes the long -term livability of the San Marcos community.
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• Mobility Element - Describes the mobility strategy for the City, which identifies a network of options including streets, sidewalks, trails, and transit, that connects people with the City. • Conservation and Open Space Element – Recognizes the habitat and scenic value of natural and cultural open spaces within the City and lists goals and policies that ensure long -term stewardship of these resources. This element also addresses climate change, water conservation, energy conservation, air quality, watersheds, and water quality. • Parks, Recreation and Community Health Element – Identifies the recreational amenities and comm unity service programs offered within the City and outlines goals for increased access to parks, trails, recreational facilities, and community service programs for all community members.
• Safety Element - Establishes policies and programs to protect public health, safety, and welfare of all residents and property. This element identifies and describes plans for response to natural and human -caused safety issues, including geologic, seismic, flood, and fire hazards.
• Noise Element - Identifies problematic noise sources within the City and outlines strategies to reduce overall ambient noise levels. This element also includes measures to strategically distribute land uses throughout the City.
• Housing Element - Describes the strategy for developing a variety of h ousing opportunities to accommodate all residents and preserve the quality of existing housing in order to promote safe, decent, and affordable housing within the 2013-2021 planning period.
The City’s Land Use and Community Design Element identifies five g oals and associated policies to guide well-balanced land use planning in the City. The following goals and policies from the City of San Marcos General Plan, Land Use Element pertain to planning:
• Goal LU -1: Achieve a balanced distribution and compatible mix of land uses to meet the present and future needs of all residents and the business community. o Policy LU -1.1: Ensure that adjacent land uses complement one another by considering compatibility of activities, development patterns and architectural character elements, and access to various mobility choices.
o Policy LU -1.4: Maintain the natural integrity of open space preserves by ensuring development projects are sensitively integrated along the edges of preserved or protected areas.
• Goal LU-2: Promote development standards and land use patterns that encourage long -term environmental sustainability.
o Policy LU -2.1: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use. o Policy LU-2.2: Encourage new development to be sited to respond to climatic conditions, such as solar orientation, wind, and shading patterns.
o Policy LU -2.3: Require the incorporation of green building practices, technologies, and strategies into development projects per code standards.
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o Policy LU-2.5: Promote landscaping (e.g., native, drought -tolerant plants) that minimizes demands on water supply.
o Policy LU-2.7: Promote the installation of trees to reduce the urban heat island effect and green infrastructure to reduce storm water runoff.
• Goal LU -3: Develop land use patterns that are compatible with and support a variety of mobility opportunities and choices.
o Policy LU -3.1: Require that new development and redevelopment incorporate connections and reduce barriers between neighborhoods, transit corridors, and activity centers within the City.
o Policy LU -3.5: Provide an interconnected open space system that is accessible to the public, including pedestrian and equestrian links, bicycle paths, multi -use trails, recreation areas, and drainage-ways.
• Goal LU -5: Promote community design that produces a distinctive, high -quality built environment with forms and character that create memorable places and enrich community life.
o Policy LU-5.4: Require building and site design that respects the natural topography and iconic ridgelines that serve as the visual backdrop for San Marcos. o Policy LU -5.6: Require a specific plan for strategic areas/properties that require high - quality design, orientation, and development due to their location or visibility within the community.
o Policy LU -5.7: Architecture shall be enhanced with high -end building materials, varied roof lines, and decorative details.
• Goal LU-7: Direct and sustain growth and expansion in area s of San Marcos that can support a concentration of a variety of uses and are particularly suitable for multimodal transportation and infrastructure expansion and improvements. o Policy LU -7.2: Coordinate pedestrian, transit and infrastructure upgrades with infill and redevelopment opportunities.
The Mobility Element of the General Plan identifies specific goals and policies related to an efficient circulation system, traffic calming and safety, and alternative modes of travel. Those that are applicable to th e land use for the proposed project are identified below. Policies associated with Goals M-2 and M-3 are analyzed in Table 3.10-5 and discussed in Section 3.15, Transportation. • Goal M-1: Provide a comprehensive multimodal circulation system that serves the City land uses and provides for the safe and effective movement of people and goods. o Policy M-1.1: Safely and efficiently accommodate traffic generated by development and redevelopment associated with implementation of the General Plan Land Use Policy Map o Policy M -1.2: Require new development to finance and construct internal adjacent roadway circulation and City -wide improvements as necessary to mitigate project impacts, including roadway, transit, pedestrian, and bicycle facilities.
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o Policy M -1.3: Require new developments to prepare and implement Transportation Demand Management (TDM) programs to minimize vehicle trip generation and promote alternative modes of travel within the city.
o Policy M-1.4: Utilize multi-modal LOS techniques to evaluate transportat ion facilities. For identified prioritized modes (based on facility typology), provide the following minimum LOS as shown in Table 3-4 of the Mobility Element:
LOS D or better for Vehicles as a prioritized mode
⸋ Generally, provides facilities that have mini mum vehicle congestion during peak periods. Most motorists are delayed less than 55 seconds at a signal (or less than one signalized cycle).
The City shall allow for flexible LOS where warranted (e.g., accepting a lower LOS than identified above).
o Policy M-1.6: Work to improve connectivity within the City by closing gaps in the existing bicycle, pedestrian, trail, transit, and roadway network. Work with new development to provide connectivity and redundancy in the mobility network. o Policy M-1.7: Strive to e nsure that streets within San Marcos shall be complete streets where feasible; thereby providing accessibility, safety, connectivity, and comfort for all modes and users of the system. Appropriate new local streets and Main Streets will prioritize pedestrian and bicycle users through the corridor. • Goal M- 2: Protect neighborhoods by improving safety for all modes of travel and calming traffic where appropriate.
o Policy M -2.1: Work with new development to design roadways that minimize traffic volumes and/or sp eed, as appropriate within residential neighborhoods; while maintaining the City’s desire to provide connectivity on the roadway network. o Policy M -2.3: Consider roundabouts, as appropriate, as an intersection control device with demonstrated air quality, traffic efficiency, and safety benefits. • Goal M-3: Promote and encourage use of alternative transportation modes, including transit, bicycles, neighborhood electric vehicles (NEVs), and walking, within the City. o Policy M-3.1: Develop an integrated, multimod al circulation system that accommodates transit, bicycles, pedestrians, and vehicles; provides opportunities to reduce air pollution and greenhouse gas emissions; and reinforces the role of the street as a public space that unites the City.
o Policy M -3.2: Improve safety conditions, efficiency, and comfort for bicyclists and pedestrians through design, maintenance, and law enforcement. Install wider sidewalks and curb extensions at pedestrian crossings (bulb outs) where appropriate. o Policy M -3.3: Provide a pedestrian and bicycle network in existing and new neighborhoods that facilitates convenient and continuous pedestrian and bicycle travel free of major impediments and obstacles.
o Policy M-3.5: Ensure that streets in areas with high levels of p edestrian activity (such as employment centers, residential areas, mixed use areas, and schools) support safe
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pedestrian travel by providing detached sidewalks, bulb -outs, enhanced pedestrian crossings, pedestrian bridges, and medians.
o Policy M -3.9: Create a pleasant walking environment for roadway typologies where pedestrian travel is prioritized. This includes providing shade trees, landscaping, benches, pedestrian -scale lighting, way finding signage, transit shelters, and other appropriate amenities.
The General Plan includes goals and policies applicable to other areas, such as mobility, safety, noise, and conservation. The project’s consistency with applicable General Plan goals and policies is presented in Table 3.10-5, at the end of this section.
San Marcos Municipal Code and Zoning Ordinance, Title 20 The provisions of Title 20 of the San Marcos Municipal Code are referred to as the Zoning Ordinance.
The Zoning Ordinance is based on the official Zoning Map of the City of San Marcos. The purpose of this Zoning Ordinance is to protect and promote the public health, safety, comfort, convenience, and general welfare of the San Marcos community; to implement the policies of the General Plan; and to provide the physical, environmental, economic, and social a dvantages that result from the orderly planned use of land resources.
The project site has a zoning designation of MU -3. According to Section 20.225.060 of the City’s Zoning Ordinance, this zone is intended to “support a job-based mixed-use area combining a variety of commercial and office uses integrated as a cohesive development. This business -oriented area shall be complementary to the MU-1 and MU-2 Zones; residential uses are not permitted in the MU-3 (SP) Zone. Typical uses include commercial retail, b usiness services, administrative and office uses, institutional and government uses, business support and financial uses, restaurants, and health care facilities. Horizontal and vertical mixed use is permitted” (City of San Marco 2021).
3.10.3 Thresholds of Significance
According to Appendix G of the State CEQA Guidelines, the proposed project would have a significant impact related to land use if it would:
• Threshold #1: Cause a significant environmental impact due to a conflict with any land us e plan, policy, or regulation adopted for the purposes of avoiding or mitigating an environmental effect.
As identified above, impacts related to physical division of an established community are not discussed in this section. Section 5.0, Environmental Ef fects Found not to be Significant, provides additional information on this topic.
3.10.4 Project Impact Analysis
The proposed project proposes 151 multi -family residential units situated on approximately 10.6 gross acres. There are two main categories of open spa ce proposed for the project – common open space (5.53 acres) and approximately 23,390 sq. ft of private open space. The proposed project is requesting approval of a General Plan Amendment (GPA20 -0002), Specific Plan (SP20 -0002), Rezone (R20 -0001), Multi -Family Site Development Plan (MFSDP20 -0001), Tentative Subdivision Map (TSM20-0001), Conditional Use Permit (CUP20 -0007), and Grading Variance (GV20 -0002), as further detailed below:
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• General Plan Amendment (GP20 -0002) – A General Plan Amendment would be requ ired to change the existing Mixed Use 3 (MU3) designation to Specific Plan Area (SPA). • Specific Plan (SP20 -0002) - The Specific Plan establishes the development rules and regulations of all land uses within the project site. Upon adoption of the Specific P lan by the City, all development within the project site must conform to the regulations of the Specific Plan.
• Rezone (R20-0001) - A rezone would be required to change the existing Mixed -Use-3 (MU-3) zoning to Specific Plan Area (SPA).
• Multi-Family Site De velopment Plan (MFSDP20-0001) - The Site Development Plan approval would be required to construct 151 multi -family residential units and address the details of the architectural style, building elevation, fencing, landscaping, among other criteria, within the development.
• Tentative Subdivision Map (TSM20 -0001) – A Tentative Subdivision Map would be required for formation of residential condominium units, private driveways, and open space areas. • Conditional Use Permit (CUP20 -0007) - A Conditional Use Permit would be required for potential use of a temporary rock crusher.
• Grading Variance (GV20 -0002) - A Grading Variance would be required to allow manufactured slopes and/or retaining walls in excess of 20 feet in height without benching within the project area.
Specific Plan
The proposed project is requesting approval of Specific Plan (SP 20-002). The Hallmark Barham Specific Plan will guide the orderly development on the project site. The following objectives describe the underlying purpose of the project:
• Provide a multi -family housing opportunity through a range of unit types, sizes, and number of different bedroom counts, including one, two, three, and four -bedroom units, as well as a range of affordability to accommodate a full spectrum of family demographics to contribute to the growing housing needs of the region;
• Create a development which accommodates appropriate recreational open space for the anticipated residents expected to reside within the Specific Plan Area; • Provide development standards to regulate the nature and appearance of all construction within the Hallmark -Barham Specific Plan Area through integration of landform use, architectural design, unified landscape theme, and recreation areas; • Design a safe and effici ent circulation system that adequately supports the appropriate level of traffic within the Specific Plan Area as well as connections to public roadways and improvements to public streets and rights -of-way inclusive of vehicular, bicycle, pedestrian modes of travel;
• Develop a financing plan that provides for the efficient and timely provision of infrastructure and public services prior to and as development occurs;
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• Implement a maintenance program which will ensure all common areas are maintained to standards set forth in the City’s General Plan; and
• Finance and/or contribute to all appropriate community and citywide infrastructure as warranted.
Threshold #1: Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purposes of avoiding or mitigating an environmental effect.
Plans and policies considered in this analysis include the San Marcos General Plan, the City of San Marcos zoning ordinance, and the Multiple Habitat Conservation Program (MHCP).
San Marcos General Plan
As identified above, the project site has an existing General Plan Land Use designation of Mixed Use 3 (MU3), which is a mixed -use non -residential designation with a maximum FAR of 1.50 . Once approved, the project will be consist ent with the General Plan as the proposed project includes a GPA. The requested GPA would amend the project site’s designation in the Land Use and Community Design Element to “Specific Plan Area.” This GPA would allow for development of the Hallmark Barham Specific Plan including 151 multi- family residential units and common and private open space in an urbanized area of the City with existing residential uses to the east and southeast of the project.
Table 3.10-5 at the end of this section summarizes the a pplicable San Marcos General Plan goals and policies relating to land use. As shown in Table 3.10 -5, the project is consistent with the applicable goals and policies.
Mobility Element Consistency – Level of Service Analysis Analysis Methodology
The AM inte rsection analysis evaluates LOS during the hour with the highest vehicular traffic between 7:00 AM and 9:00 AM. The PM intersection analysis evaluates LOS during the hour with the highest vehicular traffic between 4:00 PM and 6:00 PM. Table 3.10 -2 summarizes the LOS criteria for signalized and unsignalized intersections.
The analysis of signalized intersections utilized the operational analysis procedure as outlined in the Highway Capacity Manual (HCM) 6th Edition signalized intersection analysis methodolog y with the assistance of the Synchro (version 10) computer software. This method defines LOS in terms of delay, or more specifically, average stopped delay per vehicle. The delay values (represented in seconds) were qualified with a corresponding intersect ion LOS. City of Santee and Caltrans location - specific signal timing information such as minimum greens, cycle lengths, splits for the freeway interchanges and real -time peak hour field observations were included in the analysis, where available.
Street se gment analysis is based upon the comparison of daily traffic volumes to the City of San Marcos’s Roadway Classifications, Capacity, and LOS Table. This table provides segment capacities for different street classifications, based on traffic volumes and roadway characteristics.
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Level of Service Standards
The City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards outlined in the General Plan Mobility Element. If the addition of the traffic generated from a pr oposed project results in any one of the following, improvements should be identified to increase performance to acceptable or pre-project conditions under each scenario:
• Triggers an intersection operating at acceptable LOS to operate at unacceptable LOS ( LOS E or F) and increases the delay by more than 2.0 seconds. • Increases the delay for a study intersection that is already operating at unacceptable LOS (LOS E or F) by more than 2.0 seconds.
• Triggers a roadway segment operating at acceptable LOS (LOS A, B , C, D) to operate at unacceptable LOS and increases the volume/capacity (V/C) ratio by more than 0.02. • Increases the V/C ratio for a study roadway segment that is already operating at unacceptable LOS (LOS E or F) by more than 0.02.
Project Trip Generation
To determine the traffic generation of the proposed project, the April 2002 SANDAG Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region (SANDAG 2002) rates were applied to the proposed project. The “Multi-family Residential” (6- 20 DU/acre)” trip rate was used to estimate the project trip generation. Table 3.10-6 presents the trip generation rates and forecasted project - generated trips for weekday conditions. As shown in Table 3.10 -6, the project would generate approximately 1,208 average daily trips (ADTs), including 97 AM peak hour trips and 121 PM peak hour tri ps. The project traffic was distributed and assigned to the street system based on the project’s proximity to state highways and arterials, the project’s two full -access driveways and based on other traffic studies prepared for developments in the area.
Table 3.10-6. Project Trip Generation
Land Use Quantity
Daily Trip Ends
(ADT)
AM Peak Hour PM Peak Hour
%
of
ADT
In:Out
Split
Volume % of
ADT
In:Out
Split
Volume
Rate Volume In Out Total In Out Total
Multi-
Family
Residential
(6-20 DU/
acre)
151 DU 8/DU 1,208 8% 20:80 19 78 97 10% 70:30 85 36 121 Source: LLG 2021
Note: Trip generation rates were obtained from the (Not so) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, April 2002 by SANDAG
Construction Trip Generation
Grading of the project site will consist of approximately 39,711 cubic yards (CY) of cut material and 86,052 CY of fill material requiring an import of approximately 46,341 cy of material. The grading phase of the project is not expected to generate trips above the trips associated with the 151 -unit multi-family residential development. Therefore, the grading phase will not result in any traffic
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related significant impacts or substantial effects above those associated with the p roject. No traffic related impacts are identified during construction.
Local Transportation Analysis of Near -Term (Year 2025) Conditions The following section presents the analysis of study area intersections and street segments under Near Term (Year 2025) conditions without and with the proposed project. Assuming project approvals in late 2021, the project is expected to start construction in late 2022 with an occupancy of Spring 2025. Near Term (Year 2025) traffic volumes were calculated based on the manual hand counts at the study area intersections conducted in September 2018. A growth factor of 1% per year for seven years (7% total) was added to the traffic counts to represent Near Term (Year 2025) conditions.
Near-Term (Year 2025) Intersection Analysis
Table 3.10-7 summarizes the intersection operations through the study area for the Near -Term (Year 2025) With and Without Project conditions.
Table 3.10-7. Near-Term Year (2025) Intersection Operations Without and With Project # Intersection Control
Type
Peak
Hour Movement
Year 2025
Without Project
Year 2025
With Project
Δ(3)
Consistent
with City LOS
Standards?(4)
Avg.
Delay
(sec.)(1)
LOS(2)
Avg.
Delay
(sec.)(1)
LOS(2)
1 E. Barham
Drive/ SR-
78 EB Off
Ramp
Signal
AM
Average
35.9 D 37.6 D 1.7 Yes
PM 21.7 C 25.5 C 3.8 Yes
2 Rancheros
Drive/ SR-
78 WB
Ramp
AWSC(5)
AM
Average
79.7 F 88.2 F 8.5 No
PM 63.8 F 68.9 F 5.1 No
3 Rancheros
Drive/
Woodland
Pkwy
Signal
AM
Average
35.0 C 37.2 D 2.2 Yes
PM 26.5 C 27.7 C 1.2 Yes
4 E. Barham
Drive/
Woodland
Pkwy
Signal
AM
Average
54.5 D 54.6 D 0.1 Yes
PM 43.8 D 48.5 D 4.7 Yes
5 E. Barham
Drive/
Project
Driveway
(West)f
MSSC(7)
AM
NBL - - 30.0 D - Yes
NBR - - 14.9 B - Yes
WBL - - 12.5 B - Yes
PM
NBL - - 46.7 E - No
NBR - - 18.6 C - Yes
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WBL - - 16.5 C - Yes
6 E. Barham
Drive/
Project
Driveway
(East)f
MSSC(7)
AM
NBL 27.7 D Yes
NBR 15.4 C Yes
WBL 12.5 B Yes
PM
NBL 43.0 E No
NBR 18.7 C Yes
WBL 16.3 C Yes
7 E. Barham
Drive/ La
Moore Road
Signal
AM
Average
4.8 A 4.8 A 0.0 Yes
PM 4.9 A 4.9 A 0.0 Yes
Source: LLG 2021
Notes: (1) Average Delay expressed in seconds per vehicle (2) Level of Service
(3) Δ denotes the increase in delay due to project
(4) City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards (LOS D or better) outlined in the General Plan Mobility Element. (5) AWSC = All Way Stop Control
(6) Intersection does not exist under “Without Project” condition (7) MSSC= Minor Street Stop Controlled Intersection. Worst-Case movement approach delay and LOS reported
Bold indicates substandard LOS E or F.
As shown in Table 3.10-7, without the project, all intersections are calculated to operate acceptably at LOS D or better during both the AM and PM peak hours with the exception of Rancheros Drive/SR - 78 WB ramps , which is calculate d to operate at LOS F . With the ad dition of p roject traffic all intersections would continue to operate acceptably at LOS D or better during both the AM and PM peak hours with the exception of Rancheros Drive/SR -78 WB Ramps, which would operate at LOS F under both “ Without” and “W ith Project” conditions. A significant LOS related impact is identified at this intersection since the p roject-related increase in delay exceeds the LOS standard threshold maximum of 2.0 seconds and mitigation is required (Impact LU-1). • Impact LU-1 Project-related traffic results in a significant increase in delay (greater than
2.0 seconds) at the Rancheros Drive/ SR - 78 WB intersection in the AM and PM peak hours under Near Term 2025 With Project condition.
Additionally, the northbound left-turn movements out of the project’s western and eastern driveways are calculated to operate at LOS E during the PM peak hour. A significant impact is identified at these driveways due to the deficient LOS E (Impact LU-2a and LU -3a) and mitigation is required . It should be noted that all other movements operate acceptably, including the northbound right -turns out of the site and the westbound left -turns into the site. The significant effect is only for the outbound left-turns during the PM peak hour.
• Impact LU-2a Northbound left-turn movement out of the E. Barham Drive/ Project Driveway (West), the project’s western driveway, is calculated to operate at LOS E during the PM peak hour under Near Term 2025 With Project condition.
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• Impact LU -3a Northbound left -turn movement out of the E. Barham Drive/ Project Driveway (East), the project’s eastern driveway, is calculated to operate at LOS E during the PM peak hour under Near Term 2025 With Project condition.
Near-Term (Year 2025) Segment Operations
Table 3.10-8 summarizes the segment operations throughout the study area for the Near-Term (Year 2025) Without and With Project condition s. As seen in Table 3.10 -8, all of the study area segments are calculated to operate acceptably at LOS C without the project. As see n in 3.10 -8, with the addition of project traffic all of the study area segments would continue to operate at LOS C, and therefore no impact is identified and no roadway improvements are required.
Table 3.10-8. Near Term (Year 2025) Roadway Segment Operations Roadway Segment
Capacity
(LOS
E)(1)
Year 2035 Without
Project
Year 2035 With
Project
Δ(5)
Consistent
with City
LOS
Standards?
(6)
ADT(2) LOS(3) V/C(4) ADT(2) LOS(3) V/C(4)
E.
Barham
Drive
Woodland
Pkwy to
Project
Driveway
(West)
30,000 18,930 C 0.631 19,570 C 0.652 0.021 Yes
Project
Driveway
(West) to
Project
Driveway
(East)
30,000 18,930 C 0.631 19,530 C 0.651 0.020 Yes
Project
Driveway
(East) to
La Moree
Road
30,000 18,930 C 0.631 19,510 C 0.650 0.019 Yes
East of La
Moree
Road
30,000 18,930 C 0.631 19,450 C 0.648 0.017 Yes
Source: LLG 2021
Notes: (1) Capacities based on City of San Marcos’s Roadway Classification Table (2) Average Daily Traffic Volumes
(3) Level of Service
(4) Volume to Capacity
(5) Δ denotes a project-induced increase in the Volume to Capacity (V/C) ratio. (6) City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards (LOS D or better) outlined in the General Plan Mobility Element.
Local Transportation Analysis of Horizon Year 2050 Conditions Year 2050 Network Conditions
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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 3.10-20
There are a series of improvements to the SR-78 freeway system in the vicinity of the project that are identified in the City of San Marcos’ Capital Improvement Program (CI P) as the “Woodland Parkway Highway 78 Interchange” project (CIP P roject Code No. 88005). These improvements would directly improve substandard locations in the study area. The following is a discussion of these improvements, organized by corridor.
• Rancheros Drive Corridor: widen Rancheros Drive to four -lane major street standards from the SR-78 Westbound Ramps to Woodland Parkway, including Class II bike lanes. Signalize the Rancheros Drive/SR -78 Westbound Ramps intersection. Provide dual westbound -to- southbound left -turn lanes from Rancheros Drive to the SR -78 westbound on -ramp. Widen the SR-78 westbound on-ramp from Rancheros Drive to include two SOV and one HOV lanes.
Widen the SR -78 westbound off- ramp to Rancheros Drive to include one left -turn lane and two right-turn lanes.
• Woodland Parkway Corridor: widen the Woodland Parkway undercrossing at SR -78 from Rancheros Drive to Barham Drive to four -lane major street standards. Provide two -travel lanes in each direction, with back -to-back left -turn lanes at b oth Barham Drive and Rancheros Drive. Provide Class II bike lanes.
• Barham Drive Corridor : realign Barham Drive from west of the SR-78 off ramp to Woodland Parkway to provide a six - lane prime arterial transitioning to a four -lane major street east of Woodland Parkway. Widen and realign the existing SR -78 eastbound off-ramp to include two left-turn lanes and one right -turn lane. Construct a new SR -78 eastbound on -ramp from E.
Barham Drive to include two SOV and one HOV lanes. Install a traffic signal at the realigned E. Barham Drive/ SR -78 eastbound ramps intersection. Remove the existing on -ramp to eastbound SR-78 located east of La Moree Road, and the associated signalized intersection. • SR-78 Freeway: widen and improve SR-78 to an 8-lane facility with two managed lanes in the median. Provide necessary on -ramp and off -ramp transitions, acceleration lanes and trap lanes, as required to provide the improvements listed above.
These improvements will be dev eloped in phases, although the timing of delivery of these improvements is unknown. While these improvements were conservatively not assumed in the near - term analysis, they were assumed to be in place in the long-term.
The above -listed improvements are ass umed in the baseline conditions for Year 2050 analysis of study area intersections and street segments.
Horizon Year 2050 Traffic Volumes
LLG reviewed several recent traffic studies prepared in the City of San Marcos that included buildout traffic volume assumptions, specifically the traffic study for the approved Sunrise Residential project located just east of the project. The Sunrise Residential project used the SANDAG Series 12 Year 2035 traffic model to forecast Year 2035 traffic volumes in the study a rea, assuming the Woodland Parkway Highway 78 Interchange project improvements discussed above were in place.
In order to conduct an analysis of Year 2050 conditions based on the City’s Traffic Impact Analysis Guidelines, LLG conducted a comparison of the SANDAG Series 12 Year 2035 traffic volumes from the Sunrise Residential project traffic study to the SANDAG Series 13 Year 2050 model traffic volumes. The Series 13 Year 2050 volumes were found to be lower than the Series 12 Year 2035 volumes. Therefore, i n order to provide a conservative analysis and be consistent with other
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documents prepared for projects in the area, the Year 2035 traffic volumes taken directly from the Sunrise Residential traffic study were used for the analysis of Year 2050 conditions instead of assuming lower volumes in Year 2050 as compared to Year 2035.
Horizon Year 2050 Intersection Analysis
Table 3.10-9 summarizes the Year 2050 Without and With Project peak hour intersection analysis.
As shown in Table 3.10 –9, without project, all intersections are calculated to operate acceptably at LOS D or better during both the AM and PM peak hours.
Table 3.10-9. Horizon Year (2050) Intersection Operations Without and With Project # Intersection Control
Type
Peak
Hour Movement
Year 2050
Without Project
Year 2050
With Project
Δ(3)
Consistent
with City
LOS
Standards?
(4)
Avg.
Delay
(sec.)(1)
LOS(2)
Avg.
Delay
(sec.)(1)
LOS(2)
1 E. Barham
Drive/ SR-78 EB
Off Ramp
Signal
AM
Average
6.7 A 6.7 A 0.0 Yes
PM 4.9 A 5.0 A 0.1 Yes
2 Rancheros
Drive/ SR-78 WB
Ramp
Signal
AM
Average
14.4 B 14.7 B 0.3 Yes
PM 18.7 B 18.9 B 0.2 Yes
3 Rancheros
Drive/ Woodland
Pkwy
Signal
AM
Average
24.9 C 26.0 C 1.1 Yes
PM 21.9 C 22.7 C 0.8 Yes
4 E. Barham
Drive/ Woodland
Pkwy
Signal
AM
Average
15.6 B 15.7 B 0.1 Yes
PM 28.3 C 32.7 C 4.4 Yes
5 E. Barham
Drive/ Project
Driveway (West)e
MSSC(6)
AM
NBL - - 27.3 D - Yes
NBR - - 14.3 B - Yes
WBL - - 12.0 B - Yes
PM
NBL - - 40.9 E - No
NBR - - 17.5 C - Yes
WBL - - 15.4 C - Yes
6 E. Barham
Drive/ Project
Driveway (East)e
MSSC(6)
AM
NBL - - 25.7 D Yes
NBR - - 14.7 B Yes
WBL - - 12.0 B Yes
PM
NBL - - 38.1 E No
NBR - - 17.5 C Yes
WBL - - 15.2 C Yes
7 E. Barham Signal AM Average 5.1 A 5.1 A 0.0 Yes
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Drive/ La Moore
Road PM 5.3 A 5.3 A 0.0 Yes
Source: LLG 2021
Notes: (1) Average Delay expressed in seconds per vehicle (2) Level of Service
(3) Δ denotes the increase in delay due to project
(4) City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards (LOS D or better) outlined in the General Plan Mobility Element. (5) Intersection does not exist under “Without Project” condition (6) MSSC= Minor Street Stop Controlled Intersection. Worst-Case movement approach delay and LOS reported
Bold indicates substandard LOS E or F.
With the addition of project traffic all intersections are calculated to continue to operate acceptably at LOS D or better during the AM and PM peak hours with the exception of the northbound left -turn movements out of the project’s western and eastern driv eways which are calculated to operate at LOS E during the PM peak hour. S ignificant LOS related impacts are identified at th ese approaches due to the deficient LOS E. It should be noted that all other movements operate acceptably, including the northbound right -turns out of the site and the westbound left -turns into the site. The significant impact is only for the outbound left-turns during the PM peak hour.
Implementation of the proposed project would result in a significant impact at the E. Barham Drive/ Project Driveway (West) and E. Barham Drive/ Project Driveway (East) Northbound Lane s (Impacts LU-2b and LU-3b). Mitigation is required.
• Impact LU-2b Northbound left -turn movement out of the E. Barham Drive/ Project Driveway (West) (the project’s western driveway) is calculated to operate at LOS E during the PM peak hour under Horizon Year 2050 with Project condition. The significant effect is only for the outbound left-turns during PM peak hour. • Impact LU-3b Northbound left -turn move ment out of the E. Barham Drive/ Project Driveway (East) (the project’s eas tern driveway) is calculated to operate at LOS E during the PM peak hour under Horizon Year 2050 with Project condition. The significant effect is only for the outbound left-turns during PM peak hour.
Horizon Year 2050 Segment Operations
Table 3.10-10 summarizes the Year 2050 Without and With Project daily street segment operations.
As shown in Table 3.10 -10, all street segments are calculated to operate acceptably at LOS C without a nd with the addition of project traffic. Therefore, no impact is identified and roadway improvements are not required.
Community Facility District (Congestion Management) Participation As a condition of project approval, the applicant/developer/property ow ner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD2011-01 (Congestion Management).
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Consistency with City of San Marcos Zoning Ordinance
As identified above, the Zoning Map of the City of San Marcos identifies the project site as MU -3. The project proposes Rezone (R20 -0001) to Specific Planning Area (SPA). The Specific Plan would serve as the zoning document for the property establishing de velopment and zoning standards. The Specific Plan provides for the development of 151 multi- family residential units situated on approximately 10.6 gross acres. Residential buildings compose approximately 2.8 -acres of the project site. Multi- family residential dwelling units are comprised of one, two, and three -story condominiums with ten dwelling unit types interspersed throughout the project site. Overall building heights will not exceed 40 feet.
Multiple Habitat Conservation Program
The project’s consistency with the MHCP is analyzed in Section 3.3, Biological Resources, of this EIR.
The analysis concludes that while the project is located within the MHCP, it is not located within a Focused Planning Area (FPA) as defined in the MHCP and San Marcos Subarea Plan. Additionally, the project would comply with habitat mitigation requirements outlined in the City’s Draft MHCP Subarea Plan. The project, therefore, is consistent with the MHCP.
Table 3.10-10. Horizon Year (2050) Roadway Segment Operations Roadway Segment
Capacity
(LOS
E)(1)
Year 2050 Without
Project
Year 2050 With
Project Δ(5)
Consistent
with City LOS
Standards?(6) ADT(2) LOS(3) V/C(4) ADT(2) LOS(3) V/C(4) E.
Barham
Drive
Woodland
Pkwy to
Project
Driveway
(West)
30,000 18,380 C 0.613 19,020 C 0.634 0.021 Yes
Project
Driveway
(West) to
Project
Driveway
(East)
30,000 18,380 C 0.613 18,980 C 0.633 0.020 Yes
Project
Driveway
(East) to
La Moree
Road
30,000 18,380 C 0.613 18,960 C 0.632 0.019 Yes
East of La
Moree
Road
30,000 18,380 C 0.613 18,900 C 0.630 0.017 Yes
Source: LLG 2021
Notes: (1) Capacities based on City of San Marcos’s Roadway Classification Table (2) Average Daily Traffic Volumes
(3) Level of Service
(4) Volume to Capacity
(5) Δ denotes a project-induced increase in the Volume to Capacity (V/C) ratio.
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(6) City of San Marcos strives to maintain intersection and roadway segment operations based on LOS standards (LOS D or better) outlined in the General Plan Mobility Element.
3.10.5 Cumulative Impact Analysis
No existing or reasonably foreseeable land use impacts were identified as a result of development of the proposed project because it would not conflict with any plans adopted for the purposes of avoiding environmental impacts , ot her than Mobility Element Policy M -1.1 (Safely and efficiently accommodate traffic generated by development and redevelopment associated with implementation of the General Plan Land Use Policy Map) and M-1.4 (Utilize multi-modal LOS techniques to evaluate transportation facilities).
The preceding analysis of the proposed project in Section 3.10.4 is based on methodologies that incorporate the cumulative effects of traffic from general growth and anticipated development in the area. This reflects background traffic and traffic from area -wide growth already approved by the City of San Marcos plus the development of the proposed project.
Near Term Year 2025 traffic volumes were calculated based on the manual hand counts at the study area intersections conducted in September 2018. A growth factor of 1% per year for seven years (7% total) was added to the traffic counts to represent Year 2025 conditions. Implementation of the proposed project would result in significant impacts at three intersections in the Near Term 2025 With Project conditions : Rancheros Drive/ SR - 78 WB ramp (Impact LU -1) and E. Barham Drive/ Project Driveway (West) , Northbound Lane (Impact LU -2a), and E. Barham Drive/ Project Driveway (East), Northbound Lane (Impact LU -3a). Mitigation measure MM-LU-1 would reduce the cumulative impact to Rancheros Drive/ SR -78 WB ramp to below a level of significance but because the improvement is located outside of City of San Marcos’s jurisdiction, the impact would remain significant and unavoidable. Mitigation measures LU-2 and LU-3 would reduce the cumulative impact to the project’s western and eastern driveways at E. Barham Drive/ Project Driveway (West) and (East) Northbound Lane during the PM p eak hour by restricting left -turns out of the project site between the hours of 4 PM and 6 PM in order to improve operations at the intersection . Therefore, a less than significant cumulative impact is identified for these intersections under Near Term Year 2025 conditions.
In order to conduct an analysis of Horizon Year 2050 conditions based on the City’s Traffic Impact Analysis Guidelines , LLG conducted a comparison of the SANDAG Series 12 Year 2035 traffic volumes from the recent Sunrise Residential project traffic study to the SANDAG Series 13 Year 2050 model traffic volumes. The Series 13 Year 2050 volumes were found to be lower than the Series 12 Year 2035 volumes. Therefore, in order to provide a conservativ e analysis and be consistent with other documents prepared for projects in the area, the Year 2035 traffic volumes taken directly from the Sunrise Residential traffic study were used for the analysis of Year 2050 conditions instead of assuming lower volume s in Year 2050 as compared to Year 2035.
Implementation of the proposed project would result in a significant impact at the northbound left - turn movements out of the project’s western driveways (E. Barham Drive/ Project Driveway (West) and eastern driveway s (E. Barham Drive/ Project Driveway (East)) Northbound Lanes (Impact LU -2b and LU-3b) which are calculated to operate at LOS E during the PM peak hour. Mitigation Measure s MM-LU-2 and LU-3 would reduce the cumulative impact to E. Barham Drive/ Project Dri veway (West) and (East) Northbound Lane s to below a level of significance by restricting left -turns out of the
project site between the hours of 4 PM and 6 PM . Therefore, a less than significant cumulative impact is identified for these intersections under Horizon Year 2050 conditions.
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3.10.6 Mitigation Measures
Traffic Mitigation
The following improvements are recommended to mitigate the identified significant impacts under Near Term 2025 and Horizon Year 2050 With Project conditions (as indicated).
Rancheros Drive/ SR-78 WB Ramp - Near Term 2025 during AM and PM peak hour (Impact LU-1) MM-LU-1 Prior to the issuance of the first building permit, the Project Developer shall pay the local and regional Public Facility Fees (PFF) development fees assessed to address the impact to the City of San Marcos’ SR 78 Interchanges.
Northbound left -turn movement out of the E. Barham Drive/ Project Driveway (West) Near Term 2025 (Impact LU-2a) and Horizon Year 2050 (Impact LU-2b) during PM Peak Hour MM-LU-2 The project s hall restrict left -turns out of the western project driveway between the hours of 4 PM and 6 PM. Signage shall be placed at the western project driveway identifying the turning movement timing restriction. The signage requirement shall be noted on the fina l project plans and shall be put in place prior to project operation.
Northbound left-turn movement out of the E. Barham Drive/ Project Driveway (East) Near Term 2025 (Impact LU-3a) and Horizon Year 2050 (Impact LU-3b) during PM Peak Hour MM-LU-3 The proje ct shall restrict left -turns out of the eastern project driveway between the hours of 4 PM and 6 PM. Signage shall be placed at the eastern project driveway identifying the turning movement timing restriction. The signage requirement shall be noted on the final project plans and shall be put in place prior to project operation.
3.10.7 Conclusion
The current General Plan land use and zoning designation is MU -3. With the proposed GPA and Rezone to Specific Plan and SPA, respectively, the project would be consistent with the applicable goals and policies of the City’s General Plan. The project would also be consistent with the MHCP.
Based upon the analysis presented in Sections 3.10.3 and 3.10.4, including Table 3.10 -5, implementation of the proposed project would not conflict with any land use plan, policy, or regulation adopted for the purposes of avoiding or mitigating an environmental effect, with the exception of Mobility Element Policies M-1.1: Safety and efficiently accommodate traffic generated by development a nd redevelopment associated with implementation of the General Plan Land Use Policy Map (related to LOS) and M-1.4: Utilize multi-modal LOS techniques to evaluate transportation facilities.
The proposed project is forecast to generate 1,208 average daily t rips, with 97 AM peak hour trips and 121 PM peak hour trips during the week. The Local Mobility Analysis shows that all study intersections and street segments are calculated to operate acceptably at LOS D or better with the addition of p roject traffic, with the exception of Rancheros Drive / SR -78 WB Ramps , which is calculated to operate at LOS F under both “ Without” and “With Project” conditions during Near Term 2025. A s ignificant LOS related effect is identified at this intersection since the project-related increase in delay exceeds the LOS standard threshold maximum of 2.0 seconds (Impact LU-1). The
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existing traffic conditions at this location are already substandard and warrant a traffic signal.
Provision of a traffic signal alone would be sufficient to reduce the project’s LOS related effect to less than significant. In addition, MM-LU-1 requires payment of local and regional PFF development fees prior to the issuance of the first building permit to address the impact to the City of San Marcos’ SR 78 Interchanges.
The project site is currently zoned MU -3, which is intended to support a job -based mixed-use area combining a variety of commercial and office uses. The p roject will result in reduced traffic as compared to the current MU -3 zoning considered in the Capital Improvement Program ( CIP).
Therefore, no additional payment is required based on the proposed zone change. A comparison of the project’s trip generation calculations and the MU -3 zoning trip generation calculations is shown below in Table 3.10 -11, and shows that the p roject is calculated to generate approximately 900 4,200 fewer ADT as compared to the land uses assumed in the General Plan.
It should be noted that the improvement would be Capital Improvement Project (CIP) located within the jurisdiction and control of the State of California (Caltrans), and neither the developer nor the City of San Marcos can ensure that Caltrans will permit the improvement to be made. Based on regional standards of practice, the near -term dir ect project impacts at this location would be considered significant and unavoidable for the purposes of CEQA. However, inter -jurisdictional coordination would be expected to occur to permit the implementation of this mitigation measure and the intersection and impacts would be less than significant in the Horizon Year.
Table 3.10-11. Proposed Project and Existing Zoning Comparison Land Use(1) Daily Trip Ends (ADT)
Proposed Project Quantity Rate Volume
Multi-family Residential (6- 20 DU/acre) 151 DU 8 /DU 1,208 Existing Zoning Quantity Rate Volume
Office (Large Commercial Office – more than
100,000 s.f.) 275.067 KSF 17 KSF 4,676
Retail (Specialty Retail/Strip Commercial) 18.344 KSF 40 KSF 734 TOTAL 5,410
Source: LLG 2021
Note: (1) Rates are based on SANDAG’s (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, April 2002.
Additionally, the northbound left-turn movement out of the project’s western driveway is calculated to operate at LOS E during the PM peak hour. A significant LOS related effect is identified at this approach due to the deficient LOS E during Near Term (Year 2025) and Horizon Year (2050) during PM Peak Hour (Impacts LU -2a and 2b). Similarly, the northbound left -turn movement out of the project’s eastern driveway is calculated to operate at LOS E during the PM peak hour. A significant LOS related effect is identified at this approach due to the deficient LOS E during Near Term (Year 2025) and Horizon Year (2050) during PM Peak Hour (Impact s LU-3a and 3b). Mitigation Measure s MM-LU-2 and MM -LU-3 requires the project to restrict left -turns out of the project site between the hours of 4 PM and 6 PM in order to improve operations at these intersections and reduce the project’s LOS related effects to less than significant.
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Figure 3.10-1. Existing Circulation Network
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Table 3.10-12. Project Consistency with Applicable San Marcos General Plan Goals and Policies General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Land Use and Community Design Element
Goal LU-1 Achieve a balanced distribution and
compatible mix of land uses to meet the
present and future needs of all residents and
the business community.
The project would construct 151 multi-family residential units, which would add to the housing stock within the City and the greater North County area of San Diego.
These units would meet the demand for future housing in the City, as contemplated by the City’s General Plan. Additionally, the project proposes a density and type of development compatible with existing surrounding development patterns in the City. The project is consistent with this goal.
Goal LU-1,
Policy LU-1.1
Ensure that adjacent land uses complement
one another by considering compatibility of
activities, development patterns and
architectural character elements, and access
to various mobility choices.
The project vicinity is developed primarily with residential uses. To the east of the project is the Mira Lago residential development and to the southeast is the Williamsburg residential development. West of the project site is Grace Church and the Barham Park & Ride. Southwest of the project site is residential development associated with the Walnut Hills II Specific Plan. The northern boundary of the project site is E. Barham Drive and immediately north of E. Barham Drive is landscaping, a sound wall, and SR‐78. South of the project site is preserved open space, a private community park/viewpoint and additional residences within the Williamsburg residential development. The architectural style of the project will be Contemporary Spanish which was chosen based on compatibility with the surrounding land uses. Proposed residential structures will also be a similar height to current and planned residential projects. The project improves roadways, and sidewalks, providing for a variety of transportation options. Each residence has garages for parking. The project is consistent with this policy.
Goal LU-1,
Policy LU-1.4
Maintain the natural integrity of open space
preserves by ensuring development projects
are sensitively integrated along the edges of
preserved or protected areas.
South of the project site is preserved open space, a private community park/viewpoint and additional residences within the Williamsburg residential development. The project is designed with a 150-foot fire fuel modifications buffer and the residential units would be buffered from the open space area by common open space with grades 10% or greater. The project is consistent with this policy.
Goal LU-2 Promote development standards and land
use patterns that encourage long-term
environmental sustainability.
The project clusters development and provides 5.35 acres of common open space.
The project also includes a comprehensive water quality management approach using low impact development (LID) techniques to mitigate any impacts to
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy environmental sustainability. The project is consistent with this goal.
Goal LU-2,
Policy LU-2.1
Promote compact development patterns that
reduce air pollution and automobile
dependence and facilitate walking, bicycling,
and transit use.
The project concentrates the proposed residential units together leaving the southern portion of the site to common open space. The project’s internal pedestrian circulation network would connect to the existing sidewalk and bicycle facilities along the project frontage on E. Barham Dr. The closest bus stops are 0.7 mile from the project site and would not be impacted by the project. The proposed project is consistent with this policy.
Goal LU-2,
Policy LU-2.2
Encourage new development to be sited to
respond to climatic conditions, such as solar
orientation, wind, and shading patterns.
The project would comply with the latest applicable Title 24 standards. The 2019 Title 24 standards require that all low-rise residential buildings shall have a photovoltaic system meeting the minimum qualification requirements such that annual electrical output is equal to or greater than the dwelling’s annual electrical usage. The project is consistent with this policy.
Goal LU-2,
Policy LU 2.3
Require the incorporation of green building
practices, technologies, and strategies into
development projects per code standards.
The project incorporates green features. As a design feature, the project would install three Level 2 EV charging stations. The project will also wire each garage for EV charging stations. The landscaping plan focuses on native, drought tolerant species. This minimizes the use of water for irrigation. The project has also been designed to meet current California Building Code requirements as related to green building practices. The project is consistent with this policy.
Goal LU-2,
Policy LU-2.5
Promote landscaping (e.g., native, drought-
tolerant plants) that minimizes demands on
water supply.
The proposed landscape plan includes a mix of trees, shrubs, grasses and groundcover and the plant selection emphasizes moderate water use species. The landscape concept plan is included as Figure 2-4a and the plant material guide is included as Figure 2-4b. The landscape plan meets the requirements of the City of San Marcos development standards, and drought resistant plant species and fire- resistant landscape design consistent with the Fire Protection Plan. The project will comply with the City’s Water Efficiency Landscaping Ordinance. The project is consistent with this policy.
Goal LU-2,
Policy LU-2.7
Promote the installation of trees to reduce
the urban heat island effect and green
infrastructure to reduce storm water runoff.
The proposed landscape plan includes a mix of trees, shrubs, grasses and groundcover and the plant selection emphasizes moderate water use species. The landscape concept plan is included as Figure 2-4a and the plant material guide is included as Figure 2-4b. Proposed tree species include desert willow, majestic beauty Indian hawthorn, California laurel, columnar Italian cypress, fern pine,
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy western redbud, European olive, Mexican palo verde, African suman, strawberry tree, flaxleaf paperbark, and date palms. See Figure 2-4b for a comprehensive list of proposed plant materials. The project will also comply with the City’s Model Water Efficient Landscape Ordinance and Municipal Code, Title 20. As discussed in greater detail in Section 3.9 (Hydrology/Water Quality) the project incorporates biofiltration features and source control and site design BMPs to reduce storm water runoff. The project is consistent with this policy.
Goal LU-3 Develop land use patterns that are
compatible with and support a variety of
mobility opportunities and choices.
The project’s internal pedestrian circulation network would connect to the existing sidewalk and bicycle facilities along the project frontage on E. Barham Dr. The closest bus stops are 0.7 mile from the project site and would not be impacted by the project. The project is consistent with this goal.
Goal LU-3,
Policy LU-3.1
Require that new development and
redevelopment incorporate connections and
reduce barriers between neighborhoods,
transit corridors, and activity centers within
the City.
The project’s internal pedestrian circulation network would connect to the existing sidewalk and bicycle facilities along the project frontage on E. Barham Dr. The closest bus stops are 0.7 mile from the project site and would not be impacted by the project. The proposed project is consistent with this policy. The project is consistent with this policy.
Goal LU-3,
Policy LU-3.5
Provide an interconnected open space
system that is accessible to the public,
including pedestrian and equestrian links,
bicycle paths, multi-use trails, recreation
areas, and drainage-ways.
The project incorporates 5.35 acres of common open space. The project incorporates sidewalks on both sides of planned roadways, which connect to the City’s larger pedestrian and bicycle network. There are no public use trails in the project vicinity. The project is consistent with this policy.
Goal LU-5 Promote community design that produces a
distinctive, high-quality built environment
with forms and character that create
memorable places and enrich community
life.
Section 2.3 of the Specific Plan details architectural treatments to ensure a complementary appearance of the structures. The architecture was chosen to complement existing architecture adjacent to the Specific Plan Area. The Specific Plan is included as Appendix A.1 of the EIR. The architecture incorporated with the Hallmark-Barham Specific Plan Area takes inspiration from traditional Spanish Colonial style architecture. Massing and scale provide the visual identity between residential dwelling units and the environment. Those qualities help dictate the placement, size, and form for multi-family residential buildings within the Specific Plan Area. Building type placement within the Specific Plan Area was studied to achieve the best possible groupings as well as providing transition massing between the neighboring mobile homes and industrial structures, thereby
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy enhancing the visual character of the neighborhood. The project is consistent with this goal.
Goal LU-5,
Policy LU-5.4
Require building and site design that
respects the natural topography and iconic
ridgelines that serve as the visual backdrop
for San Marcos.
The project has been designed to respect the existing topography on the site.
Views of the surrounding hillsides would remain unobstructed from SR-78. The project site is not a protected scenic vista nor is it located on a ridgeline. The project also incorporates extensive design features that ensure that the visual character changes blend with the existing topography and surrounding development. The project is consistent with this policy.
Goal LU-5,
Policy LU-5.6
Require a specific plan for strategic
areas/properties that require high-quality
design, orientation, and development due to
their location or visibility within the
community.
The project is processing a new Specific Plan to provide for the cohesive design of the project. The Specific Plan details architectural treatments to ensure consistent, high-quality design. The Specific Plan is included as Appendix A.1 of the EIR. The project is consistent with this policy.
Goal LU-5,
Policy LU-5.7
Architecture shall be enhanced with high-end
building materials, varied roof lines, and
decorative details.
Section 2.3 of the Specific Plan details architectural treatments to ensure a complementary appearance of the structures. The Specific Plan is included as Appendix A.1 of the EIR. The architecture incorporated with the Hallmark-Barham Specific Plan Area takes inspiration from traditional Spanish Colonial style architecture. Elements and materials traditionally used for the Spanish Colonial style include low pitched roofs using “S” tiles, simple forms with stucco walls, fiber cement trim at selected window enhancements, trim at window headers, accent tiles for a decorative look at select gables and select entryways, and decorative sectional garage doors. The architecture was chosen to complement existing architecture adjacent to the Specific Plan Area. The project is consistent with this policy.
Goal LU-7 Direct and sustain growth and expansion in
areas of San Marcos that can support a
concentration of a variety of uses and are
particularly suitable for multimodal
transportation and infrastructure expansion
and improvements.
The project site is within the City of San Marcos, surrounded by existing residential development. Existing services and utilities are present in proximity to the project.
The project is in proximity to transit and provides sidewalks to encourage non- motorized transportation. The project is consistent with this goal.
Goal LU-8 Ensure that existing and future development As described further in Section 3.13 (Public Services), libraries are adequate to
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy is adequately serviced by infrastructure and
public services.
serve the proposed project. Increase in demand for fire and police protection services would be offset with payment of appropriate development fees, including payment of Public Facility Fees (PFF) and annexation into and participation in applicable Community Facilities Districts (CFD). Impacts to parks would be offset through provision of on-site recreational facilities and payment of PFF. Additionally, as analyzed in Section 3.17 (Utilities and Service Systems) water and sewer services are available to serve the project. The project is consistent with this goal.
Goal LU-8,
Policy LU-8.1
New development shall pay its fair share of
required improvements to public facilities
and services.
As described further in Section 3.13 (Public Services), impacts to fire and police protection services would be offset with payment of appropriate CFD and PFF fees.
The project is also required to pay appropriate statutory fees for schools, which would ensure impacts to schools are less than significant. Impacts to parks would be offset through payment of the City's PFF (see Section 3.14, Recreation). The project is consistent with this policy.
Goal LU-8,
Policy LU-8.2
Promote development timing that is guided
by the adequacy of existing and/or
expandable infrastructure, services, and
facilities.
As described further in Section 3.13 (Public Services), impacts to fire and police protection services would be offset with payment of appropriate CFD and PFF fees.
The project is also required to pay appropriate statutory fees for schools, which would ensure impacts to schools are less than significant. Impacts to parks would be offset through payment of the City's PFF (see Section 3.14, Recreation).
Additionally, as analyzed in Section 3.17 (Utilities and Service Systems) water and sewer services are available to serve the project. The project is consistent with this goal.
Goal LU-10 Fire protection, emergency services, and law enforcement: Provide effective, high-quality,
and responsive services.
Based upon correspondence from the San Marcos Fire Department (SMFD) and information from the San Diego Sheriff’s Department, current staff levels are adequate to meet current demand; however, development of the proposed project would increase this demand. Correspondence from SMFD is included in Appendix M of the EIR. To supplement fire and police protection services, the developer would annex into and contribute to applicable CFDs, which would aid in the continued provision of these services. The project is consistent with this goal.
Goal LU-10,
Policy LU-10.1
Provide demand-based fire-fighting and
emergency medical services infrastructure,
equipment, and personnel to provide a high
level of fire, emergency medical, and law
According to correspondence with the San Marcos Fire Department current staff levels are adequate to meet current demand; however, development of the proposed project would increase this demand. Correspondence from SMFD is included in Appendix M of the EIR. To supplement fire protection services, the
3.10 Land Use and Planning
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy enforcement service in San Marcos to meet
existing and future demands.
developer would annex into and contribute to applicable CFDs, which would aid in the continued provision of these services. The project is consistent with this policy.
Goal LU-10,
Policy LU-10.2
Work closely with the County of San Diego
Sherriff’s Department to determine and meet
the community needs for adequate
personnel, equipment, and state-of-the-art
technology to effectively combat crime, and
meet existing and projected service
demands.
Current staff levels at the Sheriff’s Department are adequate to meet current demand; however, development of the proposed project would increase this demand. To supplement police protection services, the developer would participate in an existing Community Facilities District (CFD 98-01, Improvement Area No. 1) for police protection, which would aid in the continued provision of these services. The project is consistent with this policy.
Goal LU-10,
Policy LU-10.3
Continue to conduct Public Outreach and
education regarding fire safety and crime
prevention within San Marcos.
The San Marcos Fire Department public education program provides comprehensive fire education via presentations, informational demonstrations, health fairs, and station tours, among others. The San Diego County Sheriff's Department provides safety presentations to youth groups and community groups through their Community Oriented Policing and Problem Solving (COPPS) deputies.
Deputies also attend Neighborhood Watch meetings. In addition, the Crime Prevention Unit focuses on community outreach regarding crime prevention techniques, current trends, and prevention education. The project's annexation into and contribution to the applicable CFD would aid in the continued provision of these services. The project is consistent with this policy.
Goal LU-11 Schools: Ensure all residents have access to high-quality education.
Based upon information from San Marcos Unified School District (SMUSD), there is available capacity at some of the schools that would serve the project; however, there are District-wide shortages in capacity for SMUSD. The project developer would pay school mitigation fees to offset impacts to schools. The project is consistent with this goal.
Goal LU-11,
Policy LU-11.1
Collaborate with the local public school
district (SMUSD), private schools, and
institutions of higher learning to ensure a
range of traditional and distance-learning
educational opportunities are provided in
superior, accessible facilities that
complement the surrounding land uses.
Based upon information from SMUSD, there is available capacity at some of the schools that would serve the project; however, there are District-wide shortages in capacity for SMUSD. Correspondence from SMUSD is included in Appendix M of the EIR. The project developer would pay school mitigation fees to offset impacts to schools. The project is consistent with this policy.
3.10 Land Use and Planning
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal LU-11,
Policy LU-11.2
Work with San Marcos Unified School District
and developers to ensure adequate school
facilities are funded as required by State law
and through developer mitigation
agreements between the school district and
the developer. The City shall require a “will
serve” letter substantiating that the
developer has paid fees to the satisfaction of
the school district prior to issuance of
building permits.
Based upon information from SMUSD, there is available capacity at some of the schools that would serve the project; however, there are District-wide shortages in capacity for SMUSD. Correspondence from SMUSD is included in Appendix M of the EIR. The project developer would pay school mitigation fees to offset impacts to schools. The project is consistent with this policy.
Goal LU-12 Libraries: Provide library resources and
services that meet the needs of the
community.
While the proposed project does not include construction of any library facilities, this EIR has determined the project would not have a significant impact on library facilities (see Section 3.13, Public Services). The project is consistent with this goal.
Goal LU-12,
Policy LU-12.1
Provide adequate library facilities and
technological access that enhance San
Marcos’s quality of life and create a civic
environment with vast opportunities for self-
learning and academic enrichment.
While the proposed project does not include construction of any library facilities, this EIR has determined the project would not have a significant impact on library facilities (see Section 3.13, Public Services). Additional library resources are also available to the community through CSUSM and Palomar Community College. The project is consistent with this policy.
Goal LU-12,
Policy LU-12.2
Accommodate technology needs of the
community and locate accessible technology
in the library.
While the proposed project does not include construction of any library facilities, project residents would have access to public computers through the existing library facilities. The project does not conflict with this policy.
Goal LU-13 Water Service and Supply: Manage and
conserve domestic water resources by
reducing water usage and waste on a per
capita basis, to ensure an adequate water
supply for existing and future residents.
The landscape plan for the project focuses on low-water use, native species. The Landscape Plan is presented in Figure 2-4a and EIR Appendix A.2. According to the Specific Plan, any landscaping within the Plan area must conform to strict water conservation measures, including the City of San Marcos Water Efficient Landscape Ordinance (WELO). Additionally, the project is required to pay Water Capital Facility Fees to RDDMWD. The project is consistent with this goal.
Goal LU-13,
Policy LU-13.1
Work closely with local and regional water
providers to ensure high quality water
supplies are available for the community.
According to the RDDMWD Urban Water Management Plan (UWMP), water acquired from SDCWA must be treated to meet stringent state and federal standards. Ensuring quality at the source is cheaper than treatment. As described
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy in Section 3.9 (Hydrology/Water Quality), the project would not contribute significant polluted runoff due to the incorporation of bioretention and water quality BMPs. Therefore, the project would not impact any local or regional water supplies. The project is consistent with this policy.
Goal LU-13,
Policy LU-13.2
Actively promote water conservation
programs aimed at reducing demand.
RDDMWD promotes conservation and has issued drought alerts under drought conditions. While not currently in effect, future residential users within this district would be required to comply with any drought alerts and required conservation measures that would reduce demand. The project also incorporates low-water landscaping and will be required to comply with the City’s WELO. The project is consistent with this policy.
Goal LU-13,
Policy LU-13.3
Encourage exploration and use of deep
underground wells to reduce reliance on
treatable water.
The project would irrigate common area slopes, public/private open space, and right-of-way landscaping with potable water. Groundwater use is not proposed by the project. According to the Specific Plan, any landscaping within the Plan area must conform to strict water conservation measures, including the City of San Marcos WELO. The project is consistent with this policy.
Goal LU-14 Wastewater: Ensure an adequate
wastewater system for existing and future
development.
Based on the analysis in Section 3.17 (Utilities and Service Systems), there is currently adequate wastewater treatment capacity to serve the project. VWD identified existing system deficiencies in pipe segments HB-29 through HB-31, as well as in capacity for solids handling, liquids handling, ocean disposal and parallel land outfall’s capacity for ultimate build-out wastewater flows. Expansion of existing wastewater facilities would be necessary to accommodate buildout of the VWD services area per the 2018 Master Plan. The project would offset its contribution to conveyance impacts plus the increase in demand through the payment of Wastewater Capital Facility Fees to VWD. The project is consistent with this goal.
Goal LU-14,
Policy LU-14.1
Work closely with local service providers to
ensure an adequate wastewater system for
existing and future development is in place.
The City has coordinated with VWD during the preparation of this EIR. Based up on the analysis in Section 3.17 (Utilities and Service Systems) and communication from VWD, there is currently adequate wastewater treatment capacity to serve the project. Expansion of existing wastewater facilities would be necessary to accommodate buildout of the VWD services area per the 2018 Master Plan. The project would offset its contribution to conveyance impacts plus the increase in demand through the payment of Wastewater Capital Facility Fees to VWD. The
3.10 Land Use and Planning
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 3.10-36
General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy project is consistent with this goal.
Goal LU-14,
Policy LU-14.2
Ensure development approval is directly tied
to commitments for the construction or
improvement of primary water, wastewater,
and circulation systems.
Based on the analysis in Section 3.17 (Utilities and Service Systems), there is currently adequate water and wastewater treatment capacity to serve the project.
Expansion of existing wastewater facilities would be necessary to accommodate buildout of the VWD services area per the 2018 Master Plan. The project would mitigate its contribution to conveyance impacts plus the increase in demand through the payment of Water Capital Facility Fees to RDDMWD and Wastewater Capital Facility Fees to VWD. The project is consistent with this policy.
Goal LU-15 Flood control and storm water drainage
facilities: ensure adequate flood control and
storm water drainage is provided by the
community.
As identified in Section 3.9 (Hydrology/Water Quality), off-site runoff is projected to be less than pre-development conditions with implementation of the project. No on-site or downstream flooding hazard is identified. Therefore, implementation of the project would not impact flood control or storm water drainage facilities. The project is consistent with this goal.
Goal LU-15,
Policy LU-15.1
Implement activities, practices, procedures,
or facilities that avoid, prevent, or reduce
pollution of the San Marcos Storm Water
Conveyance System and receiving waters.
As identified in Section 3.9 (Hydrology/Water Quality), implementation of the project’s comprehensive water quality management plan, which incorporates biofiltration and BMPs, would ensure the project would treat runoff containing the pollutants of concern for locally impaired water bodies. Implementation of the project would reduce pollutants entering the San Marcos Storm Water Conveyance System and receiving waters. The project is consistent with this policy.
Goal LU-15,
Policy LU-15.2
Improve inadequate or undersized
drainage/flood control facilities to solve both
small neighborhood and large regional
drainage and flood control problems.
As identified in Section 3.9 (Hydrology/Water Quality), off-site runoff is projected to be less than pre-development conditions with implementation of the project. No on-site or downstream flooding hazard is identified. No inadequate or undersized drainage/ flood control facilities were identified that serve the project area.
Therefore, implementation of the project would not impact flood control or storm water drainage facilities. The project is consistent with this policy.
Goal LU-15,
Policy LU-15.3
Avoid, to the extent possible, development in
floodplain and flood prone areas.
As identified in the Initial Study prepared for the proposed project (Appendix B.1), the project was determined to have no impact on 100-year flood hazards. The project does not propose development within a floodplain or flood prone area. The project is consistent with this policy.
Goal LU-15, Retain drainage courses in their natural The project is adequately designed such that it would not substantially alter the
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Policy LU-15.4 condition, to the extent possible. Consider smaller-scale drainage improvements to
protect the environment and avoid disturbing
natural drainage courses; consider detention
areas and raised building pads.
existing drainage pattern of the site or area. The project detains and retains runoff through the site with combined water quality and hydromodification bioretention and BMPs. The project is consistent with this policy.
Goal LU-16 Solid waste: reduce the amount of waste
material entering regional landfills with an
efficient and innovative waste management
program.
As discussed in Section 3.17 (Utilities and Service Systems), the City of San Marcos has a disposal rate target of 8.9 lbs/person/day. If the City meets this target, the City is considered in compliance with the 50 percent diversion requirement of AB 939. The most recent data (2019) from CalRecycle identifies the annual per capital disposal rate for the City of San Marcos is 5.0 lbs/person/day. Thus, the City is exceeding their current targets for diversion. In accordance with AB 34, the project would be required to achieve a 75 percent waste diversion rate. All green waste will be diverted from landfills and recycled as mulch. The Sycamore Sanitary Landfill has sufficient permitted capacity to accommodate the project's solid waste disposal needs. The project is consistent with this goal.
Goal LU-16,
Policy LU-16.1
Work closely with local service providers to
ensure adequate solid waste disposal,
collection, and recycling services.
Non-recyclable waste, including general trash and green materials, would be collected and transported for disposal by EDCO, a licensed hauler. According to Section 3.17 (Utilities and Service Systems), the Sycamore Sanitary Landfill has sufficient permitted capacity to accommodate the project's solid waste disposal needs. In accordance with AB 34, the project would be required to achieve a 75 percent waste diversion rate. All green waste will be diverted from landfills and recycled as mulch. The project is consistent with this policy.
Goal LU-16,
Policy LU-16.2
Increase recycling, composting, source
reduction, and education efforts throughout
the city to reduce the amount of solid waste
requiring disposal at landfills.
The City of San Marcos is in compliance with AB 939, which requires 50 percent waste diversion through recycling. The project is consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Mobility Element
Goal M-1 Provide a comprehensive multimodal
circulation system that serves the City land
uses and provides for the safe and effective
movement of people and goods.
Vehicular, bicycle, and pedestrian circulation within the Hallmark-Barham Specific Plan Area features a main circulation driveway, which allows free movement through the Plan area. The private driveway accesses Hallmark-Barham Specific Plan from Barham Drive to the north via two entry points; one located on the eastern end of the Plan area and another located at the western end of the Plan area. The private driveway loops through the northern half of the Specific Plan Area and connects the southern portion of the Plan area via a short north-south connection at the center of the Specific Plan Area. All internal alleys connect to the main driveway. The private internal driveway paved surface area within the Specific Plan will be a minimum of 26 feet in width. Alleys within the Specific Plan Area will be a minimum of 20 feet in width. All sidewalks within the Specific Plan Area will be a minimum of 5 feet in width and will allow for an accessible path of travel from each building to a sidewalk connection in the Barham Drive right-of- way. Sidewalks adjacent to perpendicular parking spaces feature a minimum of 6’ of width to accommodate vehicle overhang. The project is consistent with this goal.
Goal M-1,
Policy M-1.1
Safely and efficiently accommodate traffic
generated by development and
redevelopment associated with
implementation of the General Plan Land
Use Policy Map.
Implementation of the proposed project is anticipated to result in traffic impacts that would increase LOS and/or delay on project-area roadways in the existing, near term (Year 2025), and horizon year 2050 conditions. Mitigation measures, as identified in Section 3.10.6 (Land Use and Planning) would ensure project-area roadways would not experience a substantial increase in traffic. Project-related impacts would be reduced to below a level of significance with incorporation of these mitigation measures with the exception of the Rancheros Drive/ SR-78 WB Ramps during Near Term 2025 conditions. A traffic signal is warranted at this intersection and is assumed to be in place by 2050 but because the intersection is located outside the jurisdiction of the City, the impact is considered significant and unavoidable. However, inter-agency coordination is expected and impacts would be less than significant in the horizon year. Because the impact is considered significant and unavoidable in the near term, implementation of the project would be inconsistent with this policy.
Goal M-1, Require new development to finance and The project has been designed to include private streets. The project applicant will
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Policy M-1.2 construct internal adjacent roadway
circulation and City-wide improvements as
necessary to mitigate project impacts,
including roadway, transit, pedestrian, and
bicycle facilities.
build and maintain the private streets. Additionally, due to off-site traffic impacts resulting from development of the proposed project, the developer would be required to mitigate as described in Section 3.10.6 (Land Use and Planning).
Therefore, the project is consistent with this policy.
Goal M-1,
Policy M-1.4
Utilize multi-modal LOS techniques to
evaluate transportation facilities. For
identified prioritized modes (based on facility
typology), provide the following minimum
LOS as shown in Table 3-4 of the Mobility
Element: LOS D or better for Vehicles as a
prioritized mode or the City shall allow for
flexible LOS where warranted (e.g., accepting
a lower LOS than identified above).
The location transportation analysis prepared for the project relied on this LOS technique to determine project-related impacts to the circulation network. As summarized in Section 3.10.4 (Land Use and Planning) of this EIR, project-related impacts resulting in a degradation of LOS to below acceptable levels would occur at three study area intersections during two scenarios. Project-related impacts would be reduced to below a level of significance with incorporation of mitigation measures provided in Section 3.10.6 (Land Use and Planning). However, the Rancheros Drive/SR-78 WB Ramps is located outside of the City’s jurisdiction so neither the developer nor the City can ensure that Caltrans will permit the improvement that is required. Based on regional standards of practice, the near- term direct project impacts at this location would be considered significant and unavoidable for the purposes of CEQA. However, inter-agency coordination is expected and impacts would be less than significant in the horizon year. Because the impact is considered significant and unavoidable in the near term, implementation of the project would be inconsistent with this policy.
Goal M-1,
Policy M-1.6
Work to improve connectivity within the City
by closing gaps in the existing bicycle,
pedestrian, trail, transit, and roadway
network. Work with new development to
provide connectivity and redundancy in the
mobility network.
Streets proposed for the internal circulation network of the proposed project include sidewalks that would connect to the existing pedestrian and bicycle network. The project is consistent with this policy.
Goal M-1,
Policy M-1.7
Strive to ensure that streets within San
Marcos shall be complete streets where
feasible; thereby providing accessibility,
safety, connectivity, and comfort for all
modes and users of the system. Appropriate
new local streets and Main Streets will
Complete streets balance the needs of all users, both motorized and non- motorized, in design and construction. Streets proposed for the internal circulation network of the proposed project include sidewalks that would connect with the existing pedestrian and bicycle network. Therefore, the project is consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy prioritize pedestrian and bicycle users
through the corridor.
Goal M-2 Protect neighborhoods by improving safety
for all modes of travel and calming traffic
where appropriate.
Travel modes within and surrounding the project area include vehicular, pedestrian, and bicycle. Streets proposed for the internal circulation network of the proposed project include sidewalks that would connect to the existing pedestrian and bicycle network. Internal traffic calming measures such as speed limit signs and stop signs may be provided to improve the overall safety of circulation within the Specific Plan Area. The provision of these amenities improves safety for pedestrians and cyclists. The project is consistent with the goal.
Goal M-2,
Policy M-2.1
Work with new development to design
roadways that minimize traffic volumes
and/or speed, as appropriate within
residential neighborhoods; while maintaining
the City’s desire to provide connectivity on
the roadway network.
Streets proposed for the internal circulation network of the proposed project include sidewalks that would connect to the existing pedestrian and bicycle network. Roadways have been designed per City of San Marcos requirements and are consistent with the City’s Mobility Element. Therefore, the project is consistent with this policy.
Goal M-2,
Policy M-2.3
Consider roundabouts, as appropriate, as an
intersection control device with
demonstrated air quality, traffic efficiency,
and safety benefits.
Streets internal to the project do not have enough traffic volumes to warrant a traffic circle. Internal traffic calming measures such as speed limit signs and stop signs may be provided to improve the overall safety of circulation within the Specific Plan Area. The provision of these amenities improves safety for pedestrians and cyclists. The project is consistent with this policy.
Goal M-3 Promote and encourage use of alternative
transportation modes, including transit,
bicycles, neighborhood electric vehicles
(NEVs), and walking, within the City.
Streets proposed for the internal circulation network of the proposed project include sidewalks that would connect to the existing pedestrian and bicycle network. The closest bus stops are 0.7 mile from the project site and would not be impacted by the project. As a design feature, the project would install three Level 2 electric vehicle (EV) charging stations. The project will also wire each garage for EV charging stations. Therefore, the project is consistent with this goal.
Goal M-3,
Policy M-3.1
Develop an integrated, multimodal
circulation system that accommodates
transit, bicycles, pedestrians, and vehicles;
provides opportunities to reduce air pollution
and greenhouse gas emissions; and
Streets proposed for the internal circulation network of the proposed project include sidewalks that would connect to the existing pedestrian and bicycle network. Therefore, the project is consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy reinforces the role of the street as a public
space that unites the City.
Goal M-3,
Policy M-3.2
Improve safety conditions, efficiency, and
comfort for bicyclists and pedestrians
through design, maintenance, and law
enforcement. Install wider sidewalks and
curb extensions at pedestrian crossings
(bulb outs) where appropriate.
Streets proposed for the internal circulation network of the proposed project include sidewalks that would connect to the existing pedestrian and bicycle network. Vehicular, bicycle, and pedestrian circulation within the Specific Plan Area features a main circulation driveway, which allows free movement through the Plan area. All internal alleys connect to the main driveway. The private internal driveway paved surface area within the Specific Plan will be a minimum of 26 feet in width.
Alleys within the Specific Plan Area will be a minimum of 20 feet in width. All sidewalks within the Specific Plan Area will be a minimum of 5 feet in width and will allow for an accessible path of travel from each building to a sidewalk connection in the Barham Drive right-of-way. Sidewalks adjacent to perpendicular parking spaces feature a minimum of 6 feet of width to accommodate vehicle overhang. Internal traffic calming measures such as speed limit signs and stop signs may be provided to improve the overall safety of circulation within the Specific Plan Area. The provision of these amenities improves safety for pedestrians and cyclists. Therefore, the project is consistent with this policy.
Goal M-3,
Policy M-3.3
Provide a pedestrian and bicycle network in
existing and new neighborhoods that
facilitates convenient and continuous
pedestrian and bicycle travel free of major
impediments and obstacles.
Streets proposed for the internal circulation network of the proposed project include sidewalks that would connect to the existing pedestrian and bicycle network. Therefore, the project is consistent with this policy.
Goal M-3,
Policy M-3.5
Ensure that streets in areas with high levels
of pedestrian activity (such as employment
centers, residential areas, mixed use areas,
and schools) support safe pedestrian travel
by providing detached sidewalks, bulb-outs,
enhanced pedestrian crossings, pedestrian
bridges, and medians.
The project is not located in an area with high levels of pedestrian activity; however, streets proposed for the internal circulation network of the proposed project include sidewalks that connect to the existing sidewalks and bike lane along the project frontage. Therefore, the project is consistent with this policy.
Goal M-3,
Policy M-3.9
Create a pleasant walking environment for
roadway typologies where pedestrian travel
is prioritized. This includes providing shade
The project is not located in an area with high levels of pedestrian activity; however, streets proposed for the internal circulation network of the proposed project include sidewalks that connect to the existing sidewalks and bike lane
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy trees, landscaping, benches, pedestrian-
scale lighting, way finding signage, transit
shelters, and other appropriate amenities.
along the project frontage. The landscape plan includes guidelines for landscape plantings in locations such as entries, streetscapes, and common open space areas. According to the Specific Plan, lighting within the project site would provide safety and accent lighting for vehicles and pedestrians. project is consistent with this policy.
Conservation and Open Space Element
Goal COS-1 Identify, protect, and enhance significant
ecological and biological resources within
San Marcos and its adaptive Sphere of
Influence.
A biological resources study (Appendix E.1) was prepared for the project to identify significant resources on the project site. The study identified direct impacts to sensitive wildlife species and sensitive habitats. Mitigation measures proposed for the project would reduce these impacts to below a level of significance. See Section 3.3 (Biological Resources) of the EIR for a description of the biological mitigation measures. The project is consistent with this goal.
Goal COS-1,
Policy COS-1.1
Support the protection of biological
resources through the establishment,
restoration, and conservation of high-quality
habitat areas.
The project would result in a direct impact to sensitive habitats, including Diegan coastal sage scrub, Diegan coastal sage scrub – Baccharis dominated and non- native grassland. This impact would be mitigated to below a level of significance through on-site preservation, off-site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the Planning Manager at a 1:1 2:1 ratio for the Diegan coastal sage scrub and Diegan coastal sage scrub – Baccharis dominated habitats and at a 0.5:1 ratio for non- native grassland. Proof of onsite preservation, off-site acquisition, payment of in lieu fees, purchase of credits from an approved mitigation bank or a combination thereof shall be provided to the Planning Manager prior to issuance of a grading permit. The project is consistent with this policy.
Goal COS-1,
Policy COS-1.2
Ensure that new development, including
Capital Improvement Projects, maintain the
biotic habitat value of riparian areas, oak
woodlands, habitat linkages, and other
sensitive biological habitats.
No oak woodlands, jurisdictional wetlands, or habitat linkages occur on the project site. The project would impact sensitive coastal sage scrub and non-native grassland communities. Mitigation measures identified for the project would reduce impacts to these communities to below a level of significance. See Section
3.3 (Biological Resources) of the EIR for a description of the biological resource mitigation measures. The project is consistent with this policy.
Goal COS-2 The City is committed to conserving,
protecting, and maintaining open space,
The project would result in a direct impact to sensitive habitats, including Diegan coastal sage scrub, Diegan coastal sage scrub – Baccharis dominated and non-
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy agricultural, and limited resources for future
generations. By working with property
owners, local organizations, and state and
federal agencies, the City can limit the
conversion of resource lands to urban uses.
native grassland. This impact would be mitigated to below a level of significance through on-site preservation, off-site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the Planning Manager at a 1:1 2:1 ratio for the Diegan coastal sage scrub and Diegan coastal sage scrub – Baccharis dominated habitats and at a 0.5:1 ratio for non- native grassland. Proof of onsite preservation, off-site acquisition, payment of in lieu fees, purchase of credits from an approved mitigation bank or a combination thereof shall be provided to the Planning Manager prior to issuance of a grading permit. The project is consistent with this policy.
Goal COS-2,
Policy COS-2.1
Provide and protect open space areas
throughout the City for its recreational,
agricultural, safety, and environmental value.
There are two main categories of open space proposed for the project – common open space and private open space. Common open space will total approximately
5.35 acres and includes open space with grades 10 percent and greater, common open space with grades less than ten percent, the water quality basin, and recreational areas. The project site has no agricultural value as the site was never used for agriculture. The project is consistent with this policy.
Goal COS-2,
Policy COS-2.2
Limit, to the extent feasible, the conversion
of open space to urban uses and place a
high priority on acquiring and preserving
open space lands for recreation, habitat
protection and enhancement, flood hazard
management, water and agricultural
resources protection, and overall community
benefit.
The project site is currently undeveloped but is in a developed area and is not being used as open space. There are two main categories of open space proposed for the project – common open space and private open space. Common open space will total approximately 5.35 acres and includes open space with grades 10 percent and greater, common open space with grades less than ten percent, the water quality basin, and recreational areas. There are no flood hazards management issues with the project. Water supply and resources were addressed in Section 3.17 (Utilities and Service Systems) and it was concluded that there is adequate potable water service to serve the project. The project also incorporates low-water landscaping and will be required to comply with the City’s WELO. The project is consistent with this policy.
Goal COS-2,
Policy COS-2.5
Continue to review future development
proposals to ensure that cultural resources
(including prehistoric, historic,
paleontological, and SB 18 Tribal resources)
are analyzed and conserved in compliance
with CEQA requirements.
The proposed project’s potential impacts to cultural resources are detailed in Section 3.4 (Cultural Resources) of the EIR. A cultural resources report was also prepared for the project and is included as Appendix F of the EIR. The City reached out to tribes consistent with the requirements of SB 18 and AB 52 and met with tribes that requested consultation. An archaeological significance evaluation (Appendix F.2) for a historic site, Barham-2020-ASM-HD-01, discovered during the
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy cultural resources inventory for the proposed project was also conducted and concluded the historical resources identified on site would not meet the criteria for listing in CRHR. The project will not impact any known cultural and/or historical resources on the project site; however, there is a potential to impact resources that are unknown at this time. Mitigation measures are incorporated into the EIR (MM-CR-1a through MM-CR-1c and MM-CR-2) to reduce impacts to cultural resources to below a level of significance. The project is consistent with this policy.
Goal COS-2,
Policy COS-2.6
Preserve healthy mature trees where
feasible; where removal is necessary, trees
shall be replaced at a ratio of 1:1.
No existing trees are proposed for removal. The proposed landscape plan is included as Figure 2-4a and the plant material guide is included as Figure 2-4b.
Proposed tree species include desert willow, majestic beauty Indian hawthorn, California laurel, columnar Italian cypress, fern pine, western redbud, European olive, Mexican palo verde, African suman, strawberry tree, flaxleaf paperbark, and date palms. See Figure 2-4b for a comprehensive list of proposed plant materials.
The project is consistent with this policy.
Goal COS-3 Protect natural topography to preserve and
enhance the natural beauty of San Marcos.
According to Section 3.1 (Aesthetics), the project has been designed to respect the existing topography on the site. Views of the surrounding hillsides would remain unobstructed from SR-78. The project site is not a protected scenic vista. The project also incorporates extensive design features that ensure that the visual character changes blend with the existing topography and surrounding development. The project is consistent with this goal.
Goal COS-3,
Policy COS-3.1
Preserve scenic resources, including
prominent landforms such as Double Peak,
Owens Peak, San Marcos Mountains,
Merriam Mountains, Cerro de Las Posas,
Franks Peak, and canyon areas through
conservation and management policies.
None of the prominent landforms as identified in the General Plan are on-site.
While implementation of the proposed project would result in changes in the viewshed, development would not alter or impede views of prominent landforms.
Views to prominent landforms would remain unobstructed. In addition, the project site is not a protected scenic vista. The project is consistent with this policy.
Goal COS-3,
Policy COS-3.2
Encourage and maintain high-quality
architectural and landscaping designs that
enhance or complement the hillsides,
ridgelines, canyons, and view corridors that
comprise the visual character in San Marcos.
According to Section 3.1 (Aesthetics), the Specific Plan includes an overall architectural design theme to ensure a pleasant, orderly, and visually appealing neighborhood. The architectural guidelines include a variety of elevation treatments, varied front yard setbacks, and enhanced side and rear elevations for select homes. The project has been designed to respect the existing topography on the site. Landscape materials will be used to enhance and accentuate key site and
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy architectural elements, frame views, provide a visually stimulating site element.
Plant material will be chosen for its appropriateness to scale, performance in the region, drought tolerance, and suitability of use. The project is consistent with this policy.
Goal COS-3,
Policy COS-3.3
Continue to work with new development and
redevelopment project applicants in
designing land use plans that respect the
topography, landforms, view corridors,
wildlife corridors, and open space that exists.
The project has been designed to respect the existing topography; A grading variance is required for projects including slopes that exceed 20 feet in height without benching. Areas where slopes are proposed to be greater than 20 feet include the southern extent of development (31.6-foot maximum slope height), a small area on the western edge of the project site (25.8-foot maximum slope height) and a portion of the project frontage with E. Barham Drive (22.8-foot maximum slope height with 6-foot retaining wall). Figure 2-11 depicts the areas that are proposed to have manufactured slopes without benching in excess of 20 feet in height. Approval of a grading variance allows for reduced grading and lower overall slope heights due to the removal of benching. No Wildlife movement corridors have been identified on the project site. Finally, the project site is not a protected scenic vista. The project is consistent with this policy.
Goal COS-3,
Policy COS-3.4
Evaluate potential impacts to visual and
aesthetic resources, including the potential
to create new light sources, while still
maintaining and being sensitive to rural
lighting standards.
Development of the proposed project would create new sources of light at a site that is currently undeveloped. Lighting will be guided by the City of San Marcos Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080, Light and Glare Standards to aid in the preservation of dark sky conditions. The Specific Plan requires all lighting to minimize glare, conflict, and light pollution while providing illumination levels that create a safe environment for vehicles and pedestrians. Lighting impacts were determined to be less than significant (Section 3.1 Aesthetics). The project is consistent with this policy.
Goal COS-4 Improve regional air quality and reduce GHG
emissions that contribute to climate change.
The project’s impacts to air quality would be less than significant as described in Section 3.2 (Air Quality) of this EIR. The project would not conflict with or obstruct implementation of any air quality plan or violate any air quality standard. Based upon the analysis in Section 3.7 (Greenhouse Gas), GHG emissions under the proposed project would be 70% less than if the project was built out under the current General Plan Designation of MU3. The project will also implement all of the applicable CAP Consistency Review Checklist (CAP Checklist) measures. The
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy project is consistent with this goal.
Goal COS-4,
Policy COS-4.1
Continue to work with the U.S. EPA, CARB,
SANDAG, and the SDAPCD to meet State and
federal ambient air quality standards.
Implementation of the proposed project would not exceed any air quality standard during construction or operation. Impacts are less than significant. The project is consistent with this policy.
Goal COS-4,
Policy COS-4.3
Participate in regional efforts to reduce GHG
emissions.
The project is not anticipated to impair implementation of AB 32. Development of the project would not affect regional efforts to reduce GHG emissions. The City’s updated 2020 CAP quantifies community emissions, identifies emission reduction targets, and specifies climate action measures to reduce GHG emissions. Based upon the analysis in Section 3.7 (Greenhouse Gas), GHG emissions under the proposed project would be 70% less than if the project was built out under the current General Plan Designation of MU3. The project will also implement all of the applicable CAP Checklist measures. The project is consistent with this policy. The project is therefore consistent with the City’s CAP and the project would be consistent with the goals of AB32. The project is consistent with this policy.
Goal COS-4,
Policy COS-4.4
Quantify community-wide and municipal GHG
emissions, set a reduction goal, identify and
implement measures to reduce GHG
emissions as required by governing
legislation.
The City’s updated 2008 CAP quantifies community emissions, identifies emission reduction targets, and specifies climate action measures to reduce GHG emissions. Based upon the analysis in Section 3.7 (Greenhouse Gas), GHG emissions under the proposed project would be 70% less than if the project was built out under the current General Plan Designation of MU3. The project will also implement all of the applicable CAP Checklist measures. The project is therefore consistent with the City’s CAP and the project would be consistent with the goals of AB32. The project is consistent with this policy.
Goal COS-4,
Policy COS-4.5
Encourage energy conservation and the use
of alternative energy sources within the
community.
As discussed in Section 3.17 (Utilities and Service Systems), the proposed project includes various on-site features and measures to reduce the proposed project’s energy consumption. Further, the proposed project would be required to be consistent with appropriate mandatory project design feature in the CAP Checklist that would reduce operational electricity consumption (details are provided in Appendix H.1 of this EIR) and would-be built-in compliance with Title 24 requirements applicable at that time. Based on the 2019 standards, homes built under the 2019 Title 24 standards would use about 53% less energy than those under the 2016 Title 24 standards. On the residential side, the standards also
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy encourage demand responsive technologies including battery storage and heat pump water heaters and improve the building thermal envelope.
Additionally, as a design feature, the project would install three Level 2 EV charging stations. The project will also wire each garage for EV charging stations.
The project has also been designed to meet current California Building Code requirements as related to green building practices. The project is consistent with this policy.
Goal COS-4,
Policy COS-4.6
Promote efficient use of energy and
conservation of available resources in the
design, construction, maintenance and
operation of public and private facilities,
infrastructure, and equipment.
As discussed in Section 3.17 (Utilities and Service Systems), the proposed project includes various on-site features and measures to reduce the proposed project’s energy consumption. Further, the proposed project would be required to be consistent with appropriate mandatory project design feature in the CAP Consistency Worksheet that would reduce operational electricity consumption (details are provided in Appendix H.1 of this EIR) and would-be built-in compliance with Title 24 requirements applicable at that time. Based on the 2019 standards, homes built under the 2019 Title 24 standards would use about 53% less energy than those under the 2016 Title 24 standards. On the residential side, the standards also encourage demand responsive technologies including battery storage and heat pump water heaters and improve the building thermal envelope.
Additionally, as a design feature, the project would install three Level 2 EV charging stations. The project will also wire each garage for EV charging stations.
The project has also been designed to meet current California Building Code requirements as related to green building practices. The project is consistent with this policy.
Goal COS-4,
Policy COS-4.8
Encourage and support the generation,
transmission, and use of renewable energy.
Future homes would meet the requirements of California’s Building Energy Efficiency Standards, which focus on several key areas to improve the energy efficiency of newly constructed buildings. The project has also been designed to meet current California Building Code requirements as related to green building practices. The project is consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal COS-5 Reduce water consumption and ensure
reliable water supply through water
efficiency, conservation, capture, and reuse.
RDDMWD promotes conservation and has issued drought alerts under drought conditions. Future residential users within this district would be required to comply with any issued alerts and required conservation measures that would reduce demand. The project proposes a landscape plan that emphasizes low-water use species in adherence to the City of San Marcos Water Efficient Landscape Ordinance. The project is consistent with this goal.
Goal COS-6 Protect and restore appropriate surface
water and groundwater beneficial uses
through prioritizing the improvement of
locally impaired water bodies within the City
of San Marcos subwatersheds.
The project is located within a watershed with numerous impaired water bodies.
The BMP Design Manual requires that pollutants of concern for each impaired water body in the watershed be treated by engineered treatment controls to a medium pollutant removal efficiency or better prior to leaving the project site. The project proposes treatment of storm water runoff via biofiltration facilities prior to discharge, which would result in a medium or high efficiency for removal of the pollutants of concern. Any groundwater infiltration would likely reach surface flows before reaching groundwater due to the approximate depth to groundwater.
Therefore, according to Section 3.9 (Hydrology/Water Quality), the project would not have a potentially significant adverse impact on groundwater quality or result in significant impacts to impaired water bodies. The project is consistent with this goal.
Goal COS-6,
Policy COS-6.2
Promote watershed stewardship as the
community norm.
The project includes a comprehensive water quality management approach, which incorporates biofiltration and the use of Best Management Practices (BMPs), to ensure the project would not contribute any pollutants to area watersheds.
Additionally, the project proponent would obtain a General Construction Activity Stormwater Permit, prepare a Stormwater Pollution Prevention Plan, and implement BMPs in compliance with the National Pollution Discharge Elimination System (NPDES) permit. Erosion and sediment control and non-stormwater management measures implemented as required under these permits would contribute to watershed stewardship. The project is consistent with this policy.
Goal COS-7 Achieve sustainable watershed protection for surface and ground water quality that
balances social, economical, and
environmental needs.
The project includes a comprehensive water quality management approach, which incorporates biofiltration and the use of BMPs, to ensure the project would not contribute any pollutants to area watersheds. Additionally, the project proponent would obtain a General Construction Activity Stormwater Permit, prepare a SWPPP, and implement BMPs in compliance with the NPDES permit. Erosion and sediment
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy control and non-stormwater management measures implemented as required under these permits would contribute to watershed stewardship. The project is consistent with this policy.
Goal COS-8 Focus watershed protection, surface and
groundwater quality management on sources
and practices that the City has the ability to
affect.
Implementation of the project’s comprehensive water quality management plan, which incorporates biofiltration and the use of BMPs, would ensure the project would treat runoff containing the pollutants of concern for locally impaired water bodies. Additionally, the project proponent would obtain a General Construction Activity Stormwater Permit, prepare a SWPPP, and implement BMPs in compliance with the NPDES permit. Erosion and sediment control and non-stormwater management measures implemented as required under these permits would reduce construction effects on receiving water quality and protect stormwater runoff. The project is consistent with this policy.
Goal COS-8,
Policy COS-8.4
Require new development and
redevelopment to protect the quality of water
bodies and natural drainage systems
through site design, source controls, storm
water treatment, runoff reduction measures,
BMPs, LID, hydromodification strategies
consistent with the Current San Diego
RWQCB Municipal Stormwater NPDES
Permit, and all future municipal stormwater
permits.
Implementation of the project’s comprehensive water quality management plan, which incorporates biofiltration and the use of BMPs, would ensure the project would treat runoff containing the pollutants of concern for locally impaired water bodies. Additionally, the project proponent would obtain a General Construction Activity Stormwater Permit, prepare a SWPPP, and implement BMPs in compliance with the NPDES permit. Erosion and sediment control and non-stormwater management measures implemented as required under these permits would reduce construction effects on receiving water quality and protect stormwater runoff. The project is consistent with this policy.
Goal COS-10 Establish and maintain an innovative,
sustainable solid waste collection, recycling,
and disposal delivery system for present and
future generations.
As discussed in Section 3.17 (Utilities and Service Systems), according to CalRecycle, the City of San Marcos has a disposal rate target of 8.9 lbs/person/day. If the City meets this target, the City is considered in compliance with the 50 percent diversion requirement of AB 939. The most recent data (2019) from CalRecycle identifies the annual per capital disposal rate for the City of San Marcos is 5.0 lbs/person/day. Thus, the City is exceeding their current targets for diversion.
In accordance with AB 34, the project would be required to achieve a 75 percent waste diversion rate. All green waste will be diverted from landfills and recycled as
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy mulch. The Sycamore Sanitary Landfill has sufficient permitted capacity to accommodate the project's solid waste disposal needs. The project is consistent with this goal.
Goal COS-10,
Policy COS-
10.1 Promote the curbside recycling program to
divert residential refuse from the landfills.
The City of San Marcos is in compliance with AB 939, which requires 50 percent waste diversion through recycling. The project would participate in the City’s recycling efforts. The project is consistent with this policy.
Goal COS-11 Continue to identify and evaluate cultural, historic, archaeological, paleontological, and
architectural resources for protection from
demolition and inappropriate actions.
A cultural resources report and archaeological significance evaluation were prepared for the project site, summarized in this Section 3.4 (Cultural Resources) of the EIR, and is included as Appendix F of the EIR. Mitigation measures are incorporated into the EIR (MM-CR-1a through MM-CR-1c and MM-CR-2) to reduce impacts to cultural resources to below a level of significance. The project is consistent with this goal.
Goal COS-11,
Policy COS-
11.1 Identify and protect historic and cultural
resources including individual properties,
districts, and sites (e.g., archaeological sites)
in compliance with CEQA.
Based upon the cultural resources report prepared for the project, several historic remnants were identified on site associated with an early twentieth-century agricultural homestead. These resources were documented via the appropriate DPR forms and are included in Appendix D of the cultural resources report (Appendix F1 of this EIR) and an archaeological significance evaluation was conducted to determine eligibility for listing in the CRHR. The evaluation concluded that the site would not be eligible for listing and the site is not considered historically significant. However, mitigation measures described in Section 3.4.6 (Cultural Resources) would ensure impacts would be less than significant for any unknown subsurface archaeological resources that could be encountered during project grading and construction. The project is consistent with this policy.
Goal COS-11,
Policy COS-
11.2 Prohibit the demolition or removal of a
historic structure without evaluation of the
condition of the structure, the cost of
rehabilitation, and the feasibility of
alternatives to preservation in place
including but not limited to relocation, or
reconstruction offsite, and/or photo-
preservation.
Based upon the cultural resources and archaeological significance evaluation reports prepared for the project, the remnants associated with an early twentieth- century agricultural homestead were determined not to be significant resources.
Therefore, there are no historic structures on-site. However, mitigation measures described in Section 3.4.6 (Cultural Resources) would ensure impacts would be less than significant for any unknown subsurface archaeological resources that could be encountered during project grading and construction. The project is consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Parks, Recreation and Community Health Element
Goal PR-1 Plan for, acquire, develop, and maintain a
system of local parks connected through an
integrated network of trails and high quality
recreational facilities.
Section 3.14 (Recreation) analyzed the project’s impacts to recreation. The proposed project would result in an increase in the City of San Marcos population by approximately 469 residents. The additional residents would require approximately 2.35 acres of new park space to fulfill the City’s General Plan requirement of five acres of park space per every 1,000 residents. The proposed project would be required to pay the City’s PFF, to go towards the acquisition and development of local and community park facilities throughout the City in addition to what is provided on-site. The project includes 82,419 s.f. (1.89 acres) of common useable open space and 26,390 s.f. (0.61 acres) of private open space.
With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this goal.
Goal PR-1,
Policy PR-1.1
Develop and maintain a complete system of
public parks and recreational amenities that
provide opportunities for passive and active
recreation at a minimum standard of 5 acres
per 1,000 residents. Parks, trails, and
recreational facilities will enhance
community livability, public health, and
safety; should be equitably distributed
throughout the City; and be responsive to the
needs and interests of residents, employees,
and visitors.
Section 3.14 (Recreation) analyzed the project’s impacts to recreation. The proposed project would result in an increase in the City of San Marcos population by approximately 469 residents. The additional residents would require approximately 2.35 acres of new park space to fulfill the City’s General Plan requirement of five acres of park space per every 1,000 residents. The proposed project would be required to pay the City’s PFF, to go towards the acquisition and development of local and community park facilities throughout the City in addition to what is provided on-site. The project includes 82,419 s.f. (1.89 acres) of common useable open space and 26,390 s.f. (0.61 acres) of private open space.
With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.
Goal PR-1,
Policy PR-1.3
Ensure that the development of parks, trails,
and recreation facilities and services keeps
pace with development and growth within
the City.
Section 3.14 (Recreation) analyzed the project’s impacts to recreation. The proposed project would result in an increase in the City of San Marcos population by approximately 469 residents. The additional residents would require approximately 2.35 acres of new park space to fulfill the City’s General Plan requirement of five acres of park space per every 1,000 residents. The proposed project would be required to pay the City’s PFF, to go towards the acquisition and
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy development of local and community park facilities throughout the City in addition to what is provided on-site. The project includes 82,419 s.f. (1.89 acres) of common useable open space and 26,390 s.f. (0.61 acres) of private open space.
With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.
Goal PR-1,
Policy PR-1.4
Promote increased access to parks and open
spaces, pedestrian- and bike-oriented routes
to parks and open space, greening of public
rights-of-way, and a variety of active and
passive uses of parks and open space.
The proposed project includes internal streets that connect to the City’s existing pedestrian and bicycle network. The proposed project would be required to pay the City’s PFF, to go towards the acquisition and development of local and community park facilities throughout the City in addition to what is provided on-site. The project includes 82,419 s.f. (1.89 acres) of common useable open space and 26,390 s.f. (0.61 acres) of private open space. With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.
Goal PR-1,
Policy PR-1.5
Require new development to be designed
and constructed in accordance with the
approved Parks Master Plan to meet or
exceed the City’s parkland standard of 5
acres per 1,000 residents.
Section 3.14 (Recreation) analyzed the project’s impacts to recreation. The proposed project would result in an increase in the City of San Marcos population by approximately 469 residents. The additional residents would require approximately 2.35 acres of new park space to fulfill the City’s General Plan requirement of five acres of park space per every 1,000 residents. The proposed project would be required to pay the City’s PFF, to go towards the acquisition and development of local and community park facilities throughout the City in addition to what is provided on-site. The project includes 82,419 s.f. (1.89 acres) of common useable open space and 26,390 s.f. (0.61 acres) of private open space.
With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.
Goal PR-1,
Policy PR-1.6
Require new infill development to provide
plazas, mini parks, or other civic spaces as
part of their parkland requirement.
The proposed project does not propose infill development, but does incorporate private park and open space areas. The proposed project is consistent with this policy.
Goal PR-1,
Policy PR-1.7
Promote park and facility design that
discourages vandalism, deters crime,
provides natural surveillance, and creates a
Safety considerations of the proposed project are discussed in Section 3.13 (Public Services). As proposed, the proposed project, including development of park and open space areas, does not present any unique public safety challenges.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy safe and comfortable environment. The proposed project is consistent with this policy.
Goal PR-2,
Policy PR-2.2
Implement the trail network per the Master
Trails Plan to increase opportunities for
physical activity (e.g., walking, biking),
healthy lifestyles, and to reduce reliance on
cars.
The City’s Master Trail Plan indicates an Urban Trail along the project frontage, which is already constructed. The internal street system would connect to the existing pedestrian and bicycle network. The proposed project would be required to pay the City’s PFF, to go towards the acquisition and development of local and community park facilities throughout the City in addition to what is provided on- site. The project includes 82,419 s.f. (1.89 acres) of common useable open space and 26,390 s.f. (0.61 acres) of private open space. With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant. The project is consistent with this policy.
Safety Element
Goal S-1 Reduce risks to the community from
earthquakes by regulating new development
and redevelopment to prevent the creation
of new geologic and seismic hazards.
The project would implement all recommendations from the geotechnical investigation (Appendix G of EIR). Additionally, development on the project site would be subject to the requirements of the latest California Building Code for resistance to seismic shaking, and would be constructed in accordance with other CBC criteria, current seismic design specifications of the Structural Engineers Association of California, other applicable regulations, and all applicable requirements of the State of California Occupational Safety and Health Administration (Cal/OSHA) to minimize risks from earthquakes. The project is consistent with this goal.
Goal S-1,
Policy S-1.1
Reduce the risk of impacts from geologic and
seismic hazards by applying current and
proper land use planning, development
engineering, building construction, and
retrofitting requirements.
The project would implement all recommendations from the geotechnical investigation (Appendix G of EIR). Additionally, development on the project site would be subject to the requirements of the latest California Building Code for resistance to seismic shaking, and would be constructed in accordance with other CBC criteria, current seismic design specifications of the Structural Engineers Association of California, other applicable regulations, and all applicable requirements of (Cal/OSHA) to minimize risks from earthquakes. The project is consistent with this policy.
Goal S-1,
Policy S-1.2
Investigate specific groundwater levels and
geologic conditions underlying all new
No natural groundwater condition is known to exist at the project site.
Furthermore, there is no known faulting at the project site so the potential for
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy development or redevelopment proposals in
areas where potential fault rupture,
liquefaction, or other geologic hazards are
suspected.
surface fault rupture is low. The project site is not located in a State liquefaction susceptibility zone and is mapped in an area with generally zero to low liquefaction. The project is consistent with this policy.
Goal S-2 Minimize the risk to people, property, and the environment due to flooding hazards.
The project site is not located within a 100-year flood hazard area nor the City’s Flood Damage Prevention Overlay Zone. Additionally, off-site runoff is projected to be less than pre-development conditions with implementation of the project. No on-site or downstream flooding hazard is identified. The project is consistent with this goal.
Goal S-2,
Policy S-2
Require existing private development to take
responsibility for maintenance and repair of
structures to resist flood damage.
The project site is not located within a 100-year flood hazard area nor the City’s Flood Damage Prevention Overlay Zone. Additionally, off-site runoff is projected to be less than pre-development conditions with implementation of the project. No on-site or downstream flooding hazard is identified. The project is consistent with this policy.
Goal S-3 Minimize injury, loss of life, and damage to
property results from structure or wildland
fire hazards.
Implementation of the proposed project would result in a developed area with roads, structures, and landscape vegetation as well as maintained parks and open spaces. The project site is located in a Local Responsibility Area with a Non-Very High Fire Hazard Severity Zone (Non-VHFHSZ) designation per CalFire’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as a Non-VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding area are not identified as a SMFPD Community Hazard Zone. The project includes a 150-foot fuel modification buffer along the southern portion of the project site to further minimize fire risk to the proposed development. The proposed project is consistent with this goal.
Goal S-3,
Policy S-3.1
Require development to be located,
designed, and constructed to provide
adequate defensibility and reduce the risk of
structural loss and life resulting from
wildland fires. Development will consider
hazards relative to terrain, topography,
accessibility, and proximity to vegetation.
One such provision for development to
The project site is located in a Local Responsibility Area with a Non-Very High Fire Hazard Severity Zone (Non-VHFHSZ) designation per CalFire’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as a Non-VHFHSZ. Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding area are not identified as a SMFPD Community Hazard Zone. The project includes a 150-foot fuel modification buffer along the southern portion of the project site to further minimize fire risk to the proposed development. The proposed project is consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy minimize the risk of structural loss and life
shall be the inclusion of overhead fire
sprinklers.
Goal S-3,
Policy S-3.2
Provide sufficient level of fire protection
service to reduce risk from urban and
wildland fire. Advocate and support regional
coordination among fire protection and
emergency service providers.
According to Section 3.13 (Public Services), while current staff levels and equipment at the San Marcos Fire Department Station One is adequate to serve the proposed project, SMFD continues to experience an increase in emergency and non-emergency demands. Additional staff and resources would be provided via Community Facilities District No. 2001-01, into which the project would annex and pay required mitigation fees. The proposed project is consistent with this policy.
Goal S-3,
Policy S-3.3
Require development to provide additional
access roads when necessary to provide for
safe access of emergency equipment and
civilian evacuation concurrently.
Access to the project site will be via two unsignalized driveways on E. Barham Drive. The western driveway will be 40-feet wide and serve as the primary entry to the project site and provide full access. The eastern driveway will be 26-feet wide and will also provide full access. Based upon mitigation measures identified in Section 3.10, Land Use (MM-LU-2 and MM-LU-3), the project will be required to limit left turns out of both driveways between the PM Peak Hour (4:00 PM to 6:00 PM). A secondary emergency-only access is provided through the western boundary of the project site at the western terminus of Street “C”. This access will connect to an existing emergency access driveway on the adjacent property which connects to Saddleback Way and then to E. Barham Drive. This access point is for emergency vehicles only and bollards would be put in place. The Fire Marshal has reviewed and approved all project plans. The proposed project is consistent with this policy.
Goal S-3,
Policy S-3.4
Coordinate with fire protection and
emergency service providers to assess fire
hazards before and after wildfire events to
adjust fire prevention and suppression
needs, as necessary, commensurate with
both short- and long-term fire prevention
needs.
The Fire Marshal has reviewed and approved all project plans. The project site is located in a Local Responsibility Area with a Non-Very High Fire Hazard Severity Zone (Non-VHFHSZ) designation per CalFire’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas identified as a Non-VHFHSZ.
Further, per Figure 6-4 of the City’s General Plan, the project site and surrounding area are not identified as a SMFPD Community Hazard Zone. The project includes a 150-foot fuel modification buffer along the southern portion of the project site to further minimize fire risk to the proposed development. The proposed project is consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal S-4 Protect life, structures, and the environment
from the harmful effects of hazardous
materials and waste.
During construction, there is a potential for accidental upset of fuels, lubricants, and other materials; however, there are existing federal and state standards in place for the handling, storage, and transport of these materials. During operation, the only hazardous materials anticipated for transport, use, or disposal would be routinely used household products. Household hazardous waste programs are in place, which address the use, handling, and disposal of these items. Additionally, the project site and surrounding properties are not considered hazardous materials sites. See Section 3.8 (Hazards and Hazardous Materials) for additional information. The proposed project is consistent with this goal.
Goal S-4,
Policy S-4.1
Promote and support the proper disposal,
handling, transport, delivery, treatment,
recovery, recycling, and storage of hazardous
materials in accordance with applicable
federal, State, and local regulations.
During construction, there is a potential for accidental upset of fuels, lubricants, and other materials; however, there are existing federal and state standards in place for the handling, storage, and transport of these materials. During operation, the only hazardous materials anticipated for transport, use, or disposal would be routinely used household products. Household hazardous waste programs are in place, which address the use, handling, and disposal of these items. Additionally, the project site and surrounding properties are not considered hazardous materials sites. See Section 3.8 (Hazards and Hazardous Materials) for additional information. The proposed project is consistent with this policy.
Goal S-4,
Policy S-4.2
Require areas of known or suspected
contamination to be assessed prior to reuse
or redevelopment. Plan for reuse of
contaminated areas in a manner that is
compatible with the nature of the
contamination and subsequent remediation
efforts.
A Phase I ESA was prepared for the project (Appendix I). The project site was not listed on any list of hazardous materials sites. The Phase I concluded there is a low likelihood that recognized environmental conditions are present at the project site as a result of the current or historical land uses or from a known and reported off- site source. The project would not develop an area of known or suspected contamination. The proposed project is consistent with this policy.
Goal S-4,
Policy S-4.3
Require that land uses using hazardous
materials be located and designed to ensure
sensitive uses, such as schools, hospitals,
day care centers, and residential
neighborhoods, are protected.
The proposed project is not anticipated to generate, release, or use large amounts of hazardous materials. During operation, the only hazardous materials anticipated for transport, use, or disposal would be routinely used household products.
Household hazardous waste programs are in place, which address the use, handling, and disposal of these items. The proposed project is not anticipated to impact any sensitive uses in the project vicinity. The proposed project is consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal S-4,
Policy S-4.4
Avoid locating sensitive uses near
established hazardous materials users or
industrial areas where incompatibilities
would result, except in cases where
appropriate safeguards have been
developed and implemented.
A Phase I ESA was prepared for the proposed project site (Appendix I). The project site was not listed on any list of hazardous materials sites. The Phase I ESA concluded that there is a low likelihood that recognized environmental conditions are present at the project site as a result of the current or historical land uses or from a known and reported off-site source. The proposed project would not place sensitive uses near any known hazardous materials users or industrial areas. The proposed project is consistent with this policy.
Goal S-5 Establish and maintain an effective
emergency response program to respond to
disasters and maintain continuity-of-life
support functions during an emergency.
The San Marcos Emergency Operations Plan identifies several main thoroughfares, including Las Posas Road, as primary evacuation corridors in an emergency. San Marcos is also included in the San Diego County Multi-Jurisdictional Hazard Mitigation Plan, which identifies risks posed by natural and human-caused disasters. The project provides for two driveways and one emergency-only access route. According to Section 3.8 (Hazards and Hazardous Materials), the project would not impact any roadway or staging areas identified in any emergency planning documents. The project is consistent with this goal.
Goal S-5,
Policy S-5.3
Develop, implement, and maintain an
effective evacuation program for areas of
risk in the event of a disaster.
The San Marcos Emergency Operations Plan identifies several main thoroughfares as primary evacuation corridors in an emergency. The project provides two driveways and one emergency access routes are provided on the project site.
According to Section 3.8 (Hazards and Hazardous Materials), the project would not impact any roadway or staging areas identified in any emergency planning documents. The project is consistent with this policy.
Goal S-6 Provide neighborhood safety through
effective law enforcement.
Current staff levels are adequate to meet current law enforcement demand; however, development of the proposed project would increase this demand. To supplement police protection services, the developer would contribute to CFD 98- 01 Improvement Area #1. The project is consistent with this goal.
Goal S-6,
Policy S-6.1
Continue to maintain demand-based law
enforcement service levels to reduce the risk
of criminal activity.
Current staff levels are adequate to meet current law enforcement demand; however, development of the proposed project would increase this demand. To supplement police protection services, the developer would contribute to CFD 98- 01 Improvement Area #1. The project is consistent with this policy.
Goal S-6,
Policy S-6.2
Continue public education efforts and
community outreach programs to promote
The San Diego County Sheriff's Department provides presentations to schools through their COPPS deputies. A school resource officer who handles all crimes
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy community involvement in crime and drug
prevention.
relating to school students is also assigned to high schools within the City of San Marcos. The project's contribution to CFD 98-01 Improvement Area #1 would aid in the continued provision of these services. The project is consistent with this policy.
Goal S-6,
Policy S-6.3
Use Crime Prevention through Environmental
Design (CPTED) principles in the design or
redevelopment of projects and buildings.
The San Diego County Sheriff's Department provides CPTED reviews through their crime prevention unit. The project's required contribution to a CFD would aid in the continued provision of this service. The Sheriff's Department has reviewed all project plans. The project is consistent with this policy.
Goal S-7 Comply with the McClellan-Palomar Airport
Land Use Compatibility Plan.
The project site is located within Review Area 2 of the McClellan-Palomar airport influence area and may be subject to annoyances associated with noise, vibration, and overflights. Consistent with the ALUCP, recordation of overflight notification documents will be required as a condition of project approval. Review Area 2 also limits heights of structures in areas of high terrain. The project site is not characterized as high terrain and proposed development would remain below surrounding prominent topographic features. The project is consistent with this goal.
Goal S-7,
Policy S-7.1
Record an overflight notification document in
association with the approval of any new
residential land use within the AIA overflight
notification area consistent with the ALUCP.
The project site is located within Review Area 2 of the McClellan-Palomar airport influence area and may be subject to annoyances associated with noise, vibration, and overflights. Consistent with the ALUCP, recordation of overflight notification documents will be required as a condition of project approval. Review Area 2 also limits heights of structures in areas of high terrain. The project site is not characterized as high terrain and proposed development would remain below surrounding prominent topographic features. The project is consistent with this goal.
Noise Element
Goal N-1 Promote a pattern of land uses compatible
with current and future noise levels.
The noise study prepared for the project (Appendix L) modeled ambient and future noise levels at the project site and compared with exterior and interior noise thresholds contained in the City’s General Plan. With the incorporation of mitigation measures included in Section 3.11 (Noise), the noise levels will be consistent with General Plan’s noise thresholds for residential projects.
Additionally, the project is not of a type that would generate excessive noise to neighboring uses during daily operation. Noise associated with increased traffic as
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy a result of the project would not increase levels above the significance threshold of 3 dBA CNEL. Therefore, the project is consistent with this goal.
Goal N-1,
Policy N-1.1
Address the potential for excessive noise
levels when making land use planning
decisions in accordance with Table 7-3 Land
Use Compatibility Noise Standards.
The noise study prepared for the project analyzed noise impacts to and generated from implementation of the proposed project. As summarized in Section 3.11 (Noise), incorporation of mitigation measures would ensure that noise levels on the project site and generated from implementation of the project would be below the City’s threshold. The project is consistent with this policy.
Goal N-1,
Policy N-1.2
Ensure that acceptable noise levels are
maintained near noise-sensitive uses.
With incorporation of mitigation measures included in Section 3.11 (Noise), the project would not generate noise levels in excess of any standards. Therefore, the project would not impact nearby noise-sensitive receptors. The project is consistent with this policy.
Goal N-1,
Policy N-1.3
Incorporate design features into residential
land use projects that can be used to shield
residents from excessive noise. Design
features may include, but are not limited to:
berms, walls, and sound attenuating
architectural design and construction
methods.
Mitigation in the form of 5- to 8-foot barriers (landscape berms and/or sound walls) would ensure noise levels at the project site meet stated thresholds as detailed in Section 3.11 (Noise). Additionally, mitigation measure MM-N-5 requires a final noise assessment be performed to identify interior noise requirements based on architectural and building plans to meet the City’s established interior noise limit. The identified interior noise requirements may include conventional building construction methods and providing a closed window condition requiring a means of mechanical ventilation (e.g., air condition) for each building and upgraded windows for all sensitive rooms (e.g., bedrooms and living spaces). The project is consistent with this policy.
Goal N-1,
Policy N-1.4
Require new development projects to provide
barriers to reduce noise levels, or provide
sufficient spatial buffers to separate
excessive noise generating land uses and
noise-sensitive land uses.
Mitigation in the form of 5- to 8-foot barriers (landscape (landscape berms and/or sound walls) would ensure noise levels at the project site meet stated thresholds as detailed in Section 3.11 (Noise). The project is consistent with this policy.
Goal N-1,
Policy N-1.5
Require an acoustical study for proposed
developments in areas where the existing
and projected noise level exceeds or would
exceed the Normally Acceptable levels
identified in Table 7-3.
A noise study was prepared for the project (Appendix L). In summary, noise impacts would be mitigated to below a level of significance through the inclusion of 5- to 8-foot barriers (landscape berms and/or sound walls) as well as additional noise measurements and requirements for interior spaces once residences are constructed. The project is consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal N-2 Control transportation-related noise from
traffic, rail, and aviation sources near noise
sensitive land uses.
The project is anticipated to experience traffic-related noise impacts. Mitigation in the form of 5- to 8-foot barriers (landscape berms and/or sound walls) as well as additional noise measurements and requirements for interior spaces once residences are constructed would ensure noise levels at the project site meet stated thresholds. The project is consistent with this goal.
Goal N-2,
Policy N-2.1
Encourage only noise-compatible land uses
along existing and future roadways,
highways, and freeways.
The project is anticipated to experience traffic-related noise impacts. Mitigation in the form of 5- to 8-foot barriers (landscape berms and/or sound walls) as well as additional noise measurements and requirements for interior spaces once residences are constructed would ensure noise levels at the project site meet stated thresholds. The project is consistent with this goal.
Goal N-2,
Policy N-2.2
Promote coordinated site planning and traffic
control measures that reduce traffic noise on
noise-sensitive land uses.
The project is anticipated to experience traffic-related noise impacts. Mitigation in the form of 5- to 8-foot barriers (landscape berms and/or sound walls) as well as additional noise measurements and requirements for interior spaces once residences are constructed would ensure noise levels at the project site meet stated thresholds. The project is consistent with this goal.
Goal N-2,
Policy N-2.3
Advocate the use of alternative
transportation modes such as walking,
bicycling, mass transit, and non-combustible
engine vehicles to reduce traffic noise.
The project’s internal pedestrian circulation network would connect to the existing sidewalk and bicycle facilities along the project frontage on E. Barham Dr. The closest bus stops are 0.7 mile from the project site and would not be impacted by the project. The project is consistent with this goal.
Goal N-3 Control non-transportation-related noise from
commercial, industrial, construction, and
other sources on noise sensitive land uses.
The nearest noise-sensitive land uses are located approximately 200 feet from the project site. As analyzed in Section 3.11 Noise, in general construction activities are modeled to comply with applicable noise limits. However, noise levels resulting from rock crushing operations and potentially from a rock drill depending on staging location, would exceed City standards. Implementation of MM-N-1 and MM-N-2 would ensure compliance during rock drilling and crushing activities.
Additional mitigation or modified construction activity may occur. Therefore, the project is consistent with this goal.
Goal N-3,
Policy N-3.1
When adjacent to noise sensitive receptors,
require developers and contractors to
employ noise reduction techniques during
construction and maintenance operations.
The nearest noise-sensitive land uses are located approximately 200 feet from the project site. As analyzed in Section 3.11 Noise, in general construction activities are modeled to comply with applicable noise limits. However, noise levels resulting from rock crushing operations and potentially from a rock drill depending on
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy staging location, would exceed City standards. Implementation of MM-N-1 and MM-N-2 would ensure compliance during rock drilling and crushing activities.
Additional mitigation or modified construction activity may occur. Therefore, the project is consistent with this goal.
Goal N-3,
Policy N-3.2
Limit the hours of construction and
maintenance operations located adjacent to
noise-sensitive land uses.
Construction activities would comply with the City’s Municipal Code requirement and any Conditional Use Permit requirements for the rock crusher to ensure impacts to nearby noise-sensitive uses are minimized. Construction activities will occur between 7:00 AM and 4:30 PM, Monday through Friday. Blasting activities would only be permitted between 9:00 AM and 4:00 PM, Monday through Friday.
No construction activities will occur on weekends or holidays. project is consistent with this policy.
Housing
Element
Goal H-1 Provide a broad range of housing
opportunities with emphasis on providing
housing which meets the special needs of
the community.
The proposed project proposes 151 multi-family residential units situated on approximately 10.6 gross acres for a maximum density of 14.3 du/acre. The Project proposes a mix of two and three-story condominiums ranging in size from a minimum of approximately 874 sq. ft. to a maximum of approximately 2,126 sq. ft.
The project is consistent with this goal.
Goal H-1,
Policy 1.1
Designate land for a variety of residential
densities sufficient to meet the housing
needs for a variety of household sizes and
income levels, with higher densities being
focused in the vicinity of transit stops and in
proximity to significant concentrations of
employment opportunities.
The proposed project proposes 151 multi-family residential units situated on approximately 10.6 gross acres for a maximum density of 14.3 du/acre. The Project proposes a mix of two and three-story condominiums ranging in size from a minimum of approximately 874 sq. ft. to a maximum of approximately 2,126 sq. ft.
Primary project access is via E. Barham Drive, which connects the project site to regional transportation corridors. The project is consistent with this policy.
Goal H-2 Protect, encourage, and provide housing
opportunities for persons of lower and
moderate incomes.
The proposed project consists of a 151 multi-family residential development, consistent with the population growth projections. While the project is not a dedicated low-income development, the Specific Plan for the project provides for a range of two- and three-story unit plans and sizes on a variety of lot sizes, therefore providing housing for a range of income levels. The project is consistent with this policy.
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General Plan
Element Goal
or Policy
Goal/Policy Description Project’s Consistency with Goal/Policy Goal H-4,
Policy 4.4
Balance the need to protect and preserve
the natural environment with the need to
provide additional housing and employment
opportunities.
The project balances the provision of housing with the preservation of open space.
The project will develop 151 single family residences on 10.6 acres and provides approximately 5.6 acres of common open space. Additionally, Section 4.0 (Alternatives) of the EIR provides a range of alternative development scenarios, including a no development alternative, considered for the project site.
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3.11 Noise
Introduction
This section addresses the potential noise effects resulting from the construction of the project and analyzes the noise compatibility of the project site with surrounding land uses. The analysis is based on the following report, which is included as Appendix L of the Environmental Impact Report (EIR)13:
• Noise Assessment, East Barham Residential Development Project, City of San Marcos, prepared by LDN Consulting (May 2021).
In the Initial Study prepared for the project ( Appendix B.1), the proposed project was determined to have no impact resulting from excessive noise levels from a private airstrip, as the project site is not located within the vicinity of a private airstrip. Therefore, this issue is not discussed further in this section. Section 5.6, Environmental Effects Found Not to Be Significant – Noise of the EIR provides additional information on this topic.
Table 3.11-1 summarizes the project- and cumulative-level noise impacts, by threshold.
Table 3.11-1. Noise Summary of Impacts
Threshold of Significance Project Direct
Impact
Project Cumulative
Impact
Impact After
Mitigation
#1 – Generation of a
substantial temporary or
permanent increase in ambient
noise levels in the vicinity of
the project in excel of
standards established in the
location general plan or noise
ordinance, or applicable
standards of other agencies.
Potentially
Significant
Less than Significant Mitigated to Less
Than Significant
#2 - Generation of excessive
groundborne vibration or
groundborne noise levels.
Potentially
Significant
Less than Significant Mitigated to Less
Than Significant
3.11.1 Existing Conditions
This section provides background on noise analysis and a description of the existing noise environment on the project site and surrounding area and details the results of the ambient noise monitoring conducted by LDN Consulting in 2021.
13 Full references for documents cited in this section are included in Chapter 7, References, of this EIR.
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Background
Noise
Noise is generally defined as “unwanted sound” that interferes with normal activities. Excessive levels of noise can cause hearing loss, although the principal human response to environmental noise is annoyance. Noise is measured on a logarithmic scale of sound pressure level known as decibel (dB). A -weighted decibels (dBA) approximate the subjective response of the human ear to broad frequency noise sources by discriminating against very low and very high frequencies of the audible spectrum. They are adjusted to reflect only frequencies audible to the human ear. Equivalent sound level (Leq) is the noise metric used to collect short -term noise level measurement samples. It represents a steady state sound level containing the same total energy as a time varying signal over a given sample period, with Lmax and Lmin as the maximum and minimum, respectively. Community receptors are more sensitive to unwanted noise intrusion during the evening and at night. State law requires that, for some planning purposes, an art ificial dBA increment be added to quiet time noise levels in a 24-hour A-weighted average noise descriptor called the Community Noise Equivalent Level (CNEL). In general, a change of 10 dBA is perceived as twice as loud (i.e., 65 dBA sounds twice as loud as 55 dBA to a human ear), a 5 dBA change in community noise levels is clearly noticeable, and a 3 dBA change is the smallest increment that is perceivable by most people. Changes of 1 to 2 dBA are not usually detectable by the human ear.
The decibel level of a sound decreases (or attenuates) exponentially as the distance from the source of that sound increases. For a single point source, such as a piece of mechanical equipment, the sound level normally decreases by about 6 dBA for each doubling of distance from the source.
Sound that originates from a linear, or “line” source, such as a heavily traveled traffic corridor, attenuates by approximately 3 dBA per doubling of distance, provided that the surrounding site conditions lack ground effects or obstacles that either scatter or reflect noise.
Surrounding site conditions, meteorological conditions, and the presence of manmade obstacles such as buildings and barriers may also reduce noise at the location of a receiver. For example, vegetation and loose soils may either absorb or scatter the sound from roadways, yielding sound attenuation rates in environments with these major ground effects that are as high as 4.5 dBA for each doubling of distance (compared to 3 dBA without major ground effects). In addition, barriers between a noise source and a receiver can substantially reduce noise levels at the receiver. A barrier that breaks the line of sight between a source and a receiver will typically result in at least 5 dBA of noise reduction. Taller barriers will provide increased noise reduction.
Vibration
Vibration is an oscillatory motion through a solid medium in which the motion’s amplitude can be described in terms of displacement, velocity, or acceleration. Human response to vibration is best approximated by the vibration velocity level.
Heavy equipment operation, including stationary equipment that produces substantial oscillation or construction equipment that causes percussive action against the ground surface, may be perceived by building occupants as perc eptible vibration known as “structureborne/groundborne” vibration.
Vibration in buildings is typically perceived as rattling of windows or items on shelves or the motion of building surfaces. The vibration of building surfaces can also be radiated as sound and heard as a low-frequency rumbling noise, known as groundborne noise. Although the perceived vibration from such equipment operation can be intrusive to building occupants, the vibration is seldom of
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sufficient magnitude to cause even minor cosmetic da mage to buildings unless the receptors are in proximity to heavy equipment.
Vibration energy spreads out as it travels through the ground, causing the vibration amplitude to rapidly decrease with distance away from the source. Soil properties also affect t he propagation of vibration. Man -made vibration issues are, therefore, usually confined to short distances from the source (i.e., 50 feet or less).
Vibration amplitudes are usually described in terms of peak levels, as in peak particle velocity (PPV) in inches/second that correlates best with human perception. The particle velocity is the velocity of the soil particles resulting from a disturbance. Agencies such as California Department of Transportation (Caltrans) use the PPV descriptor because it correlat es well with damage or complaints. Caltrans estimates that the threshold of perception is approximately 0.006 inches/second PPV and the level at which continuous vibration begins to annoy people is approximately 0.010 inches/second PPV (Caltrans 2020).
Existing Noise Environment
The project site is currently vacant, with areas disturbed from previous agricultural uses. The project site does not currently contain any sources of noise or vibration generation. The project vicinity is developed primarily wit h residential uses. To the east of the project is the Mira Lago residential development and further east is a mobile home park. T o the southeast is the Williamsburg residential development. West of the project site is Grace Church , which includes preschool and daycare uses, and the Barham Park & Ride. Southwest of the project site is residential development associated with the Walnut Hills II Specific Plan. E. Barham Drive is to the north and then State Route 78 (SR-78) and existing open space is to the sou th. Sources of noise in the surrounding area primarily include traffic from E. Barham Drive and SR-78.
Existing ambient noise measurements were collected by LDN Consulting in September 2020 near the northwestern portion of the project site along E. Barham Drive. Sound level meters mounted to tripods approximately five feet above the ground were used and measured sound for a period of 15 minutes hours. The monitoring location is shown in Figure 3.11-1.
The results of the noise level measurements are presented in Table 3.11-2. The measurements were taken on site to establish a baseline of the vehicle noise from SR -78 and E. Barham Drive. The measurements were free of obstruction and had a direct line of sight to the roadways . As shown in Table 3.11-2, the overall sound level was found to be 69.0 dBA Leq, with a maximum of 79 dBA.
Table 3.11-2. Measured Ambient Noise Levels
Measurement
Identification Description Date/Time
Noise Levels (dBA Leq)
Leq Lmax Lmin L10 L50 L90
ML 1 E. Barham Drive
September
25, 2020
2:00PM to
2:15 PM
69.0 79.0 61.9 71.4 67.3 63.7
Source: LDN Consulting 2021c
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3.11.2 Regulatory Setting
The following section provides a general description of the applicable regulatory requirements pertaining to noise, including federal, state, and local guidelines.
Federal
Federal Bodies
Title 49 Chapter 65 of the United States Code of Federal Regulations (CFR) provides for the regulation of noise to protect the public health, safety, and welfare. The Federal Highway Administration (FHWA); Federal Rail Administration (FRA) and Federal Transit Administration (FTA); and the Federal Aviation Administration (FAA), respectively, regulate roadway, rail, and aircraft.
Vibration and Groundborne Noise Impact Regulations
Publications of the FTA and Caltrans are two of the seminal works for the analysis of groundborne noise and vibration relating to transportation and construction -induced vibration. While the project is not subject to FTA or Caltrans regulations, these guidelines serve as a useful tool to evaluate vibration impacts. Caltrans guidelines recommend that a standard of 0.2 in/sec peak part icle velocity (PPV) not be exceeded for the protection of normal residential buildings, and that 0.08 in/sec PPV not be exceeded for the protection of old or historically significant structures. With respect to human response within residential uses (i.e., annoyance, sleep disruption), FTA recommends a maximum acceptable vibration standard of 80 vibration velocity (VdB).
State
State noise standards regulate noise levels of motor vehicles, sound transmission through buildings, occupational noise control, and noise insulation. State regulatory guidelines governing noise levels generated by individual motor vehicles and guidelines governing occupational noise control are not applicable to planning efforts nor are these areas typically subject to California Environmental Quality Act (CEQA) analysis.
Office of Planning and Research General Plan Guidelines The State of California General Plan Guidelines, published by the state Governor’s Office of Planning and Research (OPR), provides guidance for the acceptability of specific land use types within areas of specific noise exposure. The guidelines also present adjustment factors that may be used to arrive at noise acceptability standards that reflect the noise control goals of the community, the particular community’s sensitivity to noise, and the community’s assessment of the relative importance of noise pollution. General Plan guidelines are advisory in nature. Local jurisdictions, including San Marcos, have the responsibility to set specific noise standards based on local conditions.
State of California Code of Regulations Title 24
In 1974, the California Commission on Housing and Community Development adopted noise insulation standards for hotels, motels, dormitories, and multi- family residential buildings (Title 2 4, Part 2, California Code of Regulations). Title 24 establishes standards for interior room noise (attributable to outside noise sources). The regulations also specify that acoustical studies must be prepared whenever a multi- family residential building or structure is proposed to be located near an existing or adopted freeway route, expressway, parkway, major street, thoroughfare, rail line, rapid transit line, or industrial noise source, and where such noise source or sources create an exterior
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CNEL (or LDN ) of 60 dBA or greater. Such acoustical analysis must demonstrate that the residence has been designed to limit intruding noise to an interior CNEL (or LDN) of at least 45 dBA [California’s Title 24 Noise Standards, Chap. 2-35].
Local
City of San Marcos General Plan
The following are applicable goals and policies from the City of San Marcos General Plan, Noise Element:
• Goal N-1: Promote a pattern of land uses compatible with current and future noise levels. o Policy N -1.1: Address the potential for e xcessive noise levels when making land use planning decisions in accordance with Table 7 -3 Land Use Compatibility Noise Standards.
o Policy N -1.2: Ensure that acceptable noise levels are maintained near noise -sensitive uses.
o Policy N -1.3: Incorporate design features into residential land use projects that can be used to shield residents from excessive noise. Design features may include, but are not limited to: berms, walls, and sound attenuating architectural design and construction methods.
o Policy N -1.4: Req uire new development projects to provide barriers to reduce noise levels, or provide sufficient spatial buffers to separate excessive noise generating land uses and noise-sensitive land uses.
o Policy N-1.5: Require an acoustical study for proposed developme nts in areas where the existing and projected noise level exceeds or would exceed the Normally Acceptable levels identified in Table 7-3.
• Goal N -2: Control transportation -related noise from traffic, rail, and aviation sources near noise sensitive land uses.
o Policy N -2.1: Encourage only noise -compatible land uses along existing and future roadways, highways, and freeways.
o Policy N-2.2: Promote coordinated site planning and traffic control measures that reduce traffic noise on noise-sensitive land uses.
o Policy N -2.3: Advocate the use of alternative transportation modes such as walking, bicycling, mass transit, and non-combustible engine vehicles to reduce traffic noise. • Goal N-3: Control non-transportation-related noise from commercial, industrial, constructio n, and other sources on noise sensitive land uses.
o Policy N -3.1: When adjacent to noise sensitive receptors, require developers and contractors to employ noise reduction techniques during construction and maintenance operations.
o Policy N -3.2: Limit the hou rs of construction and maintenance operations located adjacent to noise-sensitive land uses.
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The following is an applicable goal and policy from the City of San Marcos General Plan, Safety Element:
• Goal S-7: Comply with the McClellan-Palomar Airport Land Use Compatibility Plan. o Policy S-7.1: Record an overflight notification document in association with the approval of any new residential land use within the AIA overflight notification area consistent with the ALUCP.
The proj ect’s consistency with applicable General Plan goals and policies is discussed in Section
3.10, Land Use and Planning. As detailed in Table 3.10 -5 in Section 3.10, the project is consistent with the applicable goals and policies.
City of San Marcos Municipal Code
Chapter 10.24 (Noise)
Chapter 10.24 of the San Marcos Municipal Code prohibits loud, annoying, or unnecessary noises.
However, the Noise Ordinance does not specifically provide quantified property line noise level limits.
Section 10.24.020 provides definitions for and examples of prohibited noise sources. Included in the list of prohibited noise sources is demolition and building construction activities that occur Monday through Friday before 7:00 AM and after 6:00 PM or on Saturdays before 8:00 AM or after 5:00 PM.
The noise ordinance does not include a quantified noise level limit for construction noise. Section
10.24.030 describes the standards for how sound is assessed . Commonly, the City has utilized the County of San Diego’s Noise Ordinance noise limit of 75 dBA for construction activities.
Section 17.32.180 (Grading Operation Restrictions)
City of San Marcos Municipal Code Section17.32.180 addresses the time limits that apply to grading, extraction, and blasting between 7:00 AM and 4:30 PM Monday through Friday. Grading, extraction, or related earth moving is not allowed in the City on the weekends or holidays. The Municipal Code does not set noise limits on construction activities. Commonly, the City has utilized the County of San Diego’s Noise Ordinance noise limit of 75 dBA for construction activities.
The Noise Element of the County of San Diego General Plan establishes limitations on sound levels to be received by various land uses. New development may cause an existing noise sensitive land use (NSLU) to be affected by noise caused by the new development, or it may create or locate a NSLU in such a place that it is affected by noise. The Noise Element identifies airports and traffic on public roadways as the major sources of noise. The County Noise Element establishes the exterior noise level standards and provides interior standards and definitions. If the exterior noise level would exceed 75 dBA CNEL, new development would not be approved.
Section 17.60 (Blasting Operations)
Section 17.60 of the Municipal Code provides local control of blasting operations complementary to the Uniform Fire Code. The particular purpose is to define hours of operation and notification and inspection process to protect nearby residents and residences from damage or injury due to blasting.
Section 17.60.060 identifies specific blasting procedures that are applicable to the project. These requirements include:
• The blaster shall notify the Building Division and the Fire Department no less than 12 hours prior to any b lasting at the location or locations of the blasting, number of blasts or
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explosions, type of explosives to be used, and scheduled time blasting will begin, and name of contractor and Certificate of Authorization date.
• The general contractor or property ow ner/developer shall give reasonable notice in writing at the time of issuance of a building permit, grading permit or encroachment license to all residences or businesses within 600 feet of any potential blast location. The notice shall be in a form approv ed by the Building Official. Any resident or business receiving such notice may request of the Building Official. that a notice of impending blasting be given by the blaster at the time of the 12 -hour advance notice given to the Building Official. The gene ral contractor or property owner/developer shall make all reasonable efforts to contact any and all parties requesting the second notice.
• The blaster shall file a written certification with the Building Official. certifying that the general notice required by Section 17.60.060(b) has been given. The certificate shall include addresses and date(s) of notification. A copy shall be retained on file at the Building Division. • Inspections of all structures within 300 feet of the blast site shall be made before bl asting operations. The persons inspecting shall obtain the permission of the building owner to conduct an inspection. The inspections shall be done by a registered structural engineer employed by the blaster or project contractor. The inspection shall be only for the purpose of determining the existence of any visible or reasonably recognizable pre -existing defects or damages in any structure. Inspection refusal shall be at the discretion of the property owner. • The structural engineer shall file a written r eport identifying all findings of the inspections with the Building Division. The report shall be signed by the engineer and countersigned by the contractor/developer or his agent receiving the report. • The blaster shall confirm with the Building Division a nd Fire Department scheduled blasts no less than one hour prior to the scheduled blast.
• The blaster shall permit Fire Department personnel to inspect the blast site and blast materials or explosives at any reasonable time prior to any blasting. The general contractor and blaster shall request and arrange 12 hours in advance of the blast to have a Fire Department official present during the blast. The Fire Department shall, whenever possible and practicable, assign a Department member to be present to observe the blast. • Blasting shall only be permitted between the hours of 9:00 AM and 4:00 PM during any weekday, Monday through Friday, exclusive of City recognized holidays unless special circumstances warrant another time or day and special approval is granted by the Building Official and Fire Chief.
• Possession, storage, transportation, and use of explosives and blasting agents shall be in accordance with the Uniform Fire Code as adopted by Ordinance of the San Marcos Fire Protection District.
Chapter 20.300 (Zoning Ordinance)
The provisions of Title 20 of the San Marcos Municipal Code are referred to as the Zoning Ordinance.
Section 20.300, Performance Standards, within the Zoning Ordinance identifies noise regulations to prohibit unnecessary, excessive, and annoying noises. Table 20.300 -4, included below as Table
3.11-3 identifies allowable noise levels (dBA) by zone type. For multifamily residential the allowable noise level, as measured at the property line is 6 5 dBA from 7:00 AM to 10:00 PM. and 55 dBA from
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10:00 PM to 7:00 AM. Increases in allowable noise levels listed in Table 3.11-4 may be permitted in accordance with the standards outlined in Table 3.11-4.
1. Noise shall be measured with a sound -level meter that meets the standards of the American National Standards Institute (ANSI) (Section S1.4 -1979, Type 1 or Type 2). Noise levels shall be measured in decibels at the property line of the receptor property, and at least five (5) feet above the ground and ten (10) feet from the nearest str ucture or wall. The unit of measure shall be designated as an A -weighted decibel (dBA) Leq standard. A calibration check shall be made of the instrument at the time any noise measurement is made.
2. No person shall create or allow the creation of exterior noi se that causes the noise level to exceed the noise standards established by Table 20.300 -4 (shown as Table 3.11 -3).
Increases in allowable noise levels listed in Table 20.300 -4 (shown as Table 3.11 -4) may be permitted in accordance with the standards outlined in Table 20.300 - 5 (shown as Table
3.11-4).
3. No person shall create nor allow the creation of noise that causes the interior noise level when measured within a dwelling unit to exceed forty -five (45) dBA at any time, except as permitted by Table 20.300-6 (shown as
Table 3.11-5).
4. Use of compressors or other equipment, including vents, ducts, and conduits, but excluding window or wall-mounted air conditioners, that are located outside of the exterior walls of any building, shall be enclosed within a permanent, noncombustible, view-obscuring enclosure to ensure that the equipment does not emit noise in excess of the ANSI standards.
Table 3.11-3. Exterior Noise Standards by Zone
Zone Allowable Noise Level (dBA Leq) Measured
from the Property Line
Single-Family Residential (A, R-1, R-2)1,2
7:00 AM and 10:00 PM (daytime) 60
10:00 PM and 7:00 AM (overnight) 50
Multifamily Residential (R-3) (1)(2)
7:00 AM and 10:00 PM (daytime) 65
10:00 PM and 7:00 AM (overnight) 55
Commercial (C, O-P, SR)(3)
7:00 AM and 10:00 PM (daytime) 65
10:00 PM and 7:00 AM (overnight) 55
Industrial
7:00 AM and 10:00 PM (daytime) 65
10:00 PM and 7:00 AM (overnight) 60
Source: City of San Marcos 2017 (Table 20.300-4)
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Notes: (1) For single-family detached dwelling units, the "exterior noise level" is defined as the noise level measured at an outdoor living area which adjoins and is on the same lot as the dwelling, and which contains at least the following minimum net lot area: (i) for lots less than 4,000 square feet in area, the exterior area shall include 400 square feet, (ii) for lots between 4,000 square feet to 10 acres in area, the exterior area shall include 10 percent of the lot area; (iii) for lots over 10 acres in area, the exterior area shall include 1 acre.
(2) For all other residential land uses, "exterior noise level" is defined as noise measured at exterior areas which are provided for private or group usable open space purposes. "Private Usable Open Space" is defined as usable open space intended for use of occupants of one dwelling unit, normally including yards, decks, and balconies. When the noise limit for Private Usable Open Space cannot be met, then a Group Usable Open Space that meets the exterior noise level standard shall be provided. "Group Usable Open Space" is defined as usable open space intended for common use by occupants of a development, either privately owned and maintained or dedicated to a public agency, normally including swimming pools, recreation courts, patios, open landscaped areas, and greenbelts with pedestrian walkways and equestrian and bicycle trails, but not including off-street parking and loading areas or driveways.
(3) For non-residential noise sensitive land uses, exterior noise level is defined as noise measured at the exterior area provided for public use.
Table 3.11-4. Permitted Increase in Noise Levels
Permitted Increase (dBA) Duration
(cumulative minutes per hour)
5 15
10 5
15 1
20 Less than 1 minute
Source: City of San Marcos 2017 (Table 20.300-5)
Table 3.11-5. Permitted Increase in Interior Noise Levels Permitted Increase (dBA) Duration
(cumulative minutes per hour)
5 1
10 Less than 1 minute
Source: City of San Marcos 2017 (Table 20.300-6)
3.11.3 Thresholds of Significance
According to Appendix G of the State California Environmental Quality Act (CEQA) Guidelines , noise impacts are considered potentially significant if they cause:
• Threshold #1: Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excel of standards established in the location general plan or noise ordinance, or applicable standards of other agencies. • Threshold #2: Generation of excessive groundborne vibration or groundborne noise levels.
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The term “substantial increase” is not defined by any responsible agency. Under ambient conditions, people generally do not perceive that noise has clearly changed until there is a 3 dBA difference .
Therefore, a threshold of 3 dBA is commonly used to define “substantial increase,” as it is noticeable to humans under typical ambient conditions. For this analysis, a direct roadway noise impact would be considered significant if the project increases noise levels for a noise sensitive land use by 3 dBA CNEL and increases noise levels above an unacceptable noise level per the City’s General Plan in the area adjacent to the roadway segment.
As identified above, impacts related to being in the vicinity of a private airstrip or airport land use plan are not discussed in this section. Section 5.6, Environmental Effects Found Not to Be Significant – Noise, provides additional information on this topic.
San Marcos Noise Impact Thresholds
Noise Due to Construction Sources
The City of San Marcos Municipal Code does not set noise limits on construction activities.
Commonly, the City utilizes the County of San Diego’s Noise Ordinance Section 36.410 noise limit of 75 dBA at any existing sensitive receptor for construction activities. The Municipal Code Section
17.32.180 does address and limit grading and extraction activities between the hours of 7:00 AM and 4:30 PM, Monday through Friday, and no grading or earth moving activities are allowed on the weekends or holidays. Commonly, the City has utilized the County of San Diego’s Noise Ordinance noise limit of 75 dBA for other projects.
City of San Marcos Rock Crushing Limits
The City of San Marcos requires that noise levels from a proposed temporary rock crusher maintain noise levels of 60 dBA or less at surrounding single family residences, 65 dBA at multifamily uses, and 70 dBA at all commercial uses , which include churches and preschools . The proposed temporary rock crusher would require issuance of a Conditional Use Permit, which can also require more restrictive hours of operation for rock crushing than for general construction activity. The project will be conditioned to limit rock crushing activities between the hours of 9:00 AM and 4:00 PM, Monday through Friday.
City of San Marcos Blasting Standards
The City of San Marcos Municipal Code, Title 17 states that all blasting operations within the City of San Marcos are prohibited unless a Certificate of Authorization is first obtained from the San Marcos Building Official and an Operations Permit issued by the Fire Chief. Written notice to all residences and businesses within 600 feet of any potential blast location is required, and an inspection of all structures within 300 feet of the blast s ite by a structural engineer shall occur to determine any existing defects or damages. Consistent with Municipal Code Section 17.60.060, blasting is permitted only between 9:00 AM and 4:00 PM, Monday through Friday, holidays excepted.
Noise Due to Transportation Sources
To control transportation -related noise sources such as arterial roads, freeways, airports, and railroads, the City of San Marcos has established guidelines for acceptable community noise levels in the Noise Element of the General Plan. For noise sensitive rural and single -family residential uses, schools, libraries, parks, and recreational areas, the City Noise Element requires an exterior noise level of less than 60 dBA CNEL for outdoor usable areas, such as yard and patio areas. For multi - family developments, the standard is 65 dBA CNEL. A standard of 70 dBA CNEL is typically applied to
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commercial uses. The City has also established an interior noise limit of 45 dBA CNEL for all residential uses. Noise sensitive indoor spaces are subject to compliance with CCR Title 24 noise insulation standards demonstrating a 45 dBA CNEL interior noise level with all windows of the structure closed.
City of San Marcos Ground Vibration Standards
The City of San Marcos does not have adopted vibration criteria. The FTA provides criteria for acceptable levels of groundborne vibration for various types of buildings that are sensitive to vibration. For purposes of identifying potential project -related vibration impacts resulting from the proposed project, the FTA criteria will be used. Table 3.11 -6 shows the FTA groundborne vibration and noise impact criteria for human annoyance.
Table 3.11-6. Groundborne Vibration and Noise Impact Criteria (Human Annoyance)
Groundborne Vibration
Impact Levels
(VdB re 1 microinch/second)
Groundborne Noise Impact Levels
(dB re 20 micropascals)
Frequent
Events1
Occasional
Events2
Infrequent
Events3
Frequent
Events
Occasional
Events
Infrequent
Events
Category 1: Buildings where
low ambient vibration is
essential for interior
operations.
65 VdB4 65 VdB4 65 VdB4 N/A4 N/A4 N/A4
Category 2: Residences and
buildings where people
normally sleep.
72 VdB 75 VdB 80 VdB 35 dBA 38 dBA 43 dBA
Category 3: Institutional
land uses with primarily
daytime use.
75 VdB 78 VdB 83 VdB 40 dBA 43 dBA 48 dBA
Source: Federal Transit Administration (FTA), Transit Noise and Vibration Impact Assessment, September 2018.
Notes: (1) Frequent Events” are defined as more than 70 vibration events per day. Most rapid transit projects fall into this category.
(2) Occasional Events” are defined as between 30 and 70 vibration events of the same source per day. Most commuter trunk lines have this many operations. (3) Infrequent Events” are defined as fewer than 30 vibration events of the same kind per day. This category includes most commuter rail branch lines.
(4) This criterion limit is based on levels that are acceptable for most moderately sensitive equipment such as optical microscopes. Vibration-sensitive manufacturing or research would require detailed evaluation to define the acceptable vibration levels. Ensuring lower vibration levels in a building often requires special design of the HVAC systems and stiffened floors. (5) Vibration-sensitive equipment is not sensitive to groundborne noise.
In addition to the vibration annoyance standards presented in Table 3.11 -6, the FTA also applies the following standards for construction vibration damage. As shown in Table 3.11 -7, structural damage is possible for typical residential construction when the PPV exceeds 0.2 inch per second (in/sec).
This criterion is the threshold at which there is a risk of damage to normal dwellings.
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Table 3.11-7. Groundborne Vibration Impact Criteria (Structural Damage) Building Category PPV (in/sec) VdB
I. Reinforced-concrete, steel, or timber (no plaster) 0.5 102 II. Engineered concrete and masonry (no plaster) 0.3 98 III. Non-engineered timber and masonry buildings 0.2 94 IV. Buildings extremely susceptible to vibration damage 0.12 90 Source: Federal Transit Administration (FTA), Transit Noise and Vibration Impact Assessment, September 2018.
Note: RMS = Root Mean Square (RMS) velocity calculated from vibration level (VdB) using the reference of one microinch/second.
3.11.4 Project Impact Analysis
Threshold #1: Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excel of standards established in the location general plan or noise ordinance, or applicable standards of other agencies.
Construction Noise
This section addresses the construction noise impacts associated with the project to determine if they would result in the exposure of persons to or generation of noise level in excess of applicable noise standards. Construction noise represents a short -term impact on the ambient noise levels.
Noise generated by construction equipment includes haul trucks, water trucks, graders, dozers, loaders, and scrapers can reach relatively high levels. Grading activities typically represent one of the highest potentia l sources for noise impacts. The most effective method of controlling construction noise is through local control of construction hours and by limiting the hours of construction to normal weekday working hours. As stated above, the City of San Marcos Municipal Code does not set noise limits on construction activities. Commonly, the City utilizes the County of San Diego’s Noise Ordinance Section 36.410 noise limit of 75 dBA at any existing sensitive receptor for construction activities.
The U.S. Environmental Protection Agency (USEPA) has compiled data regarding the noise generating characteristics of specific types of construction equipment. Noise levels generated by heavy construction equipment can range from 60 dBA to in excess of 100 dBA when measured at 50 feet.
However, these noise levels diminish rapidly with distance from the construction site at a rate of approximately 6 dBA per doubling of distance. For example, a noise level of 75 dBA measured at 50 feet from the noise source to the receptor would b e reduced to 69 dBA at 100 feet from the source to the receptor and reduced to 63 dBA at 200 feet from the source.
LDN used a point -source noise prediction model to calculate the expected construction noise impacts (LDN 2021 c). The essential model input da ta for these performance equations include the source levels of each type of equipment, relative source to receiver horizontal and vertical separations, the amount of time the equipment is operating in a given day, also referred to as the duty-cycle and any transmission loss from topography or barriers.
The equipment needed for the proposed project will consist of a large bulldozer, a water truck, a medium sized front loader, a medium sized crawler type excavator, a large highway haul truck, a small to medi um sized road grader, and a medium sized rubber tire backhoe. Based on the EPA
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noise emissions, empirical data and the amount of equipment needed, worst case noise levels from the construction equipment for site preparation would occur during the grading operations.
Additionally, the project will require a rock crusher and may require blasting, which would also require the need for a rock drill . This equipment is utilized separately from the grading equipment and is discussed in more detail below.
Grading
The grading activities will consist of the preparation of internal roadways, parking, and the finished pads. The equipment will be spread out over the project site from distances near the occupied property lines to distances of 500 feet or more away. Based upon the site plan , the majority of the grading operations, on average, will occur more than 200 feet from the property lines. This means that most of the time the average distance from all the equipment to the nearest property line is 200 feet.
As shown i n Table 3.11-8, cumulative noise levels would be 82.4 dBA at 50 feet away. A n average distance of 200 feet from the construction activities to the nearest property line would result in a noise attenuation of 12.0 dBA without shielding , resulting in 70.4 dB A. Therefore, the noise levels from construction equipment will comply with the 75 dBA Leq standard at the property lines .
Therefore, a less than significant impact is anticipated during grading and no mitigation is required .
Additionally, all equipment should be properly fitted with mufflers and all staging and maintenance should be conducted as far away for the existing residence as possible.
Table 3.11-8. Construction Noise Levels
Equipment Type Quantity Used Source @ 50 Feet
(dBA)
Cumulative Noise
Level @ 50 Feet (dBA)
Tractor/Backhoe 1 72 72.0
Dozer D9 Cat 1 74 74.0
Loader/Grader 1 73 73.0
Excavator 1 72 72.0
Water Truck 1 70 70.0
Haul Truck 1 75 75.0
Paver/Blade 1 75 75.0
Cumulative Level 82.4
Distance to Sensitive Uses 200
Noise Reduction due to Distance -12.0
Property Line Noise Level 70.4
Source: LDN Consulting 2021c
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Blasting and Rock Drilling
Areas of the project site that require deeper cuts and where the native material is not easily rip pable (graded) may require blasting and the use of a rock drill. The rock drill would be moved around the site on an as needed basis dependent upon the site characteristics. The use of a rock drill would occur independently of all other proposed equipment. The drilling and blasting activities would occur in one area and then the grading equipment would relocate or remove the debris. To determine the worst-case noise levels from the drilling operations , the noise level from the rock drill is assumed to be 85.0 dBA at 50 feet. Utilizing a 6 dBA reduction per doubling of distance, at an average distance of 160 feet from any property line, the noise levels will comply with the 75 dBA standard as shown in Table 3.11-9.
Table 3.11-9. Construction Noise Levels
Construction Equipment Quantity Source @ 50
Feet (dBA)
Duty Cycle
(Hours/Day)
Noise Level @ 50
Feet (dBA)
Rock Drill 1 85 8 85.0
Noise Reduction Needed to Comply -10.0
Distance Required to Reduce Noise Levels 160
Nearest Property Line Noise Level 74.9
Source: LDN Consulting 2021c
However, in the event that a rock drill is staged within 160 feet of any occupied noise sensitive land use, noise levels would exceed the 75 dBA exterior noise threshold. This represents a significant impact (Impact N -1) and mitigation is required . Additionally, the project would comply with all provisions identified in the City’s Municipal Code Section 17.60.06 as it relates to blasting and blasting shall only be permitted between the hours of 9:00 AM and 4:00 PM during any weekday. • Impact N-1 Depending on the staging location of a rock drill, noise levels may exceed the 75 dBA exterior noise threshold.
Rock Crushing
This section examines the potential noise source impacts associated with the operation of the proposed temporary rock crushing equipment. The project may utiliz e a Thunderbird Hazemag Impact Crushing Plant Model CP300 rock crusher, or equivalent as proposed by the applicant. City’s Municipal Code limits the rock crusher to operate between the hours of 7:00 AM and 4:30 PM , Monday through Friday. Rock crushing is n ot allowed on weekends or holidays. According to the project applicant, rock crushing is only anticipated to occur for several weeks once the material is required. The crusher would be located at the northern grading limits of the project, adjacent to E.
Barham Drive, approximately 500 feet from the nearest single -family residences to the east, 500 feet from the nearest single -family residences to the west, and 465 feet from the church and preschool to the west. Based on empirical data collected at a material processing plant in the City of Upland noise levels from a rock crusher ranged between 80 -86 dBA at 45 feet (LDN 2011). A worst- case noise level of 86 dBA Leq at 45 feet was utilized for the analysis.
Although the City does not have a specific noise thr eshold for rock crushing in the municipal code or in the General Plan, historically the City has required that noise levels from the proposed temporary rock crusher maintain noise levels of 60 dBA or less at surrounding single -family residences, 65 dBA
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at multi-family uses, and 70 dBA at all commercial uses. The City updated the municipal code with the approval to amend Chapter 20 in 2017. Specifically, the amendment established under Chapter
20.300.070 (Performance Standards) regulating exterior noise stan dards required that noise levels from the sources are maintained at 60 dBA or less at surrounding single -family residences, and 65 dBA at multi -family and all commercial uses . Although rock crushing activities are part of the construction phase of project development the City has applied these standards to rock crushers.
Table 3.11 -10 presents the anticipated rock crushing noise levels. As shown in Table 3.11 -10, distance alone is not adequate enough to achieve the City’s 60 dBA Leq standard at the single-family residences or the City’s 65 dBA Leq standard at the Church and preschool . Given this, the noise levels are anticipated to be above the City’s 60 dBA Leq standard at the residences and 65 dBA Leq standard at the Church and preschool, for the rock crus her. This represents a significant impact
(Impact N-2) and mitigation is required during rock crushing activities . As can be seen in Table 3.11 - 10, a five-decibel reduction is needed to reduce the noise level to 60 dBA Leq at the residences and a 0.7 decibel reduction is needed at the church and preschool. • Impact N-2 Noise levels resulting from rock crushing operations would exceed the City’s 60 dBA Leq standard at the single -family residences and the City’s 65 dBA Leq standard at the adjacent church and preschool.
Table 3.11-10. Rock Crushing Noise Levels
Sensitive Use
Rock Crusher
Noise Level
@ 45 Feet
(dBA Leq)
Distance
to
Sensitive
Use (Feet)
Noise
Reduction
due to
Distance
(dBA Leq)
Noise
Level @
Sensitive
Uses (dBA
Leq)
Noise
Threshold
(dBA Leq)
Reduction
Needed
(dBA Leq)
Single-Family
Residential 86 505 -21.0 65.0 60 5.0
Church/ Preschool 465 -20.3 65.7 65 0.7
Source: LDN Consulting 2021c
Cumulative Construction Noise
Sound levels are logarithmic not linear, so adding two sources of 68 dBA plus 68 dBA is equal to 71 dBA not 136 dBA. Sound levels that are separated by more than ten decibels generally do not cumulatively add to each other . The rock crusher noise level (60.0 dBA after mitigated ) and the grading noise level (74.8 dBA) are not an ticipated to add to each based on the difference between the two noise levels and the separation of the equipment. Therefore, the rock crusher and grading operations cumulatively would not exceed the 75 dBA Leq standard average over 8 hours at the property lines. Additionally, the rock drill and grading equipment will be separated from each other, typically by several hundred feet and working near different property lines and are not anticipated to cumulatively increase the noise level at a specific property line.
Operational Noise
This section addresses the operational noise impacts associated with the project to determine if they would result in the exposure of persons to or generation of noise level in excess of applicable noise standards.
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Future Onsite Roadway Noise
To determine the future noise environment and impact potential resulting from increased traffic associated with the proposed project, the Sound32 model was utilized. The critical model input parameters, which determine the projected vehicular traffic noise levels, incl ude vehicle travel speeds, the percentages of automobiles, medium trucks, and heavy trucks in the roadway volume, the site conditions, and the peak hour traffic volume. The peak hour traffic volumes range between six to 12 percent of the average daily traf fic (ADT) and ten percent is generally acceptable for noise modeling.
Table 3.11-11 presents the roadway parameters used in the analysis including the peak traffic volumes, vehicle speeds, and the hourly traffic flow distribution (vehicle mix). The vehicle mix provides the hourly distribution percentages of automobile, medium trucks, and heavy trucks for input into the Sound32 model. The Buildout conditions for E. Barham Drive include the future year 2050 traffic volume forecasts provided in traffic study prepared for the project (LLG 2021).
Table 3.11-11. Future Traffic Parameters
Roadway
Average Daily
Traffic
(ADT)(1)
Peak Hour
Volumes(1)
Modeled
Speeds
(MPH)
Vehicle Mix %(2)
Auto Medium
Trucks
Heavy
Trucks
SR-78 West - 6,300 65 95.52 2.1 2.4
SR-78 East - 8,400 65 95.52 2.1 2.4
E. Barham Drive 19,040 1,904 45 96 2 2
Source: LDN Consulting 2021c
1 Traffic speeds from the project traffic report prepared by LLG 2021 2 Typical city vehicle mix
The required coordinate information necessary for the Sound32 model input was taken from the conceptual site plans provided by SB&O dated 2020. The conceptual plans were used to identify the pad elevations, roadway elevations, and the relationship between the noise source(s) and the outdoor receptor areas. The modeled observer locations for the outdoor use areas are shown in Figure 3.11-2.
The modeling results for the ground level patios are shown in Table 3.11-12. As shown, ground floor noise levels would exceed the 65 dBA exterior threshold as stated in the City’s General Plan Noise Element for the units at the top of slopes along E. Barham Drive facing SR -78 (Receptors 2 -4, 6-7, 10-14, and 16). This represents a significant impact (Impact N-3) and mitigation is required. • Impact N-3 Noise levels at 11 receptors at the top of slopes along E. Barham Drive facing SR-78 are modeled to exceed the City’s General Plan Noise Element 65 dBA exterior noise threshold.
Table 3.11-12. Future Exterior Noise Levels (Ground Level) Receptor
Number Receptor Location
Unmitigated
Ground Level Noise
Levels (dBA CNEL)
Barrier Heights
(Feet)
Mitigated Ground
Floor Noise Levels
(dBA CNEL)
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Receptor
Number Receptor Location
Unmitigated
Ground Level Noise
Levels (dBA CNEL)
Barrier Heights
(Feet)
Mitigated Ground
Floor Noise Levels
(dBA CNEL)
1 Building 8 54 0 54
2 Building 7 69 8 64
3 Building 7 70 8 65
4 Building 7 70 8 65
5 Building 8 65 0 65
6 Building 1 71 8 64
7 Building 2 71 8 65
8 Building 2 64 0 60
9 Building 3 65 0 62
10 Building 3 72 8 and 6(1) 64
11 Building 4 74 8 64
12 Building 5 72 8 65
13 Building 6 74 8 65
14 Building 6 69 8 62
15 Rec Area 1 62 0 61
16 Rec Area 2 68 0 63
17 Rec Area 3 65 0 65
Source: LDN Consulting 2021c
Note: (1) See Figure 3.11-4
The modeling results for the buildout analysis are quantitatively shown in and Tables 3.11 -13 and
3.11-14 for the second and third floor balconies . As shown, noise levels would exceed the 65 dBA exterior threshold at the second and third floor balconies for the units facing E. Barham Drive and SR-78 and farther back (Receptors 2 -14). This represents a significant impact (Impact N -4) and mitigation is required.
• Impact N-4 Noise levels at 13 receptors on second and third floor balconies facing E.
Barham Drive and SR -78 are modeled to exceed the City’s General Plan Noise Element 65 dBA exterior noise threshold.
Table 3.11-13. Future Exterior Noise Levels (Second Level) Receptor
Number Receptor Location
Unmitigated
Ground Level Noise
Levels
(dBA CNEL)
Barrier Heights
(Feet)
Mitigated Ground
Floor Noise Levels
(dBA CNEL)
1 Building 8 56 0 56
2 Building 7 70 7 63
3 Building 7 71 7 64
4 Building 7 71 7 63
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Receptor
Number Receptor Location
Unmitigated
Ground Level Noise
Levels
(dBA CNEL)
Barrier Heights
(Feet)
Mitigated Ground
Floor Noise Levels
(dBA CNEL)
5 Building 8 66 5 64
6 Building 1 73 7 65
7 Building 2 74 7 65
8 Building 2 66 5 61
9 Building 3 66 0 65
10 Building 3 75 7 64
11 Building 4 77 7 64
12 Building 5 74 7 63
13 Building 6 77 7 65
14 Building 6 72 7 65
Source: LDN Consulting 2021c
Table 3.11-14. Future Exterior Noise Levels (Third Level) Receptor
Number Receptor Location
Unmitigated
Ground Level Noise
Levels
(dBA CNEL)
Barrier Heights
(Feet)
Mitigated Ground
Floor Noise Levels
(dBA CNEL)
1 Building 8 61 0 61
2 Building 7 71 7 63
3 Building 7 72 7 63
4 Building 7 72 7 63
5 Building 8 67 5 64
6 Building 1 75 7 64
7 Building 2 76 7 64
8 Building 2 77 7 64
9 Building 3 68 5 64
10 Building 3 75 7 64
11 Building 4 77 7 64
12 Building 5 74 7 63
13 Building 6 77 7 64
14 Building 6 72 5 65
Source: LDN Consulting 2021c
Onsite Rail Line Noise
The proposed project is located approximately 500 feet from the San Diego Northern Railroad consisting of SPRINTER service operated by the North County Transit District . According to the City of
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San Marcos General Plan Noise Element, the 65 dBA CNEL noise contour from the rail activity, with no shielding, is located 130 feet from the centerline of the railroad. Noise levels from train activity would be reduced to less than 60 dBA CNEL at the project site and would not significantly impact the noise levels at the receptors. Therefore, no impact related to rail line noise is identified.
Project Related Offsite Transportation Noise
To determine if direct or cumulative off-site noise level increases associated with the development of the proposed project would create noise impacts, the traffic volumes for the existing conditions were compared with the traffic volume increase of existing plus the proposed project. According to the project traffic study, the project is estimated to only generate 1,208 daily trips w ith a peak hour volume of 119 trips (LLG 2021). The existing traffic volumes on adjacent E. Barham Drive is 18,025 ADT. Typically, it requires a project to double (or add 100%) the traffic volumes to have a direct impact of 3 dBA CNEL or be a major contrib utor to the cumulative traffic volumes. The project will add less than a 1 0% increase to E. Barham Drive volumes. Therefore, no direct or cumulative impacts are anticipated. Impacts would be less than significant.
Threshold #2: Generation of excessive groundborne vibration or groundborne noise levels.
This section analyzes the potential for the project to expose person to or generation of excessive vibration or groundborne noise. Proposed residential uses would not be characterized as creating excessive vibration during project operation. The noise modeling is based upon project construction details and schedule provided by the project applicant.
The nearest vibration-sensitive uses to the project site are the residences located 100 feet or more from the pro posed construction. The FTA has determined the vibration levels that would cause annoyance to a substantial number of people and potential damage to building structures. As presented in Table 3.11 -7, the FTA criterion for infrequent vibration induced annoy ance is 80 Vibration Velocity (VdB) for residential uses . As shown in Table 3.11 -7, the FTA criterion for vibration induced structural damage is 0.2 in/sec PPV.
Construction Equipment
Table 3.11-15 lists the average vibration levels that would be experienced at th e nearest vibration sensitive uses (residences located 100 feet or more from construction ) from temporary construction activities. As shown, project-related construction activities would result in PPV levels below the FTA’s criteria for vibration-induced structural damage. Therefore, construction activities would not result in vibration-induced structural damage to residential buildings near the construction areas.
Additionally, construction activities would generate levels of vibration that would n ot exceed the FTA criteria for nuisance for nearby residential uses. Therefore, vibration impacts from construction equipment would be less than significant.
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Table 3.11-15. Vibration Levels from Construction Activities (Residential Receptors) Equipment
Approximate
Velocity Level at
25 Feet
(VdB)
Approximate
RMS Velocity
at 25 Feet
(in/sec)
Approximate
Velocity Level at
100 Feet
(VdB)
Approximate
RMS Velocity at
100 Feet
(in/sec)
Small bulldozer 58 0.003 68.9 0.0111
Jackhammer 79 0.035 60.9 0.0044
Loaded trucks 86 0.076 67.9 0.0095
Large bulldozer 87 0.089 39.9 0.0004
FTA Criteria 80 0.2
Significant Impact? No No
Source: LDN Consulting 2021c
1 PPV at Distance D = PPVref x (25/D)1.5
Blasting Activities
As stated above, blasting may be required during the project grading and site preparation activities.
The project would comply with all provisions identified in the City’s Municipal Code Section 17.60.06 as it relates to blasting and vibration. Blasting shall only be permitted between the hours of 9:00 AM and 4:00 PM during any weekday. The project will be conditioned to these defined hours of operation and require a notification and inspection process to protect nearb y residents and residences from damage or injury due to blasting . Therefore, the project would not create excessive vibration or groundborne noise and impacts would be
less than significant.
3.11.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a project’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to noise, the cumulative analysis is based upon a list approach to determine the proposed project’s contributing effect on potential cumulative noise impacts.
As discussed above, future traffic noise levels were analyzed comparing existing traffic with existing plus proposed project traffic levels. This analysis accounts for reasonably foreseeable cumulative traffic levels in the vicinity of the project. As discussed previously, impacts would be less than significant.
3.11.6 Mitigation Measures
Implementation of the following mitigation measures would be required as a condition of project approval:
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Rock Drilling Noise (Impact N-1)
MM-N-1 If a rock drill is proposed within 160 feet of any occupied noise sensitive land use, a noise mitigation plan based upon the location of the construction equipment, topography and construction schedule shall be p repared by an acoustical engineer. If noise levels are determined to exceed City’s noise threshold of 60 dBA at any existing sensitive receptor, a mitigation plan shall be developed that may include a temporary noise barrier along any property line where the impacts could occur. A barrier ranging from 8 to 12 feet in height may be needed. The proposed noise barrier shall be of solid non -gapping material to adequately reduce construction noise levels below the noise threshold. The mitigation plan may also incorporate the usage of the equipment (amount of time used and/or the location in respect to the property line). The mitigation plan shall determine the final height and location of a temporary barrier if one is necessary.
The final mitigation design shall be reviewed and approved by the Planning Division Manager.
Rock Crusher Noise (Impact N-2)
MM-N-2 To minimize exterior noise levels related to rock crusher operation during construction and to comply with the City of San Marcos noise standards limiting noise levels to 60 dBA Leq at residences and 65 dBA Leq at the nearby church and preschool, barriers shall be constructed to break the line of sight from the rock crusher to a receptor. Assuming the rock crusher is 10 feet in height, the barrier must be at least 11 -12 feet in height to shield the crusher both visually and acoustically. The barrier may consist of an earthen berm, 5/8” plywood, 1 - inch acoustical blankets or any combination of these materials. The barriers shall be in place prior to t he commencement of rock crushing activities. The locations of crusher and placement of the required barriers are presented in Figure 3.11 -3.
The design of the barriers, including materials and color for any sound walls shall be subject to review and approval by the Planning Division Manager.
To ensure compliance with the City’s thresholds, noise measurements of the rock crusher should be conducted to determine the hourly noise level within the first week of operation once the final crusher type and location are determined . If noise levels are found to be above the established thresholds of 60 dBA Leq at any existing single family residential use, 65 dBA Leq for any multifamily use or 65 dBA Leq at a commercial use then additional mitigation in the form of higher barriers, sound absorbing materials or operational limits on the crusher usage shall be incorporated.
Future Onsite Roadway Noise (Impact N-3 and N-4)
MM-N-3 To minimize on-site exterior ground floor noise levels and to comply with the City of San Ma rcos noise standards, 6 -8-foot barriers shall be constructed along the units adjacent to E. Barham Drive. The barriers shall be in place prior to project occupancy and shall be constructed of a non -gapping material (i.e., of masonry, ½ inch thick glass, ea rthen berm, or any combination of these materials). The locations of barriers are presented in Figure 3.11 -4. The design of the barriers,
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including materials and color for any sound walls shall be subject to review and approval by the Planning Division Manager.
MM-N-4 To minimize on -site exterior second and third floor balcony noise levels and to comply with the City of San Marcos noise standards, open decks, and balconies for the units adjacent to E. Barham Drive and additional units, as shown on Figure 3.11 -5, shall require barriers to reduce sound levels . The barriers will range from 5 feet to 7 feet, as shown on Figure 3.11-5, and shall be in place prior to project occupancy and shall be constructed of a non -gapping material (i.e., masonry, 1/4 inch thick glass, or Plexiglass) . The design of the barriers shall be subject to review and approval by the Planning Division Manager.
MM-N-5 To ensure compliance with the CCR Title 24 interior noise threshold of 45 dBA CNEL, a final noise assessment s hall be performed prior to the issuance of building permits. This final report shall identify the interior noise requirements based on architectural and building plans to meet the City’s established interior noise limit. The identified interior noise requirements, which may include conventional building construction methods and providing a closed window condition requiring a means of mechanical ventilation (e.g., air condition) for each building and upgraded windows for all sensitive rooms (e.g., bedrooms a nd living spaces), shall also be in place prior to occupancy of the residences adjacent to E. Barham Drive.
3.11.7 Conclusion
General project construction and grading would not exceed the 75dBA threshold. However, p otential noise impacts could occur d epending on the staging location of a rock driller and during rock crushing. Implementation of mitigation measure MM-N-1 and N-2 would reduce noise levels to below a level of significance by breaking line of sight from the noise source to ensure rock drilling and crushing operations comply with City standards. Implementation of the project would increase ambient noise levels in the project vicinity both temporarily and permanently. Operational noise impacts at the project site would exceed the City’s General Plan Noise Element 65 dBA exterior noise threshold at the proposed units located along E. Barham Drive at the ground floor levels and second and third floor balconies. As shown in Tables 3.11 -12 to 3.11 -14, incorporation of mitigation measure MM-N-3 and MM -N-4 would ensure exterior noise levels at the project site are compliant with the City’s thresholds by constructing noise barriers to reduce on -site noise. Additionally, since noise levels are modeled to exceed the City’s General Plan Noise Element 6 5 dBA exterior noise threshold, an interior noise assessment is required per CCR Title 24 to ensure the interior noise threshold of 45 dBA CNEL is met. Incorporation of mitigation measure MM -N-5 would ensure interior noise levels would meet the City’s threshold. With in corporation of these mitigation measures, noise impacts related to project implementation would be reduced to below a level of significance.
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Figure 3.11-1. Ambient Monitoring Locations
Source: LDN 2021c
ML 1
SR-78
E BARHAM DR
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Figure 3.11-2. Modeled Receptor Locations
Source: LDN 2021c
1 Modeled Receptors 17
3 4
2 5
6 10
9 7
8 11 12 13
14 15
16 17
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Figure 3.11-3. Preliminary Rock Crusher Location and Mitigation
Rock Crusher
Mitigation
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Figure 3.11-4. Ground Level Mitigation Measures
8’
8’ 8’
6’
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Figure 3.11-5. Upper Level Mitigation Measures
Upper Floor
Balconies requiring
7 Foot Barriers
Upper Floor
Balconies requiring
5 Foot Barriers
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3.12 Population and Housing
This section analyzes the potential for impacts related to population and housing resulting from development of the proposed project . This section considers population and housing characteristics in the area and discusses project consistency with regional growth projections.
In the Initial Study prepared for the proposed project (Appendix B.1), implementation of the proposed project was determined to have no impacts related to the displacement of housing or people. There is no existing housing on the project site and the project site is vacant. A previous residential structure and associated outbuildings were removed in the 1980s. Therefore, the construction of the proposed project would not displace a substantial number of existing homes, necessitating the construction of replacement housing elsewhere, nor would it displace a substantia l number of people. This issue is not discussed further in this section. Section 5. 7, Environmental Effects Found Not to Be Significant – Population and Housing, of the Environmental Impact Report (EIR) provides additional information on this topic.
Table 3.12-1 summarizes the project- and cumulative-impact analysis by threshold for the proposed project.
Table 3.12-1. Population/Housing Summary of Impacts
Threshold of Significance Project-Level Impact Cumulative-Level Impact
Impact After
Mitigation
Threshold #1: 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
Less than
Significant
Less than
Significant
3.12.1 Existing Conditions
This section provides background information regarding population and housing forecasts for the City of San Marcos based upon demographic information from the San Diego Association of Governments (SANDAG).
Population
As of January 1, 2020, the California Department of Finance (DOF) estimates the population of the City is 97,209 (DOF 2020). Based on growth projections provided by the Series 13: 2050 Regional Growth Forecast prepared by S ANDAG, it is estimated that the City’s population growth will reach 109,095 persons by 2035, and 113,015 persons by 2050 (SANDAG 2013).
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Housing
As of January 1, 2020, the City of San Marcos had 32,460 housing units. The housing stock is comprised of approx imately 58.4 percent single -family detached and attached units, and approximately 31 percent multi- family units. Approximately 10.3 percent of the housing stock as of January 2020 consisted of mobile homes (DOF 2020). Based on the Series 13: 2050 Regional Growth Forecast, the City is expected to have 37,337 housing units by 2050 (SANDAG 2013).
3.12.2 Regulatory Setting
This section describes the local regulatory setting as it relates to population and housing for the proposed project.
State
California Planning and Zoning Law
The legal framework within which California counties and cities exercise local planning and land use functions is provided in the California Planning and Zoning Law (Sections 65000 through 66499.58 of the California Government Code) . Under that law, each county and city must adopt a comprehensive, long -term general plan. The law gives counties and cities wide latitude in how a jurisdiction may create a general plan, but there are fundamental requirements that must be met.
The require ments include seven mandatory elements described in the Government Code. Each element must contain text and descriptions setting forth objectives, principles, standards, policies, and plan proposals; diagrams and maps that incorporate data and analysis; an d implementation measures.
Once the general plan of a county or city is adopted, it should be construed as a dynamic document, for which adaptability is a key component. Each jurisdiction frequently reviews its general plan for consistency and to ensure it addresses growth-related issues in a comprehensive manner. State law allows up to four general plan amendments per general plan element per year, so each jurisdiction can make changes as justified.
California Building Standards Code
In 2001, California co nsolidated the Uniform Building, Plumbing, Electrical, and Mechanical codes into the California Building Standards Code, which is contained in Title 24 of the California Code of Regulations. The California Building Standards Code contains 11 parts: Electrical Code, Plumbing Code, Administrative Code, Mechanical Code, Energy Code, Residential Building Code, Historical Building Code, Fire Code, Existing Building Code, Green Building Standards Code, and the Reference Standards Code. These codes promote public health and safety and ensure that safe and decent housing is constructed in the City.
Senate Bill 375
Senate Bill 375 (codified in the Government Code and Public Resources Code), took effect in 2008 and provides a new planning process to coordinate land us e planning, regional transportation plans, and funding priorities in order to help California meet the greenhouse gas (GHG) reduction goals established in Assembly Bill 32. Senate Bill 375 requires metropolitan planning organizations to incorporate a Sustainable Communities Strategy (SCS) in their Regional Transportation Plans (RTPs) that will achieve GHG emissions reduction targets by reducing vehicle miles traveled from light -duty vehicles through the development of more compact, complete, and efficient communities.
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Regional Housing Needs Assessment
A Regional Housing Needs Assessment (RHNA) is mandated by State Housing Law as part of the periodic process of updating local housing elements of the General Plan. The RHNA quantifies the need for housing within each jurisdiction during specified planning periods. Communities use the RHNA in land use planning, prioritizing local resource allocation, and in deciding how to address identified existing and future housing needs resulting from population, employment, and household growth. The RHNA does not necessarily encourage or promote growth, but rather allows communities to anticipate growth, so that collectively the region and subregion can grow in ways that enhance quality of life, improve access to jobs, promotes transportation mobility, and addresses social equity, fair share housing needs.
Regional
San Diego Association of Governments
SANDAG is a public agency, composed of 18 cities and the County of San Diego, which builds strategic plans guiding the San Die go region in land use, growth, economics, and the environment.
SANDAG also provides population and housing estimates for the region, which are based, in part, on local jurisdictional planning data and inform regional planning.
The SANDAG Regional Comprehen sive Plan, adopted in 2004, provides a long -term planning framework for the San Diego region (SANDAG 2004). The Regional Comprehensive Plan identified smart growth and sustainable development as important strategies to direct the region’s future growth tow ard compact, mixed -use development in urbanized communities that already have existing and planned infrastructure, and then connecting those communities with a variety of transportation choices.
In 2011, SANDAG approved the 2050 Regional Transportation Pla n and Sustainable Communities Strategy (RTP/SCS). This approval marked the first time SANDAG’s RTP included a sustainable communities strategy, consistent with the Sustainable Communities and Climate Protection Act of 2008, also known as Senate Bill 375. T his RTP/SCS provided a blueprint to improve mobility, preserve open space, and create communities, all with transportation choices to reduce greenhouse gas emissions and meet specific targets set by the California Air Resources Board (CARB) as required by the 2008 Sustainable Communities and Climate Protection Act. In 2010, CARB established targets for each region in California governed by a metropolitan planning organization.
SANDAG is the metropolitan planning organization for the San Diego region.
San Diego Forward: The Regional Plan
SANDAG is required by law to update its regional transportation plan every 4 years. In October 2015, SANDAG adopted the most recent update to its RTP/SCS. SANDAG’s 2015 RTP/SCS, known as San Diego Forward: The Regional Plan ( Regional Plan), integrates the elements of the prior Regional Comprehensive Plan and combines those elements with the Regional Plan. SANDAG is currently preparing the 2021 Regional Plan. While work is in progress on the 2021 Regional Plan, SANDAG prepared a 2019 Federal Regional Transportation Plan (2019 Federal RTP) that complied with federal requirements for the development of regional transportation plans, retains air quality conformity approval from the US Department of Transportation, and preserved fun ding for the region’s transportation investment. The 2019 Federal RTP builds on the 2015 Regional Plan.
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The Regional Plan updates growth forecasts and is based on the most recent planning assumptions considering currently adopted land use plans, including the City’s General Plan and other factors from the cities in the region and the County. SANDAG’s Regional Plan will change in response to the ongoing land use planning of the City and other jurisdictions. For example, the City’s General Plan, and other local General Plans of cities, may change based on General Plan amendments initiated by the jurisdiction or landowner applicants. The General Plan amendments may result in increases in development densities by amending the regional category designations or zoning classifications.
Accordingly, SANDAG’s RTP/SCS latest forecasts of future development in the San Diego region, including location, must be coordinated closely with each jurisdiction’s ongoing land use planning because that planning is not static, as r ecognized by the need for updates to SANDAG’s RTP/SCS every 4 years.
Regional Growth Forecast
SANDAG estimates future population, housing, land use, and economic growth throughout San Diego County and its comprising cities, including the City of San Marcos . On October 13, 2013, SANDAG accepted the Series 13: 2050 Regional Growth Forecast. This forecast serves as the foundation for San Diego Forward: The Regional Plan and other planning documents across the region. SANDAG growth projections for the region and for the City of San Marcos are outlined in Table 3.12-2 below.
Table 3.12-2. Forecasted Growth for the San Diego Region and the City of San Marcos Jurisdiction
Year Change 2020-2050
2020 2035 2050 Numeric Percent
Population
San Diego Regional 3,435,713 3,853,698 4,068,759 633,046 18.4% City of San Marcos 98,915 109,095 113,015 14,100 14.3%
Housing
San Diego Regional 1,249,654 1,394,688 1,491,804 242,150 19.4% City of San Marcos 32,625 35,795 37,337 4,712 14.4%
Employment
San Diego Regional 1,624,124 1,769,938 1,911,405 287,281 17.7% City of San Marcos 45,783 54,902 64,328 18,545 40.5%
Source: SANDAG 2013
The City of San Marcos is expected to experience a slower growth rate for population and housing, and a higher employment growth rate when compared to the entire region of San Diego. It should also be noted that the 2050 Regional Growth Forecast is not intended to be an exact formula utilized to determine growth in the region and comprising jurisdictions; rather it should be utilized as a starting point for regional planning.
Regional Housing Needs Assessment
Based on a methodology that weighs a number of f actors (i.e., projected population growth, employment, commute patterns, and available sites), SANDAG determined quantifiable needs for housing units in the region according to various income categories. In its final Regional Housing Needs Assessment figur es, SANDAG allocated 3,116 housing units to the San Marcos area for the
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2020– 2030 Housing Element Cycle, including 1,258 housing units for very low - and low -income households (SANDAG 2020). After credits for constructed units (546) and approved units (1.039) are taken into consideration, the City has a remaining 2021 -2029 RHNA of 1,585, including 640 extremely/very low -income, 475 low -income, and 414 above moderate -income units (City of San Marcos 2021).
Local
City of San Marcos General Plan
The City’s Housing Element identifies three goals and associated policies to provide a basis for housing and growth projections in the City . The following goals and policies from the City of San Marcos General Plan, Housing Element pertain to population and housing:
• Goal H-1: Provide a broad range of housing opportunities with emphasis on providing housing which meets the special needs of the community.
o Policy 1.1: Designate land for a variety of residential densities sufficient to meet the housing needs fo r a variety of household sizes and income levels, with higher densities being focused in the vicinity of transit stops and in proximity to significant concentrations of employment opportunities.
• Goal H -2: Protect, encourage, and provide housing opportuniti es for persons of lower and moderate incomes.
• Goal H -4: Reduce or remove governmental constraints to the development, improvement, and maintenance of housing where feasible and legally permissible. o Policy 4.4: Balance the need to protect and preserve the n atural environment with the need to provide additional housing and employment opportunities.
The proposed project’s consistency with applicable General Plan goals and policies is discussed in Table 3.10-5 in Section 3.10, Land Use and Planning, of this EIR . As detailed in Section 3.10.4, the project is consistent with the applicable goals and policies pertaining to population and housing.
The City has prepared a draft of their 2021 -29 Housing Element . At the time of publication of the draft 2021 -29 Housing Element, the City had already constructed approximately 50 percent (approximately 1,585 units) of its RHNA allocation of 3,116 units with housing units constructed , under construction, or approved . Based on a sites inventory assessment, the City has the ab ility to adequately accommodate the remaining RHNA requirements within land that currently permits residential development (comprised of proposed applications, vacant residential sites, and vacant land in Specific Plan Areas). The project site is not ident ified within the City’s draft 2021 -29 Housing Element as a site that could contribute to the RHNA allocation (City of San Marcos 2021).
3.12.3 Thresholds of Significance
Appendix G of the California Environmental Quality Act (CEQA) Guidelines provides thresholds for determining significant environmental impacts. A project may be deemed to have a significant impact to population and housing if it would:
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• Threshold #1: 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).
3.12.4 Project Impact Analysis
Threshold #1: Induce substantial population growth in an area, either directly (e.g., by proposing new homes and businesses) or indirectly (e.g., through extension of roads or other infrastructure).
Increases in population, housing, and employment are generally considered to be social or economic effects, as opposed to physical effects, which are the focu s of CEQA analysis. There are circumstances where social and economic changes could indirectly cause physical environmental impacts or result in changes to environmental resources, such as air quality, traffic, or noise levels.
In other situations, lead ag encies may evaluate social or economic change related to a physical change in determining whether the physical change is significant (CEQA Guidelines Section 15131).
The approximately 10.56-acre project site is located entirely within the City of San Marcos. A General Plan Amendment is required to re-designate the project site from Mixed-Use 3 (MU3) to Specific Plan Area (SPA). A rezone is also required to re -designate the project site from Mixed -Use-3 to SPA. The General Plan Amendment and Rezone would all ow the Specific Plan to provide rules and regulations for development of the project site.
Construction of the proposed project would represent a temporary increase in construction employment. Given the relatively common nature and scale of the constructio n associated with the proposed project, the demand for construction employment would likely be met within the existing and future labor market in the City and North County San Diego area. The size of the construction workforce would vary during the differe nt stages of construction, but a substantial quantity of workers from outside the local area would not be expected to relocate permanently.
The proposed project would directly induce growth through the development of 151 multi -family residential dwelling u nits, resulting in a gross density of approximately 1 4.3 dwelling units per acre.
Based on the population rate of 3.1 persons per dwelling unit, the proposed project would directly induce population growth to the area and would potentially add an estimated 469 people to the area. The proposed project would not, however, indirectly induce a growth in population as no extension of infrastructure is proposed beyond what is required to adequately serve the proposed project. Additionally, the majority of the sur rounding area is developed. The SANDAG population growth forecasts rely, in part, on individual jurisdiction’s planning documents, such as the City’s General Plan. Because the project proposes a General Plan Amendment and Rezone, the estimated population of 469 people would not have been accounted for in SANDAG’s projections. Therefore, the project’s induced population would exceed these projections. However, determination of impacts related to population growth are based upon whether the induced growth wou ld be considered substantial.
As shown in Table 3.12 -2 above, the City’s population is projected to grow from 98,9 15 people in 2020 to 10 9,095 people by 2035 (an increase of 10,180 people). The population increase of 4 69 people would account for 4.6% of SANDAG’s projected population growth.
There is no hardline number or percentage available to determine whether or not this estimated introduction of 469 people (4.6% of projected growth) could be considered a substantial increase in population. However, SANDAG’s 2050 Regional Growth Forecast is intended to be used as a starting point for regional planning as opposed to a prescribed growth pattern. Although the City determined
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that there are adequate sites available with appropriate designations/zoning to acco mmodate the remaining RHNA allocation for the current Housing Element planning period, the City has the discretion to adjust allocated housing units/sites as necessary to balance proposed plans for residential development with approved/constructed resident ial development (City of San Marcos 2021). Therefore, while the proposed project would directly induce growth beyond current estimates and forecasts, it would not be considered substantially growth inducing, and impacts would be less than significant.
3.12.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a project’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect.
As discussed above, the proposed project would introduce an estimated 4 69 people resulting from the development of 151 residential units. Based upon regional projections, comparisons to current land use designations, and comparison with the RHNA p lanning periods, the introduction of the estimated 469 people would not be considered substantial. Impacts would be less than significant.
The cumulative projects listed in Table 2 -3 would either directly or indirectly induce population growth. Projects th at include residential development may increase population in the City similar to the proposed project. These cumulative projects include various residential and mixed -use development projects listed in Table 2 -3, including single -family residential, mult i-family (affordable and market rate) and student housing. In addition, commercial development is proposed or approved, which can indirectly lead to population growth in the City and surrounding areas. The introduction of a new population is not, in and of itself, a significant impact. As with a project level analysis, the significance of a cumulative population impact is determined by whether the population growth resulting from the combined cumulative projects would be considered substantial.
Further, the project would not result in the removal of a barrier of growth that would reasonably result in the intensification or development of land. All utility and infrastructure improvements would be sized to only adequately serve the proposed project (see Section 3.17, Utilities and Service Systems). Additionally, because the project is surrounded by existing development, it is unlikely that the approval and construction of the project would lead to an intensification of the land uses in the immediate vicinity of the site. Therefore, a cumulative impact would not occur.
3.12.6 Mitigation Measures
Based upon the analysis presented in sections 3.12.4 and 3.12.5, impacts were determined to be less than significant. No mitigation measures are required.
3.12.7 Conclusion
Physical impacts related to population growth associated with the proposed project are addressed throughout the topic -specific chapters of this EIR. See Sections 3.1, Aesthetics, through 3.1 8, Wildfire. When significant impacts were identified in the EIR, mitigation measures have been
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identified to reduce impacts to below a level of significance. The only impacts that will remain significant and unavoidable are a land use impact related to Mobility Element consistency (Year 2025 impact at Rancheros Drive/S R-78 WB) and a transportation impact related to vehicle miles traveled (VMT).
Construction of the proposed project would represent a temporary increase in construction employment. Given the relatively common nature and scale of the construction associated with the proposed project, the demand for construction employment would likely be met within the existing and future labor market in the City and North County San Diego area. The size of the construction workforce would vary during the different stages of construction, but a substantial quantity of workers from outside the local area would not be expected to relocate permanently. Impacts would be less than significant.
As discussed above, the proposed project would introduce an estimated 469 people resulting from the development of 151 multi-family residential units. Based upon regional projections, comparisons to current land use designations, and comparison with the RHNA planning periods, the introduction of the estimated 469 people would not be considered substantial. Impacts would be less than significant.
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3.13 Public Services
This section analyzes the potential impact of the proposed project on public services including fire protection services, police protection services, schools, parks, and libraries. Please see Section 3.16, Utilities and Service Systems, for an analysis of water, wastewater , energy, telecommunications, stormwater, and solid waste services. The analysis also considers the California Environmental Quality Act (CEQA) Guidelines Appendix G and applicable State and Local regulations, including the City of San Marcos General Plan. The General Plan is available on the City’s web site. 14 Service
provider letters are included in Appendix M of this document.
Table 3.13 -1 summarizes the project - and cumulative -level public services analysis impact, by threshold of significance.
Table 3.13-1 Public Services Summary of Impacts
Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
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:
Fire protection services Less than
Significant
Less than
Significant
Less than
Significant
Police protection services Less than
Significant
Less than
Significant
Less than
Significant
Schools Less than
Significant
Less than
Significant
Less than
Significant
Parks Less than
Significant
Less than
Significant
Less than
Significant
Other public facilities Less than
Significant
Less than
Significant
Less than
Significant
3.13.1 Existing Conditions
This section details the existing service providers and resources related to fire protection, police protection, schools, parks, and libraries.
Fire Protection
The project site is located within the San Marcos Fire Protection District (SMFPD) boundary. The SMFD would provide fire protection and emergency medical services to the project. The SMFD has existing automatic mutual aid fire agreements in place with the C ities of Carlsbad, Vista, Escondido, Encinitas, and the Rancho Santa Fe Fire Protection District. The SMFD has an Insurance Service Office (ISO) Rating 1, on a scale of one to ten with one being superior service. Ther e are four fire
14 http://www.san-marcos.net/work/economic-development/general-plan
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stations in t he City and their existing staffing resources are presented in Table 3.13-2. Fire station locations are presented in Figure 3.13-1 (City of San Marcos 2021a).
The proposed project would be primarily served by Fire Station No.3 at 404 Woodland Parkway.
According to correspondence with the San Marcos Fire Department, current staff levels and equipment at these stations are sufficient with average response time to the project site from Station 3 at approximately two minutes (SMFD 2021).
Table 3.13-2. San Marcos Fire Station Staffing
Station Staffing
Fire Station No. 1
180 West Mission Road
• One paramedic engine company (3 personnel)
• One paramedic truck company (3 personnel)
• One paramedic rescue
• One paramedic ambulance (2 personnel)
Fire Station No. 2
1250 South Rancho Santa Fe Road
• One paramedic engine company (3 personnel)
• One paramedic ambulance (2 personnel)
Fire Station No. 3
404 Woodland Parkway
• One paramedic engine company (3 personnel)
• One paramedic ambulance (2 personnel)
Fire Station No. 4
204 San Elijo Road
• One paramedic engine company (3 personnel)
• One paramedic ambulance (2 personnel)
• One battalion chief
Police Protection
Police protection services for the proposed project would be provided by the San Diego County Sheriff’s Department under contract with the City. As shown in Figure 3.13 -1, the proposed project would be served by the Sheriff’s San Marcos Station, located at 182 Santar Place, locate d approximately 0.5 mile northwest of the project site.
The Sheriff’s San Marcos Station provides law enforcement services to the City and unincorporated communities of Harmony Grove, Elfin Forest, Lake San Marcos, Hidden Meadows, Ivy Del, Del Dios, Lake Hodges, and the San Pasqual Valley. L aw enforcement services include general patrol, criminal investigation, crime prevention, juvenile services, narcotics and gang investigations, communications and dispatch, and various management support services. Services are available 24 hours a day, 7 days a week. Over 100 deputies, volunteers, and professional staff members serve the residents of San Marcos. Additionally, Community Oriented Police and Problem Solving (COPPS) teams are assigned to investigate community quality of life issues (San Diego C ounty Sheriff’s Department 2021). Lastly, the Sheriff’s San Marcos Station has the only ASTREA (Sheriff’s Aviation) landing pad in the County, providing assistance to ground units and extending the range deputies can patrol.
Schools
The project site is located within the San Marcos Unified School District (SMUSD) . SMUSD is 49 square miles in size and encompasses most of the City of San Marcos and portions of the cities of Vista, Escondido, and Carlsbad, as well as unincorporated areas of the County of San Diego between
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these cities. SMUSD provides kindergarten through 12th grade education in the City of San Marcos and operates ten elementary schools, three middle schools, two comprehensive high schools, one continuation high school, one independent study high school, one charter school, and one adult education school (SMUSD 2021). Schools that would serve the project include:
• Knob Hill Elementary School, 1825 Knob Hill Road, San Marcos • Woodland Park Middle School, 1270 Rock Springs Rd, San Marcos • Mission Hills High School, 1 Mission Hills Court, San Marcos Parks
The purpose of the City’s Parks, Recreation, and Community Health Element of the General Plan is to provide recreational opportuniti es, which contribute to the health and well -being of the residents of San Marcos and to provide goals and policies that outline the role recreational amenities plan in achieving the City’s vision for the future (City of San Marcos 2012a).
There are 16 major community parks and 18 mini parks located throughout the City. The City residents in the project area are currently served by several nearby parks. The closest park to the project site is Alder Glen Tot Lot located at 608 Shelly Drive which contains play equipment, a trail connection, permanent restrooms, and a kiosk. Jack’s Pond Park located at 986 La Moree Road is also in the project vicinity. Jack’s Pond Park consists of picnic shelter and picnic tables, a trail connection, play equipment, turf area, and permanent restrooms (City of San Marcos 2021b).
Libraries
The City is served by the San Diego County Library, San Marcos Branch located at 2 Civic Center Drive, approximately 1.4 miles northwest of the project site. The San Marcos Branch is 15,394 square feet (s.f.) (City of San Marcos 2012b), contains a MakerBot 3D printer, a 28 -person capacity meeting room, and is Americans with Disabilities Act (ADA) accessible (San Diego County Library 2021a). Under normal circumstances, the library is open seven days a week, however hours of operation and library access is cu rrently limited due to the COVID-19 pandemic. (San Diego County Library 2021a). The San Diego County Library system has 33 branches, and E -library, two bookmobiles, and four digital kiosks (San Diego County Library 2021b).
Additional library services are a vailable in the County through the Serra Library System and community members can also access materials through the two colleges located in San Marcos. A resident may secure a Community Borrower card to obtain borrowing privileges at the California State University San Marcos (CSUSM) campus. Palomar Community College offers free “Community Patron” library access for residents with a valid picture identification and proof of current mailing address.
3.13.2 Regulatory Setting
Local
San Marcos General Plan
The following are applicable goals and policies from the City of San Marcos General, Land Use and Community Design Element related to public services:
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Land Use and Community Design Element
• Goal LU -8: Ensure that existing and future development is adequately serviced by infrastructure and public services.
o Policy LU -8.1: New development shall pay its fair share of required improvements to public facilities and services.
o Policy LU -8.2: Promote development timing that is guided by the adequacy of exist ing and/or expandable infrastructure, services, and facilities. • Goal LU -10: Fire protection, emergency services, and law enforcement: Provide effective, high-quality, and responsive services.
o Policy LU -10.1: Provide demand -based fire -fighting and emergency medical services infrastructure, equipment, and personnel to provide a high level of fire, emergency medical, and law enforcement service in San Marcos to meet existing and future demands.
o Policy LU -10.2: Work closely with the County of San Diego Sherriff ’s Department to determine and meet the community needs for adequate personnel, equipment, and state-of-the-art technology to effectively combat crime, and meet existing and projected service demands.
o Policy LU-10.3: Continue to conduct p ublic outreach and education regarding fire safety and crime prevention within San Marcos.
• Goal LU-11: Schools: Ensure all residents have access to high-quality education. o Policy LU-11.1: Collaborate with the local public school district (SMUSD), private schools, and institutions of higher learning to ensure a range of traditional and distance -learning educational opportunities are provided in superior, a ccessible facilities that comple ment the surrounding land uses.
o Policy LU-11.2: Work with San Marcos Unified School Distri ct and developers to ensure adequate school facilities are funded as required by State law and through developer mitigation agreements between the school district and the developer. The City shall require a “will serve” letter substantiating that the devel oper has paid fees to the satisfaction of the school district prior to issuance of building permits. o Goal LU-12: Libraries: Provide library resources and services that meet the needs of the community.
o Policy LU-12.1: Provide adequate library facilities and technological access that enhance San Marcos’s quality of life and create a civic environment with vast opportunities for self-learning and academic enrichment.
o Policy LU-12.2: Accommodate technology needs of the community and locate accessible technology in the library.
Safety Element
The following are applicable goals and policies from the City of San Marcos General Plan, Safety Element related to public services, including fire protection, police protection, parks, and libraries:
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• Goal S -3: Minimize inju ry, loss of life, and damage to property resulting from structural or wildland fire hazards.
o Policy S -3.1: Require development to be located, designed, and constructed to provide adequate defensibility and reduce the risk of structural loss and life result ing from wildland fires. Development will consider hazards relative to terrain, topography, accessibility, and proximity to vegetation. One such provision for development to minimize the risk of structural loss and life shall be the inclusion of overhead f ire sprinklers.
o Policy S-3.2: Provide sufficient level of fire protection service to reduce risk from urban and wildland fire. Advocate and support regional coordination among fire protection and emergency service providers.
o Policy S-3.3: Require development to provide additional access roads when necessary, to provide for safe access of emergency equipment and civilian evacuation concurrently. o Policy S-3.4: Coordinate with fire protection and emergency service providers to as sess fire hazards before and after wildfire events to adjust fire prevention and suppression needs, as necessary, commensurate with both short - and long -term fire prevention needs.
• Goal S-6: Provide neighborhood safety through effective law enforcement. o Policy S -6.1: Continue to maintain demand -based law enforcement service levels to reduce the risk of criminal activity.
o Policy S -6.2: Continue public education efforts and community outreach programs to promote community involvement in crime and drug prevention. o Policy S -6.3: Use Crime Prevention through Environmental Design (CPTED) principles in the design or redevelopment of projects and buildings.
San Marcos General Plan – Parks, Recreation, and Community Health Element Parks, Recreation, and Community Health Element
The following are applicable goals and policies from the City of San Marcos General Plan, Parks, Recreation and Community Health Element related to parks:
• Goal PR -1: Plan for, acquire, develop, and maintain a system of local parks connected through an integrated network of trails and high-quality recreational facilities. o Policy PR-1.1: Develop and maintain a complete system of public parks and recreational amenities that provide opportunities for passive and active recreation at a m inimum standard of 5 acres per 1,000 residents. Parks, trails, and recreational facilities will enhance community livability, public health, and safety; should be equitably distributed throughout the City; and be responsive to the needs and interests of re sidents, employees, and visitors.
o Policy PR-1.2: Update and maintain a Master Parks Plan and a Master Trails Plan that implement the City’s long -term vision for a complete system of parks, trails, and recreation facilities.
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o Policy PR-1.3: Ensure that the d evelopment of parks, trails, and recreation facilities and services keeps pace with development and growth within the City. o Policy PR -1.4: Promote increased access to parks and open spaces, pedestrian - and bike-oriented routes to parks and open space, gree ning of public rights -of-way, and a variety of active and passive uses of parks and open space. o Policy PR-1.5: Require new development to be designed and constructed in accordance with the approved Parks Master Plan to meet or exceed the City’s parkland st andard of 5 acres per 1,000 residents.
o Policy PR-1.6: Require new infill development to provide plazas, mini parks, or other civic spaces as part of their parkland requirement.
o Policy PR-1.7: Promote park and facility design that discourages vandalism, deters crime, provides natural surveillance, and creates a safe and comfortable environment. o Policy PR -2.2: Implement the trail network per the Master Trails Plan to increase opportunities for physical activity (e.g., walking, biking), healthy lifestyles, and to reduce reliance on cars.
The project’s consistency with applicable General Plan goals and policies is discussed in Section
3.10, Land Use and Planning. As detailed in Table 3.10 -5 in Section 3.10, the project is consistent with all applicable goals and policies.
3.13.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to public services are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to public services would occur if the project would:
Threshold #1: Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the const ruction 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.
3.13.4 Project Impact Analysis
Threshold #1: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governme ntal facilities, the construction of which could cause significant environmental
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impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
Fire Protection
Fire protection services in the City are provided by the San Marcos Fire Department (SMFD). SMFD is a full-service department responsive to the City and the San Marcos Fire Protection District, which covers an area of 33 square miles and a population of approximately 95,000 res idents. SMFD provides the following services within its service area: fire suppression, rescue, emergency medical service, fire prevention services, vegetation management, public education, emergency preparedness and trauma support (City of San Marcos 2021a).
The proposed project would increase the demand on SMFD resources as a result of the development of residential uses and the associated population increase. Additional residents on the project site would increase the need for fire protection services th rough routine fire and emergency medical calls. As a condition of project approval, p rior to the issuance of a grading permit, the applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 2001 -01 (Fire and Paramedic). This would offset the project’s increase in demand for fire protection services.
SMFD was contacted for their input on the project, inclu ding for information regarding stations serving the project, current staffing, response times, and other items related to fire protection services. The response from the Fire Marshal is included in Appendix M. According to SMFD Battalion Chief/Fire Marshal Jason Nailon, the project would be served by Fire Station No. 3 at 404 Woodland Parkway. This station is staffed with one fire engine company (3 personnel) and one ambulance (2 personnel).
The average response time for the SMFD to the project site from St ation #4 would be two minutes.
SMFD has indicated that there is capacity to serve the project (SMFD 2021). The project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for fire service s. The project design includes a 150-foot onsite fire fuel modification buffer Impacts would be less than significant.
Police Protection
As discussed in Section 3.13.1, above, the San Diego County Sheriff’s Department provides law enforcement services to t he City. More specifically, the project would be served by the San Marcos Station, located approximately 0.5 miles from the project site. The project would introduce approximately 469 residents on-site, resulting in an increased demand on existing police p rotection resources. The increased density of development on the project site would be expected to increase the frequency of emergency and non -emergency calls to the Sherriff’s Department. However, as discussed in Section 3.13.1, above, over 100 deputies, volunteers, and professional staff serve the residents of the City. Law enforcement services include general patrol, criminal investigation, crime prevention, juvenile services, narcotics and gang investigations, communications and dispatch, and various management support services. Unlike fire services, which respond solely to emergencies, law enforcement services consist of patrolling large areas 24 hours a day, 365 days a year. Police units are continuously mobile, and service calls are responded to by th e nearest available mobile unit. At
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the San Marcos Station, patrol deputies are assigned to a geographical “beat” area, allowing deputies to become familiar with citizens and problems within their “beats”. As such, the location of the proposed project rela tive to the nearest station would not affect police protection. Further, in an effort to minimize the increased demand for police protection services, the project has been designed to improve the safety for future residents and visiting guests. Safety feat ures proposed for the project includes walls and fencing. Lastly, lighting would be implemented throughout the site to provide safety as described in Section 2.2.2.3 (Chapter 2, Project Description).
Additionally, the project would participate in an existing Community Facilities District ( CFD 98 -01, Improvement Area No. 1) for police protection. Thus, while new development places increased demand on police protection services, it is not anticipated tha t the proposed project would result in the need for construction or expansion of existing police facilities. Therefore, the proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered facilities. Impacts resulting from the proposed project would be less than significant.
Schools
The project site is located within the service boundary of the San Marcos Unified School District (SMUSD). Per SMUSD the following schools would serve the project:
• Knob Hill Elementary School, 1825 Knob Hill Road, San Marcos • Woodland Park Middle School, 1270 Rock Springs Rd, San Marcos • Mission Hills High School, 1 Mission Hills Court, San Marcos Table 3.13-3 summarizes the enrollment and capacity at each of these schools.
Table 3.13-3. Enrollment and Capacity by School
School Grade Level 2019-20
Enrollment(1)
2019-20
Capacity(2)
Knob Hill Elementary K-5 838 964
Woodland Park Middle 6-8 1,229 1,384
Mission Hills High 9-12 2,864 2,692
Source: SMUSD 2021
Notes: (1) Enrollment as of October 3, 2020
(2) Capacity is based on building utilization for the 2019-20 school year.
Using the student generation rate for multifamily residential units provided in the SMUSD’s 2021 School Facilities Needs Assessment (SFNA) of 0.3072 students per multi -family unit, the construction of 151 multifamily units on the project site will generate approximately 4 7 students.
While there is current capacity at the elementary school and middle school that would serve t he project, the high school is over capacity. Additionally, SMUSD has indicated that, at the District -level they are overcrowded. Based on the District’s 2021 SFNA, the District’s 2020/2021 capacity was 19,022 and its enrollment was 20,898, leaving the Dis trict with a capacity shortage of 1,876 students. Additionally, recently approved projects in SMUSD’s service area which have not yet been constructed, will add additional students to the schools that will serve the project (SMUSD 2021).
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While there is som e capacity at the elementary school and middle school that would serve the project, the high school that is identified to serve the project is over capacity. Further, the addition of these students would contribute to the District -wide capacity issues . The project applicant shall pay school mitigation fees pursuant to California Education Code Section 17620 et seq. and Government Code Sections 65995(h) and 65996(b) in effect at the time of building permit issuance. Current Level II school fees are $4.38/s.f . for residential development (SMUSD 2020). Further, consistent with General Plan Policy LU-11.2, the applicant shall provide a letter from the school district(s) to the City prior to the issuance of building permits confirming these fees have been paid.
Payment of these fees would assist in funding SMUSD’s long -range plans. State Bill (SB) 50 states that the fees imposed by school districts shall constitute the exclusive method of considering and mitigating impacts on school facilities caused by a developm ent project. Such payment shall provide “full and complete mitigation of the impacts of any legislative or adjudicative act...on the provision of adequate school facilities” (Government Code Section 65995(h)). As such, with contribution of required development fees, impacts to schools would be
less than significant.
Parks
Buildout of the proposed project is estimated to add an additional 4 69 residents to the City.
Assuming five acres of park space per 1,000 residents, this equates to a demand of approximate ly
2.38 acres of park space generated by project residents.
The project applicant would be required to pay the City’s Public Facility Fees (PFF), required by all projects that increase the demand for park and recreation needs in the City. The PFF money wou ld go towards the acquisition and development of local and community park facilities throughout the City, to offset the demand on public park space generated by the project, as described in Municipal Code Chapter 17.36 and 17.44. Payment of the PFF shall b e made prior to City issuance of the first building permit for the proposed project. Therefore, payment, which would ultimately contribute to development of new parks and recreational facilities, would offset the increase in demand of parks and recreational facilities generated by the proposed project, such that existing facilities would not substantially deteriorate. Impacts to existing neighborhood and regional parks would be less than significant.
In addition, the project would provide 82,419 s.f. (1.89 acres) of common usable open space area including open space areas with grades less than 10 percent and five recreational areas that would include amenities such as multi-age play areas, tot lots, seating areas, barbeque stations, open turf areas, and pati o areas. These areas will be maintained by the Home Owners Association .
Additionally, the project provides for 26,390 s.f.(0.61 acre) of private open space . The proposed project would meet and exceed the common useable and private open space requirements p er the City’s Municipal Code. As such, with payment of the required PFF in combination with provision of on- site common and private open space, the project would meet and exceed the anticipated demand for neighborhood and regional parks or other recreation al facilities. Project residents would have access to adequate on -site recreational facilities, which will offset increased use of existing parks and recreational facilities. Therefore, project residents would not cause or result in the overuse of existing parks and recreational facilities such that substantial physical deterioration would occur.
Impacts to parks and park services would be
less than significant.
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Other Public Facilities
Development of the project would add an additional 4 69 residents to the City. This would increase the demands on library services and resources. However, additional library services are available in the County through a cooperation of County libraries, independent city libraries, and the Imperial County Library, which collectively form the Serra Library System. This system enables County library cardholders to check out library materials from the other Serra member libraries (Serra Cooperative Library System 2016). In addition, community members can purchase a community borrower card to obtain borrowing privileges at the California State University San Marcos (CSUSM) campus (C SUSM 2021). Community members can also borrow materials at Palomar Community College with a valid picture ID and proof of current mailing address (Palomar College 20 21). These additional library resources are located in the San Marcos community and provide over 200,000 square feet of additional library space. Therefore, a less than significant impact is identified for this issue area.
3.13.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adeq uate discussion of a project’s significant cumulative impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to public services, the cumula tive analysis is based upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts related to public services (see Table 2-3, Cumulative Projects).
Fire Protection Services
The geographic area for the cumula tive analysis of fire protection and emergency services is those areas that are serviced by the SMFPD. The cumulative projects that fall within this geographic area would add to the increase in demand for fire protection and emergency services. The SMFPD provides service to the City of San Marcos and has existing automatic mutual aid fire agreements in place with the Cities of Carlsbad, Vista, Escondido, Encinitas, and the Rancho Santa Fe Fire Protection District. As discussed in Section 3.13.4, above, alth ough the proposed project would introduce approximately 469 residents on -site, the project is not expected to cause a decline in SMFD response times. Nonetheless, the cumulative projects listed in Table 2 -3 would result in additional demand of fire protect ion services, and the potential need for additional fire protection resources. However, all cumulative projects would be required to participate in existing Community Facilities Districts as determined necessary. Future projects would be required to offset the increase in demand caused by their respective project. Development fee payments would go towards providing the additional staff and equipment that would be needed by SMFD in the future to provide fire protection services, including potential new fire stations. Similarly, to offset any potential cumulative impacts to fire protection services, the project would pay all required development impact fees. Thus, cumulative impacts to fire protection services would be less than significant.
Police Protection Services
The geographic area for the cumulative analysis of police protection is those areas that are serviced by the San Marcos Sheriff’s Department. All cumulative projects listed in Table 2 -3 would result in an
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increase in demand for police protection s ervices from the San Marcos Sheriff’s Department. The project site would be served by the San Marcos Station, located approximately 1.2 miles from the project site. As discussed in Section 3.13.4, the proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered facilities.
However, the cumulative projects listed in Table 2 -3 would result in additional demand of police protection services, and the potential need for additional police pro tection resources. Nonetheless, all cumulative projects would be required to offset increased demand to police protection services, through the payment of fees. These fees would provide for additional staff and equipment to assist in the provision of law e nforcement services. In order to offset any potential cumulative impacts to fire protection services, the proposed project would also be required to contribute toward the future police protection resources through the payment of fees. As such, with payment of fees, cumulative impacts to police protection services would be
less than significant.
Schools
While there is some capacity at the elementary school and middle school that would serve the project, the high school that is identified to serve the project is over capacity. Based on the District’s 2021 SFNA, the District’s 2020/2021 capacity was 19,022 and its enrollment was 20,898, leaving the District with a capacity shortage of 1,876 students. Additionally, recently approved projects in the City which ha ve not yet been constructed and the cumulative projects included on Table 2 -3 that have a residential component and would generate students that need to be accommodated by either SMUSD or another school district in the area.
As discussed in Section 3.13.4, the project applicant would be required to contribute development fees to SMUSD, pursuant to California Education Code Section 17620 et seq. and Government Code Sections 65995(h) and 65996(b) as well as the City’s Municipal Code Section 17.52.050. The applicant shall pay the school mitigation fees that are in effect at the time of building permit issuance.
The current school fee for residential development required by S MUSD is $4.38 per square foot; however, this fee amount could change between the draftin g of this EIR and the time of building permit issuance (S MUSD 2021). Further, consistent with General Plan Policy LU -11.2, the applicant shall provide a letter from the school district(s) to the City prior to the issuance of building permits confirming the se fees have been paid. All of the cumulative projects included in Table 2 -3 that include residential development would result in increased demand for school services, and would be required to pay school fees to offset the increase demand, similar to the p roposed project.
Additionally, non-residential projects are also required to pay school fees consistent with SMUSD’s developer fee schedule. As such, with contribution of required development fees by the proposed project and related projects, cumulative impacts to schools would be less than significant.
Parks
The proposed project as well as the cumulative projects that are in the City of San Marcos (as identified in Table 2 -3) would add to the cumulative demand for park and recreation facilities in the City. All residential projects that increase the demand for park and recreation needs in the City are required to provide park space and/or pay park in lieu -fees. The environmental documentation prepared for each project would analyze impacts associated with t he construction of any parks within each overall development footprint. As discussed in Section 3.13.4, the proposed project would be required to pay the City’s PFF, which is required for all projects that increase the demand for park and recreation needs in the City. The PFF would be used for developing neighborhood and
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regional parks. It is expected that all cumulative projects that increase demand for parks and recreation needs would also be required to pay these fees. As such, cumulative impacts on recreational facilities in the City would be less than significant.
Libraries
Cumulative projects within the services area of the San Marcos Branch Library would result in an increase in demand for library services. Aside from the San Marcos Branch, additional library services are available in the County through the Serra Library System, which allows library cardholders to check out materials from the other Serra member libraries. In addition, community members can get borrowing privileges at the CSUSM campus a nd the Palomar Community College.
These additional library resources are located in the San Marcos community and provide over 200,000 square feet of additional library space. Cumulative impacts to library services would be less
than significant.
3.13.6 Mitigation Measures
No significant impacts to public services were identified; thus, no mitigation measures are required.
3.13.7 Conclusion
Development of the proposed project would result in an increase in demand for fire protection, emergency medical services, police protection, school services, and library facilities. However, the project applicant would be required to pay all applicable de velopment fees including payment of school mitigation fees, pursuant to California Education Code Section 17620 et seq. and Government Code Sections 65995(h) and 65996(b) as well as the City’s Municipal Code Section
17.52.050, and payment of the City’s PFF, required by all projects that increase the demand for park and recreation needs in the City, in order to avoid direct and cumulative impacts to schools and parks.
Although the project, on its own, is not expected to result in impacts to fire and police p rotection services, with the additional demand on fire and police services to be added by the cumulative projects listed in Table 2 -3, potential need for additional fire and police protection resources could occur. As such, the project applicant would be r equired to pay all required development fees to fire and police services to offset any potential cumulative impacts. The project applicant will also annex into CFD 2001 -01 for f ire and p aramedic and CFD 98 -01, Improvement Area No. 1 for police protection and this would offset and minimize potential impacts . As such, with payment of fees towards schools, parks, fire, and police, impacts to public services would be less than significant.
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Figure 3.13-1 Public Services in Project Vicinity
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 3.14-1
3.14 Recreation
Introduction
This section analyzes the potential impacts of the proposed project to existing recreational facilities.
The analysis also considers the California Environmental Quality Act (CEQA) Guidelines Appendix G and applicable State and Local regulations, including the City of San Marcos General Plan. The General Plan is available on the City’s web site.15
Table 3.14-1 summarizes the project- and cumulative-impact analysis by threshold for the proposed project.
Table 3.14-1. Recreation Summary of Impacts
Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
Threshold #1: The project
increases 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.
Less than
Significant
Less than
Significant
Less than
Significant
Threshold #2: The project
includes recreational facilities or
requires the construction or
expansion of recreational facilities
which might have an adverse
physical effect on the
environment.
Less than
Significant
Less than
Significant
Less than
Significant
3.14.1 Existing Conditions
This section describes existing park, recreation facilities, and trails on the project site and in the project vicinity.
Parks and Recreation Facilities
According to the City’s General Plan, San Marcos has nearly 270 acres of developed parkland, consisting of 149 acres of neighborhood parks, 98 acres of community parks, 20 acres of smaller parks, and three acres of other recreational facilities (City of San Marcos 2012).
The San Marcos General Plan park acreage standar d calls for five acres of parkland for every 1,000 residents. As of January 1, 2020, the California Department of Finance (DOF) estimates the population of the City is 97,209 (DOF 2020). Based on growth projections provided by the Series 13:
15 http://www.san-marcos.net/work/economic-development/general-plan
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2050 Regional Growth Forecast prepared by SANDAG, it is estimated that the City’s population growth will reach 109,095 persons by 2035 (SANDAG 2013) . Using 2020 population figures, approximately 486 acres of parkland is required to meet the General Plan park standard. Using 2035 population figures, approximately 546 acres of parkland would be necessary.
There are 16 major community parks and 18 mini parks located throughout the City. The City residents in the project area are currently served by several nearby parks. The closest park to the project site is Alder Glen Tot Lot located at 608 Shelly Drive which contains play equipment, a trail connection, permanent restrooms, and a kiosk. Jack’s Pond Park located at 986 La Moree Road is also in the project vicinit y. Jack’s Pond Park consists of picnic shelter and picnic tables, a trail connection, play equipment, turf area, and permanent restrooms (City of San Marcos 2021).
Trails
The City of San Marcos has 63 miles of completed trails with plans to expand the trail network to 72 miles (City of San Marcos 2017). The goal of the trail system is two-fold: (1) to serve as a recreational amenity and (2) provide an alternative means of circulation for non -motorized travelers through an inter-linked citywide system of tra ils connecting residential neighborhoods to parks, schools, colleges, stores, restaurants, movie theaters, other important destinations within the City, and with the wider regional trails system in adjacent cities.
3.14.2 Regulatory Setting
This section describes the state and local laws and regulations that are applicable to the proposed project.
State
Quimby Act
Since the passage of the 1975 Quimby Act (California Government Code Section 66477), cities and counties have been authorized to pass ordinances requiring that developers set aside land, donate conservation easements, or pay fees for park improvements. Revenues generated by the Quimby Act cannot be used for the operation and maintenance of park facilities. The goal of the Quimby Act was to require developers to help mitigate the impacts of property improvements. The act gives authority for passage of land dedication ordinances only to cities and counties.
The Landscape and Lighting Act of 1972
The Landscape and Lighting Act of 1972 enables cities, counties , and special districts to acquire land for parks, recreation, and open space. A local government may also use the assessments to pay for improvements and maintenance in these areas.
The Mello-Roos Community Facilities Act
The Mello -Roos Community Faciliti es Act (Government Code [GC] section 53311 et seq.) is a tax - based financing method available to cities, counties, and special districts. It authorizes local governments to establish community facilities districts (CFDs) within which they may levy special taxes and issue bonds to finance open space acquisition, maintenance, and other programs.
Approval of the special tax and any related bond issue requires approval by two -thirds of the district electorate.
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Local
City’s Municipal Code Chapter 17.36 – Park and Recreational Development Construction Fee As described in Chapter 17.36 in the City’s Municipal Code, the continued increase in the development of dwelling units and population within the City has created the need for planning, acquisition, improvement, expansion and operation of public parks, playgrounds, recreational facilities in the City, and thus the need for additional revenues with which to finance such facilities.
This chapter of the Municipal Code requires that each builder of each dwelling unit to be constructed within the City of San Marcos shall, prior to the construction, pay a fee, as adopted by Resolution by the City Council.
City’s Municipal Code Chapter 17.44 – Development Services and Public Facilities, Exaction, Fees and/or Costs
The City recognizes that the continued development of property within the City's jurisdictional boundaries has resulted in an increased demand on existing public services, facilities, and infrastructure; the need for expansion of public services, facilities and infrastructure; and/or the need for the installation of new public services, facilities, and infrastructure. It is the intent of the City that each applicant for a grading, cons truction, building and/or development permit or entitlement shall, prior to the issuance of such permit or entitlement, pay Public Facilities Fees. The funds generated by the payment of fees described Chapter 17.44 shall be deposited into separate accounts established for the purposes of maintaining, expanding, and installing public infrastructure.
Such public infrastructure includes active or passive open space and parks.
San Marcos General Plan – Parks, Recreation, and Community Health Element The following are applicable goals and policies from the City of San Marcos General Plan, Parks, Recreation, and Community Health Element:
• Goal PR -1: Plan for, acquire, develop, and maintain a system of local parks connected through an integrated network of trails and high-quality recreational facilities. o Policy PR-1.1: Develop and maintain a complete system of public parks and recreational amenities that provide opportunities for passive and active recreation at a minimum standard of 5 acres per 1,000 residents. Park s, trails, and recreational facilities will enhance community livability, public health, and safety; should be equitably distributed throughout the City; and be responsive to the needs and interests of residents, employees, and visitors.
o Policy PR-1.2: Update and maintain a Master Parks Plan and a Master Trails Plan that implement the City’s long -term vision for a complete system of parks, trails, and recreation facilities.
o Policy PR-1.3: Ensure that the development of parks, trails, and recreation facilities and services keeps pace with development and growth within the City. o Policy PR -1.4: Promote increased access to parks and open spaces, pedestrian - and bike-oriented routes to parks and open space, greening of public rights -of-way, and a variety of active and passive uses of parks and open space.
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o Policy PR-1.5: Require new development to be designed and constructed in accordance with the approved Parks Master Plan to meet or exceed the City’s parkland standard of 5 acres per 1,000 residents.
o Policy PR-1.6: Require new infill development to provide plazas, mini parks, or other civic spaces as part of their parkland requirement.
o Policy PR-1.7: Promote park and facility design that discourages vandalism, deters crime, provides natural surveillance, and creates a safe and comfortable environment.
The project’s consistency with applicable General Plan goals and policies is discussed in Section
3.10, Land Use and Planning. As detailed in Table 3.10 -5 in Section 3.10, the project is consistent with the applicable goals and policies.
Parks Master Plan
The City adopted its Parks Master Plan in 1990, which presents a vision of parks and recreation facilities for the City. Since that time, the City has changed significantly so a Master Plan Update was adopted in 2017. The goal of the Parks Master Plan Upda te is to identify potential improvement to the park system and, as funding becomes available, suggest additional amenities for new parks and improvements at existing park facilities (City of San Marcos 2017).
Master Trails Plan
The City’s Master Trails Pla n, adopted in 1991, details a trails implemen tation strategy and description of each proposed trail segment. The plan envisions a system of connectivity through trail corridors networked across the City. To meet this goal, the Master Trails Plan recommends creation of 72 miles of trails that will provide an alternative means of circulation and recreational opportunities to San Marcos residents and visitors. These trails will include 21 miles of urban trails, 36 miles of multiuse trails, and 15 miles of soft -surface trails that connect neighborhoods to parks, schools, and workplaces as well as to the trails systems of neighboring cities and the County of San Diego (City of San Marcos 201 7). The City’s Master Trail Plan identifies an Urban Trail along the project’s Barham Drive frontage, which is already constructed.
3.14.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to recreation are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guideline s, a significant impact related to recreation would occur if the project would:
• Threshold #1: 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.
• Threshold #2: Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.
3.14.4 Project Impact Analysis
As discussed in Section 2.2.2.1 of this EIR, there are two main categories of open space proposed for the project – common open space and priva te open space . Common open space will total
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approximately 5.35 acres and includes open space with grades 10 percent and greater, common open space with grades less than ten percent, the water quality basin, and recreational areas.
Private open space is associated with private patio and deck areas on the residential units. The open space concept plan is included as Figure 2 -3 and Table 3.14 -2 summarizes the proposed open space areas.
Table 3.14-2. Proposed Open Space Summary
Open Space Description Amount Provided
(square feet)
Common Open Space
Common Open Space
(Grades 10 percent or greater) 134,776(1)
Common Open Space
(Grades less than 10 percent) 64,913(2)
Water Quality Basin/Bio-retention Area 6,764(1)
Recreational Areas 10,742(2)
Private Open Space
Private Open Space
(Patios/Decks) 26,390
Notes: (1) Per the Zoning Ordinance, open space areas with grades of 10 percent or greater and the water quality basin/bioretention areas do not counted as usable open space. (2) Open space with grades of less than 10 percent and recreational areas count towards the project’s usable open space calculation.
Common Open Space
Common open space is divided into: 1) common open space area with grades 10 percent or greater ; 2) common open space area with grades l ess than 10 percent ; 3) the water quality basin/bioretention area; and 4) recreational areas.
Common Open Space – Grades 10 Percent or Greater
The first category is common open space with grades of 10 percent or greater. According to the City of San Marcos Zoning Ordinance, open space of 10 percent grade or greater cannot be counted as usable open space. This category includes open space features such as landscaping and slopes and encompasses 134,776 s.f.
Common Open Space – Grades Less than 10 Percent
Common open space area s with grades less than 10 percent are considered to be usable open space. These areas which encourage relaxation activities such as observing nature, bird watching, painting, photography, and picnicking as well as recreationa l open space areas such as open turf areas. This encompasses 64,913 s.f.
Common Open Space – Water Quality Basin/Bioretention Area
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The project includes a 6,764-s.f. water quality basin area. This is a passive open space area located in the northwest corner of the project site which is used to direct water during rain events to control for flooding and to treat water before it is discharged from the site. The water quality basin/bioretention area does not count towards usable common open space.
Common Open Space – Recreational Areas
The proposed project includes five recreational open space areas totaling 10,742 s.f. inclusive of multi-age play areas, tot lots, seating, barbeque stations, open turf areas, and patio areas. These areas will be maintained by the Home Owners Association and include:
• A 3,564 s.f. primary recreation area will provide residents with amenities such as a barbeque counter and patio space, a bocce ball court, and a tot lot with seating and open turf area.
Excluding the tot lot, other recreational amenities within the primary recreation area may be substituted to make room for a pool.
• A 2,345 s.f. multi -age recreation area has been established adjacent to Building 12 and includes a multi-age play structure, open turf area, and bench seating. • An 1,805 s.f. amenity space adjacent to Building 1 will include an enhanced paved patio area, tables with seating, open turf areas and a dog wash station. • A 1,552 s.f. overlook tot lot area provided adjacent to Building 17 includes features such bench seating, a fire pit with seating, walkways, and a tot lot. • A 1,476 s.f. amenity space adjacent to Building 25 includes a dog wash and open turf area.
Private Open Space
Private open space within the proposed project consists of private patio space and priva te balcony/deck space. The City requires that each unit with ground floor living must provide 250 s.f. of private open space. Units with living space on the second floor and above must provide 50 s.f. of private open space in the form of decks or balconies . There is a total of 88 units within the proposed project that include ground floor living space and 63 units with living area on the second floor or above. Therefore, according to the City of San Marcos Zoning Ordinance, the units with ground floor living would be required to provide 22,000 s.f. of private patio space and the units with living space on the second floor and above would be required to provide approximately 3,150 s .f. of balcony/deck space. Combined, the minimum private open space required for the proposed project equates to 25,150 s.f. The proposed project provides a total of 26,390 s.f. of outdoor private space and will exceed the City’s requirement.
Threshold #1: Would the project increase the use of existing neighborhood and regional park s or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
Based on the population rate of 3.1 persons per housing unit in San Marcos , buildout of the proposed project is estimated to add an additional 4 69 residents to the City. This increase in residents would increase demand for neighborhood and regional parks and other recreational facilities. Assuming five acres of park space per 1,000 residents (the minimum standard goal of the City’s General Plan discussed in Section 3.14.2), the addition of residents on site equates to a demand of approximately 2.35 acres of public park space generated by project residents.
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The project applicant would be required to pay the City’s Public Facility Fees (PFF), which is required by all projects that increase the demand for park and recreation needs in the City. The PFF money would go towards the acquisition and development of local and community park facilities throughout the City, to offset the demand on public park space generated by the project, as described in Municipal Code Chapter 17.36 and 17.44. Payment of the PFF shall be made prior to City issuance of the first building permit for the proposed project. The PFF payment would ultimately contribute to development of new parks and recreational facilities and would offset the increase in demand of parks and recreational facilities generated by the proposed project, such that existing facilities would not substantially deteriorate. Impacts to existing neighborhood and regional parks would be less
than significant.
In addition, as discussed above, the project would provide 82,419 s.f. (1.89 acres) of common usable open space are a including open space areas with grades less than 10 percent and five recreational areas that would include amenities such as multi-age play areas, tot lots, seating areas, barbeque stations, open turf areas, and patio areas. These areas will be maintaine d by the Home Owners Association . Additionally, the project provides for 26,390 s.f. of private open space . The proposed project would meet and exceed the common useable and private open space requirements per the City’s Municipal Code. As such, with payme nt of the required PFF in combination with provision of on -site common and private open space, the project would meet and exceed the anticipated demand for neighborhood and regional parks or other recreational facilities.
Project residents would have acces s to adequate on -site recreational facilities, which will offset increased use of existing parks and recreational facilities. Therefore, project residents would not cause or result in the overuse of existing parks and recreational facilities such that subs tantial physical deterioration would occur. Impacts to neighborhood and regional parks would be less than significant.
Threshold #2: Would the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
Impacts associated with construction of the proposed project’s public and private open space are considered within the overall development footprint for the proposed project. Impacts from the development of proposed recreational facilities have been considered in the project impact analysis and mitigation measures for the proposed project as a whole are discussed in the various sections of this EIR.
As stated under Threshold #1, the project applican t would be required to pay the City’s PFF that would go towards the acquisition and development of local and community park facilities throughout the City. As such, the project applicant may contribute to the construction or expansion of recreational facil ities offsite that may have an adverse physical effect on the environment. Future expansion or development of new recreational facilities would be subject to CEQA environmental review as appropriate, which would identify and address any site -specific impacts. Therefore, impacts due to the construction or expansion of recreational facilities are considered less than significant.
3.14.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a p roject’s significant cumulative
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impact, in combination with other closely related projects, can be based on either: (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, r egional, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to recreation, the cumulative analysis is based upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts related to recreation. All of the cumulative projects within the City identified in Table 2 -3 are considered in this cumulative analysis.
The proposed project as well as the cumulative projects that are in the City of San Marcos (as identified in Table 2-3) would add to the cumulative demand for park and recreation facilities in the City. The proposed project would provide 82,419 s.f. (1.89 acres) of com mon useable open space area defined as common open space area with grades of 10% or less and recreational areas.
Further, private open space totaling 26,390 s.f. (0.61 acre) would be provided . The project applicant would be required to pay the City’s PFF w hich helps pay for the acquisition and development of local and community park facilities throughout the City.
All cumulative projects that increase the demand for park and recreation needs in the City would be required to provide park space and/or pay the City’s PFF. Furthermore, any substantial expansion or development of new recreational facilities would be subject to the appropriate CEQA environmental review prepared by the City, which would identify and address any site -specific impacts. Therefore, implementation of City policies, such as the collection of PFF, along with compliance with CEQA requirements would ensure that cumulative impacts to recreational facilities would be properly addressed and mitigated. Therefore, cumulative impacts to recreational facilities are considered less
than significant.
3.14.6 Mitigation Measures
No significant impacts to recreation were identified; thus, no mitigation is required.
3.14.7 Conclusion
The proposed project would result in an increase in the City of San Marcos population by approximately 4 69 residents. The additional residents would require approximately 2.3 5 acres of new park space to fulfill the City’s General Plan requirement of five acres of park space per every 1,000 residents. The proposed project would be required t o pay the City’s PFF, to go towards the acquisition and development of local and community park facilities throughout the City in addition to what is provided on -site. The project includes 82,419 s.f. (1.89 acres) of common useable open space and 26,390 s.f. (0.61 acres) of private open space. With payment of the PFF and provision of on-site common open space and recreational amenities, impacts would be less than significant.
Lastly, any impacts associated with the development of proposed open space have be en considered in the project impact analysis and mitigation for the proposed project as a whole and are discussed in the various sections of this EIR. Therefore, impacts resulting from construction of new park facilities would be less than significant.
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3.15 Transportation
This section provides a transportation impact analysis for the proposed project related to transit, roadway, bicycle and pedestrian facilities, vehicle miles traveled, design feature hazards and emergency access. The section is based on the following report:
• Transportation Impact Analysis & Local Transportation Analysis, Hallmark Barham Specific Plan, San Marcos, California, prepared by Linscott Law & Greenspan (LLG) (May 2021).
The complete report is included as Appendix K.
Section 3.10 Land Use and Planning , includes a description of existing traffic conditions, methodology, baseline conditions and trip generation for the local transportation analysis/ level of service (LOS) . Section 3.10 analyzes the project’s consistency with the Mobility Element of the General Plan. Table 3.15-1 summarizes the project - and cumulative-level traffic impact analysis, by threshold.
Table 3.15-1. Transportation/Traffic Summary of Impacts Thresholds of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
#1: Conflict with a program plan,
ordinance or policy addressing the
circulation system, including
transit, roadway, bicycle, and
pedestrian facilities
Significant Impact Significant Impact Significant and
Unavoidable
#2: Would the project conflict or
be inconsistent with CEQA
Guidelines Section 15064.3,
subdivision (b)?
Significant Impact Significant Impact Significant and
Unavoidable
#3 - Substantially increase
hazards due to a design feature
(e.g., sharp curves or dangerous
intersections) or incompatible
uses (e.g., farm equipment).
Less than
Significant
Less than
Significant
Less than
Significant
#4: Result in inadequate
emergency access
Less than
Significant
Less than
Significant
Less than
Significant
3.15.1 Existing Conditions
The City has strived to create a robust, city -wide system of bicycle and pedestrian paths and routes, which provide residents with alternative modes of travel as well as recreational opportunities . The project site is located near the Barham Park & Ride.
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Existing Pedestrian Connections
Pedestrian facilities are intermittently provided within the p roject study area. Paved sidewalks are provided along the south side of E. Barham Drive, on the east side of Woodland Parkway, and on both sides of La Moree Road. However, no sidewalks are currently provided along Rancheros Drive.
Existing Transit Service
The project site is located within one mile of the Ca l State San Marcos S PRINTER light rail station and within 0.9 mile of the Nordahl Road SPRINTER light rail station. Bus stops serving the North County Transit District (NCTD) Route s 305 and Route 347 are located approximately 0.7 mile from the project site. Residents will be able to utilize these public transit opportunities. A summary of the available transit service routes is provided below.
The SPRINTER hybrid rail line spans 22 -miles and connects Oceanside, Vista, San Marcos, and Escondido – serving 15 stations along Highway 78 corridor. The SPRINTER runs every 30 minutes in each direction Monday through Friday from approximately 4:00 AM to 9:00 PM . Saturday, Sunday, and holiday trains operate every 30 minutes between 10:00 AM and 6:00 PM and hourly befo re 10:00 AM and after 6:00 PM.
NCTD Bus Route 305 runs from the Vista Transit Center t o t he Escondido Transit Center with destinations to Palomar College, San Marcos Civic Center, Mission Hills High School, San Marcos Middle School, Vista Transit Center Es condido Transit Center, Arc Enterprises, and DMV. There are 33 stops along this route. Route 305 currently operates Monday through Friday from 4:32 AM through 11:02 PM departing from the Vista Transit Center and from 4:19 AM through 10:16 PM departing from the Escondido Transit Center. Weekend route schedule begins at 5:32 AM through 11:02 PM departing from Vista Transit Center and begins at 5:15 AM to 10:18 PM departing from the Escondido Transit Center. Route 305 travels at 30 -minute headways on weekdays, and 30 - minute headways on weekends.
NCTD Bus Route 347 runs from Cal State San Marcos to Palomar College with destination s to Cal State University San Marcos, Palomar College, Restaurant Row, Cal State San Marcos SPRINTER Station, and Edwards Cinemas. There are 24 stops along this route. Route 347 currently operates Monday through Friday from 5:20 AM through 7:12 PM departing from the CSUSM Sprinter Station and from 5:45 AM through 7:36 PM departing from Palomar College Transit Center. Saturday route schedule begins at 7:51 AM through 7:12 PM departing from CSUSM Sprinter Station and begins at 7:14 AM to 6:35 PM departing from Palomar College Transit Center. Route 347 does not operate on Sundays. Route 305 travels at 30 -minute headways on weekdays, and 60 -minute headways on Saturdays.
Existing Bicycle Conditions
There are currently Class II bike lanes in each direction of trave l on E. Barham Drive, Woodland Parkway, and La Moree Road in the vicinity of the project site, consistent with the City of San Marcos Bicycle and Pedestrian Plan (City of San Marcos 2012).
Table 3.15-2 summarizes the existing and future bicycle facility classifications along E. Barham Drive within the study area.
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Table 3.15-2. Bicycle Mobility
Street Segment Existing Condition Future Classification Barham Drive
Woodland Parkway to Project Driveway (West) Class II Bicycle Lane Class II Bicycle Lane Project Driveway (West) to Project Driveway
(East) Class II Bicycle Lane Class II Bicycle Lane
Project Driveway (East) to La Moree Road Class II Bicycle Lane Class II Bicycle Lane East of La Moree Road Class II Bicycle Lane Class II Bicycle Lane Source: City of San Marcos Bicycle and Pedestrian Master Plan. (San Marcos 2012)
3.15.2 Regulatory Setting
The following provides a general description of the applicable regulatory requirements and guidelines for the project area.
State Regulations
California Department of Transportation
The California Department of Transportation (Caltrans) is the primary state agency responsible for transportation issues. One of its duties is the construction and m aintenance of the state highway system. Caltrans has established standards for roadway traffic flow and has developed procedures to determine if intersections require improvements. For projects that may physically affect facilities under its administration, Caltrans requires encroachment permits before any construction work may be undertaken. For projects that would not physically affect facilities, but may influence traffic flow and levels of services at such facilities, Caltrans may recommend measures to mitigate the traffic impacts of such projects.
AB 1358 – California Complete Streets Act of 2008
The California Complete Streets Act of 2008 (Assembly Bill [AB] 1358) requires circulation elements as of January 1, 2011 to accommodate the transportation sys tem from a multi -modal perspective, including public transit, walking, and biking, which have traditionally been marginalized in comparison to autos in contemporary American urban planning.
SB 743, CEQA Guidelines Update
In December 2018, the California Natural Resources Agency certified and adopted the CEQA Guidelines update package, which included the California Natural Resources Agency Guidelines for the Implementation of CEQA . As a result, the California Governor’s Offic e of Planning and Research (OPR) updated and released the Technical Advisory on Evaluating Transportation Impacts in CEQA (Technical Advisory) in December 2018. According to the updated guidelines, lead agencies had until July 1, 2020 to comply with the up dated CEQA revision. The City of San Marcos has adopted VMT thresholds as part of their Transportation Impact Analysis Guidelines (City of San Marcos 2020).
While VMT is the preferred quantitative metric for assessing potentially significant transportation impacts under CEQA, it should be noted that SB 743 does not prevent a city or county from using metrics such as LOS as part of the application of local general plan policies, municipal and zoning codes, conditions of approval, or any other planning requir ements through a city’s planning approval
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process; cities can still ensure adequate operation of the transportation system in terms of transportation congestion measures related to vehicular delay and roadway capacity. As such, the City can continue to req uire congestion -related transportation analysis and mitigation projects through planning approval processes outside CEQA. Section 3.10 Land Use and Planning includes results of the LOS analysis prepared for the project.
Local Plans and Policies
SANDAG San Diego Forward: The Regional Plan
The Regional Comprehensive Plan (RCP), adopted in 2004 by the San Diego Association of Governments (SANDAG), laid out key principles for managing the region’s growth while preserving natural resources and limiting urban sprawl. The plan covered eight policy areas, including urban form, transportation, housing, healthy environment, economic prosperity, public facilities, our borders, and social equity.
In 2011, SANDAG approved the 2050 Regional Transportation Plan an d Sustainable Communities Strategy (RTP/SCS). This approval marked the first time SANDAG’s RTP included a sustainable communities strategy, consistent with the Sustainable Communities and Climate Protection Act of 2008, also known as Senate Bill 375. This RTP/SCS provided a blueprint to improve mobility, preserve open space, and create communities, all with transportation choices to reduce greenhouse gas emissions and meet specific targets set by the California Air Resources Board (CARB) as required by the 2008 Sustainable Communities Act. In 2010, CARB established targets for each region in California governed by a metropolitan planning organization. SANDAG is the metropolitan planning organization for the San Diego region.
The SANDAG target, as set by CARB , is to reduce the region’s per capita emissions of greenhouse gas emissions from cars and light -duty trucks by 7% by 2020, compared with a 2005 baseline. By 2035, the target is a 13% per capita reduction. There is no target set beyond 2035. To achieve the 2020 and 2035 targets, SANDAG and other metropolitan planning organizations are required to develop a Sustainable Communities Strategy (SCS) as an element of its RTP. The SANDAG SCS integrates land use and transportation plans to achieve reductions in greenhouse gas emissions and meet the CARB-required targets.
On October 9, 2015, the SANDAG Board of Directors adopted San Diego Forward: The Regional Plan (Regional Plan). The Regional Plan combines the two previously described existing regional planning documents: the RCP and the RTP/SCS. The Regional Plan updates growth forecasts and is based on the most recent planning assumptions considering currently adopted land use plans, including the City’s General Plan and other factors from the cities in the region and the County. SANDAG’s Regional Plan will change in response to the ongoing land use planning of the City and other jurisdictions. For example, the City’s General Plan, and other local General Plans of cities, may change based on General Plan amendments initiated by the jurisdiction or landowner applicants.
The General Plan amendments may result in increases in development densities by amending the regional category designations or zoning classifications. Accordingly, SANDAG’s RTP/SCS latest forecasts of future development in the San Diego region, including location, must be coordinated closely with each jurisdiction’s ongoing land use planning because that planning is not static, as recognized by the need for updates to SANDAG’s RTP/SCS every 4 years .
In 2019, the SANDAG Board of Directors adopted the San Diego Forward: The 2019 Federal Regional Transportation Plan. It combines the big -picture vision for how the region will grow by 2050 with an implementation program to help make that vision a reality.
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SANDAG is in the processing of developing San Diego Forward: The 2021 Regional Plan. The Regional Plan is updated every four years and combines three planning documents that SANDAG must complete per state and federal laws: The Regional Transportation Plan, S ustainable Communities Strategy, and Regional Comprehensive Plan. The Regional Plan also supports other regional transportation planning and programming efforts, including overseeing which projects are funded under the Regional Transportation Improvement P rogram and the TransNet program .
SANDAG is applying data -driven strategies, innovative technologies, and stakeholder input to create a future system that is faster, fairer, and cleaner. Part of this data -driven approach includes the implementation of five key transportation strategies referred to as the 5 Big Moves. These strategies provide the framework for the Regional Plan and consider policies and programs, changes in land use and infrastructure, take advantage of the existing transportation highway and transit networks, and leverage trends in technology to optimize use of the transportation system. Together, these initiatives will create a fully integrated, world -class transportation system that offers efficient and equitable transportation choices, mee ts state climate targets, and supports local jurisdictions’ achievements of Climate Action Plan goals.
Congestion Management Program (CMP)
The 2008 Congestion Management Program (CMP) for San Diego County was developed to meet the requirements of Section 6 5089 of the California Government Code. Since that time, the local agencies within San Diego County approved to opt out of the CMP requirements, as allowed within the Government Code. As such, there are no CMP -specific requirements associated with this project.
However, to ensure the region’s continued compliance with the federal congestion management process, SANDAG has prepared San Diego Forward: The Regional Plan in compliance with 23 Code of Federal Regulations 450.320. The Regional Plan incorporates pe rformance monitoring and measurement of the regional transportation system, multimodal alternatives to single -occupancy vehicles, land use impact analysis, congestion management tools, and Integration with the Regional Transportation Improvement Program process.
City of San Marcos Transportation Impact Analysis Guidelines The City of San Marcos approved Transportation Impact Analysis Guidelines (TIAG) on November 16, 2020 (City of San Marcos 2020). TIAG provide screening criteria for determining whether a l and development project should conduct a Vehicle Miles Traveled (VMT) analysis. These thresholds are based on the project’s consistency with the General Plan, estimated daily trips, project location, and other project characteristics. A VMT analysis applie s to all land development projects except for those that meet at least one of the provided screening criteria.
City of San Marcos Bikeway Master Plan
The 2005 Bikeway Master Plan is an update to the City’s original master plan adopted in 2001.
Goals of the master plan were to obtain State Bicycle Transportation Account (BTA) grant funds and improve bicycle facilities throughout the city for safer routes to school, connections to adjacent cities and incorporate an environmental inventory analysis. One of the goals of the master plan was to connect the City’s trails to bicycle facilities to complete a safe and enjoyable trail and bikeway system.
San Marcos General Plan
The Land Use and Community Design Element of the General Plan identifies specific policies related to congestion management. Those that are applicable to the proposed project are identified below.
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• Policy LU-3.7: Require new development to prepare traffic demand management programs. • Policy LU-3.8: Require new development and discretionary actions to annex into a Congestion Management Community Facilities District.
The Mobility Element of the General Plan identifies specific goals and policies related to an efficient circulation system, traffic calming and safety, and alternative modes of travel. Those that are applicable to the transportation analysis for the proposed project are identified below. Policy M-1.4, which addresses LOS is analyzed in Section 3.10-4, Land Use. • Goal M-1: Provide a comprehensive multimodal circulation system that serves the City land uses and provides for the safe and effective movement of people and goods. o Policy M-1.1: Safely and efficiently accommodate traffic generated by development and redevelopment associated with implementation of the General Plan Land Use Policy Map o Policy M -1.2: Require new development to finance and construct internal adjacent roadway circulation and City -wide improvements as necessary to mitigate project impacts, including roadway, transit, pedestrian, and bicycle facilities. o Policy M -1.3: Require new developments to prepare and implement Transportation Demand Management (TDM) programs to minimize vehicle trip generation and promote alternative modes of travel within the city.
o Policy M-1.4: Utilize multi-modal LOS techniques to evaluate transportation facilities. For identified prioritized modes (based on facility typology), provide the following minimum LOS as shown in Table 3-4 of the Mobility Element:
LOS D or better for Vehicles as a prioritized mode
⸋ Generally, provides facilities that have minimum vehicle congestion during peak periods. Most motorists are delayed less than 55 seconds at a signal (or less than one signalized cycle).
The City shall allow for flexible LOS where warranted (e.g., accepting a lower LOS than identified above).
o Policy M-1.6: Work to improve connectivity within the City by closing gaps in the existing bicycle, pedestrian, trail, transit, and roadway network. Work with new development to provide connectivity and redundancy in the mobility network. o Policy M-1.7: Strive to ensure that streets within San Marcos shall be complete streets where feasible; thereby providing accessibility, safety, connectivity, and comfort for all modes and users of the system. Appropriate n ew local streets and Main Streets will prioritize pedestrian and bicycle users through the corridor. • Goal M-2: Protect neighborhoods by improving safety for all modes of travel and calming traffic where appropriate.
o Policy M -2.1: Work with new development to design roadways that minimize traffic volumes and/or speed, as appropriate within residential neighborhoods; while maintaining the City’s desire to provide connectivity on the roadway network.
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o Policy M -2.3: Consider roundabouts, as appropriate, as an in tersection control device with demonstrated air quality, traffic efficiency, and safety benefits. • Goal M-3: Promote and encourage use of alternative transportation modes, including transit, bicycles, neighborhood electric vehicles (NEVs), and walking, within the City. o Policy M-3.1: Develop an integrated, multimodal circulation system that accommodates transit, bicycles, pedestrians, and vehicles; provides opportunities to reduce air pollution and greenhouse gas emissions; and reinforces the role of the stre et as a public space that unites the City.
o Policy M -3.2: Improve safety conditions, efficiency, and comfort for bicyclists and pedestrians through design, maintenance, and law enforcement. Install wider sidewalks and curb extensions at pedestrian crossings (bulb outs) where appropriate. o Policy M -3.3: Provide a pedestrian and bicycle network in existing and new neighborhoods that facilitates convenient and continuous pedestrian and bicycle travel free of major impediments and obstacles.
o Policy M-3.5: Ensure that streets in areas with high levels of pedestrian activity (such as employment centers, residential areas, mixed use areas, and schools) support safe pedestrian travel by providing detached sidewalks, bulb -outs, enhanced pedestrian crossings, pedestrian bridges, and medians.
o Policy M -3.9: Create a pleasant walking environment for roadway typologies where pedestrian travel is prioritized. This includes providing shade trees, landscaping, benches, pedestrian -scale lighting, way finding signage, transit she lters, and other appropriate amenities.
The proposed project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10, Land Use and Planning. As presented in Table 3.10 -5 in Section 3.10, the project is consistent with the applicable goals and policies with the exception of Polic ies M1.1 and M-1.4, which relate to level of service. As detailed in Section 3.10.4, Land Use, the project will have a significant and unavoidable impact at the Rancheros/SR 78 Westbound (WB) ramp.
3.15.3 Thresholds of Significance
Appendix G of the California Environmental Quality Act (CEQA) Guidelines provides thresholds for determining significant environmental impacts. A project may be deemed to have a significant impact on transportation/traffic if it would:
• Threshold #1: Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities; or • Threshold #2: Conflict or be inconsistent with CEQA Guidelines Section 15064.3(b); or • Threshold #3: Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or • Threshold #4: Result in inadequate emergency access.
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3.15.4 Project Impact Analysis
Threshold #1: Conflict with a p rogram plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities The project would not result in any conflicts related to plans or policies addressing transit, bicycle, and pedestrian facilities. The project would not result in any impact to existing built out pedestrian and bicycle facilities along the project frontage. The project’s internal pedestrian circulation network would connect to the existing sidewalk on E. Barham. The closest bus stops are 0.7 mile from the project site and would not be impacted by the project. No impact related to a conflict with a program plan, ordinance, or policy addressing transit, bicycle and pedestrian facilities is identified for the project.
However, b ased upon the analysis presented in Section 3.10.4, the project will result in an inconsistency with the Mobility Element of the City’s General Plan. Specifically, Mobility Element Policies M-1.1 and M-1.4 identify preferred level of service for roadways and intersections. The Local Mobility Analysis/Level of Service analysis presented in Section 3.10.4 of determined that all study intersections and street segments are calculated to operate acceptably at LOS D or better with the addition of project traffic, with the exceptio n of three intersections. Northbound left-turn movements out of both the western and eastern project driveways would result in unacceptable LOS under Near Term 2025 and Horizon Year 2050 conditions . However, Mitigation Measures LU -2 and LU -3 were identified that restrict left -turns out of these driveways between 4 PM and 6 PM . Those measures would reduce impacts to below a level of significance.
Project traffic will also impact the Rancheros Drive / SR-78 WB Ramp which is calculated to operate at LOS F under both “without project ” and “ with project” in the Near Term 2025 conditions.
Mitigation Measure MM -LU-1 would reduce this impact to below a level of significance but because MM-LU-1 includes funding for improvements at a facility that is under Caltrans control, not the City’s control, it was concluded that the impact would be determined to be significant and unavoidable.
This represents a conflict with the LOS goals of the Mobility Element and represents a significant impact (Impact TR-1).
• Impact TR-1 Project-related traffic results in a significant increase in delay (greater than
2.0 seconds) at the Rancheros Drive/ SR - 78 WB intersection in the AM and PM peak hours under Near Term 2025 With Project condition.
Threshold #2: Conflict or be inconsistent with CEQA Guidelines Section 15064.3(b).
The City’s Transportation Impact Analysis Guidelines (San Marcos 2020b) provide s everal screening approaches to identify when a project should be expected to cause a less -than-significant impact related to VMT. The project does not meet any of the screening criteria therefore a transportation VMT analysis using the SANDAG Regional Travel Demand Model is required. The recommended tools to estimate VMT are outlined below.
• SANDAG Travel Demand Model : The SANDAG regional travel demand model can be used to estimate VMT and traffic volumes in the City. This tool can be used to estimate VMT efficiency metrics specific to a project, as well as total citywide VMT.
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• SANDAG Online VMT Tool: SANDAG has prepared an online VMT estimating tool to estimate VMT efficiency metrics for residential and employment projects. This tool maps VMT by census tract in San Diego County.
The use of the SANDAG online VMT mapping tool should be limited to individual land -use projects where an efficiency metric (such as VMT per capita or per employee) is being estimated. In addition, the use of the online tool should be limited to projects generating fewer than 2,400 daily vehicle trips, with trip generation estimated using SANDAG’s (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region (April 2002).
VMT Significant Impact Thresholds
Based on the City’s Transportation Impac t Analysis Guidelines, the transportation VMT thresholds of significance are shown in Table 3.15 -2. Since the project proposes a residential use, a significant impact would occur if the project generates VMT per resident that exceeds a level of 15 percent below the existing countywide average.
Table 3.15-2. VMT Impact Threshold by Land Use
Land Use Type Impact Threshold
Residential Uses
A significant impact will occur if the project generates VMT per resident exceeding a level of 15 percent below the existing countywide average.
Employment Projects
(including office and
industrial)
A significant impact will occur if the project generates VMT per employee exceeding a level of 15 percent below the existing countywide average.
Retail Uses A significant impact will occur if the project would result in a net increase in existing total citywide VMT.
Mixed-Use Projects
Evaluate each component of a mixed-use project independently and apply the significance threshold for each land use type, incorporating internalization reductions.
Redevelopment Projects
(replaces existing uses)
If the project results in a net increase in VMT, apply the appropriate significance threshold for the project land use type(s).
Source: City of San Marcos Transportation Impact Analysis Guidelines (November 2020) VMT Analysis
A detailed transportation VMT per resident analysis was conducted using the SANDAG Series 13 Year 2020 Travel Demand Model (LLG 2021). The model generates a land use -specific average tr ip length as well as an average daily volume, which ultimately calculates the total VMT per resident. The SANDAG Series 13 Year 2020 Travel Demand Model results are included in Appendix K of this document.
Table 3.15-3 summarizes the regional average baseline VMT results provided by SANDAG. As shown in Table 3.15 -3, the r egional average baseline VMT per resident is 17.6 miles per resident. For the purpose of determining the significance of VMT impacts, the project VMT per capita would need to be 15% below the Regional average, which equates to 14.96 VMT per resident.
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Table 3.15-3. Project VMT Findings
Scenario
Regional
Baseline VMT
per Capita
Significance
Threshold(1)
Project VMT
per Capita
Transportation
Impact?
(Over Threshold)
VMT per Resident 17.6 14.96 18.2 Yes
Source: SANDAG, October, 2020
Note: (1) 85% of the Regional baseline VMT per capita
Similar to the regional average baseline calculations, the project VMT per resident was calculated.
The project site is located in Traffic Analysis Zone (TAZ) 1026. As shown in 3.15 -3, the average VMT per resident for TAZ 1026 is calculated at 18.2 VMT per resident . The results of the project VMT comparison indicate that the project would exceed the VMT significance threshold by 21.66%. This would require mitigation of 21.66% or more to reduce the VMT impact to less-than-significant.
When a p roject results in a signi ficant impact, CEQA requires mitigation measures to be implemented to reduce or mitigate impacts. With the shift away from LOS, delay, and vehicular capacity metrics and impact thresholds to VMT thresholds, mitigating significant transportation impacts now requires focusing on measures to shorten vehicle trip distances or reduce single - occupancy vehicle trips (in favor of carpooling, taking public transit, bicycling, walking, and other modes), since VMT in essence is a function of the number of vehicle trip s and their associated trip lengths. Whereas previous LOS-related mitigation measures focused on expanding roadway facilities primarily for vehicles, VMT -reducing mitigation measures can include modifying project characteristics, implementing on - or off -site improvements to transit, pedestrian and bicycle facilities, parking management strategies, and TDM strategies to either reduce or shorten vehicular trips.
Specific VMT mitigation strategies applicable to projects in the City have been developed based on a review of relevant literature and research. The selected strategies, as well as the applicable VMT reduction percentages and other attributes, included in Appendix K of this document , are primarily based on a review of the guidance published by the Cali fornia Air Pollution Control Officers Association (CAPCOA) in August 2010 ( Quantifying Greenhouse Gas Mitigation Measures: A Resource for Local Government to Assess Emission Reductions from Greenhouse Gas Mitigation Measures).
Based on the VMT analysis pre sented above, a significant transportation impact is calculated. The results of the p roject VMT comparison indicate that the p roject would exceed the significance threshold by 21.66%. This would require mitigation of 21.66% or more to reduce the VMT impact to less-than-significant.
It should be noted that there is a limit to the amount of VMT reduction that can be applied to a development project. Within the City, with its suburban land use and transportation context, CAPCOA indicates that the maximum feasible total reduction combining all measures is 15%. All City - suggested off-site improvements are not applicable or not feasible for the project to install. Project design features that would contribute to additional VMT reductions include: 1) provision of bicycle racks; 2) the CC&Rs will include a requirement that the HOA inform community members about public transit and carpool options; and 3) a telecommute workspace will be available in the community room building. There are no other feasible mitigat ion measures to reduce VMT for the project. Even if all feasible mitigation measures were implemented, the project would still be unable to reduce impacts to below a level of significance.
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However, the CAPCOA measure LUT -1 (Increase Density ) was identified as a design measure that would reduce the p roject’s VMT as calculated using the SANDAG Series 13 Year 2020 Travel Demand Model. This design measure was selected since the project’s features meet the measure’s description and applicability criteria. Per LUT-1, designing the project with increased densities (i.e., dwellings per unit area) affects the distance people travel and provides greater options for the mode of travel they choose. This measure is applicable for residential projects in a suburban area.
To calculate the VMT reduction for this design measure, a comparative VMT calculation was conducted between the residential density in TAZ 1026 and in the p roject site. The residential density for TAZ 1026 was calculated by taking the total number of dwell ing units contained in the TAZ and dividing it by the total acreage on which the dwelling units lay. Based on the weighted average of the data, the residential density for TAZ 1026 is 7.03 dwelling units per acre. The average residential density of the project site is 14.3 dwelling units per acre. The calculations are included in Appendix K of this EIR.
Using the residential densities determined for TAZ 1026 and the p roject site, the corresponding VMT reductions were calculated using the CAPCOA methodology for LUT 1. The VMT reduction utilized for LUT-1 is the difference between the project site VMT reduction and the total TAZ VMT reduction.
The project’s net-VMT reduction associated with LUT -1 is calculated to be 6.2%. This 6.2% reduction in the project’s unadjusted VMT per capita of 18.2 results in a p roject VMT per capita of 17.07. Even with this adjustment, the project still exceeds the 14.96 VMT per capita significance threshold and results in a VMT-related significant impact (Impact TR-2). • Impact TR-2 The project’s per capita VMT is 17.07, which exceeds the threshold of 14.96 VMT per capita.
Threshold #3: Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm eq uipment).
Access to the project site will be via two unsignalized driveways on E. Barham Drive. The western driveway will be 40 -feet wide and serve as the primary entry to the project site and provide full access. The eastern driveway will be 26 -feet wide and will also provide full access . Based upon mitigation measures identified in Section 3.10, Land Use (MM-LU-2 and MM-LU-3), the project will be required to limit left turns out of both driveways between the PM Peak Hour (4:00 PM to 6:00 PM).
A secondary emergency -only access is provided through the western boundary of the project site at the western terminus of Street “C”. This access will connect to an existing emergency access driveway on the adjacent property which connects to Saddleback Way and then t o E. Barham Drive.
This access point is for emergency vehicles only and bollards would be put in place. A vehicle queuing analysis was prepared for the project and is discussed later in this section.
The internal circulation network does not include any ha zardous design features or propose any incompatible uses. As described in EIR Section 2.2.2.4, the proposed project’s internal roadways are designed to provide safe movement of bicycle, pedestrian, and vehicle traffic through the project site. Vehicular ci rculation through the project will be via three private 26 -foot-wide internal streets, Driveways “A”, “B” and “C”. These streets provide access to private alleys (Alleys A through K) . In addition, the proposed project provides an accessible path of travel through the site and to each residence via pedestrian pathways that also connect to the sidewalk on E. Barham Drive.
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Internal private driveways and alleys proposed within the project site are neighborhood streets designed to accommodate the level of traffic generated by the proposed project. Internal roadways are designed to provide the safe and quiet movement of bicycle, pedestrian, and vehicle traffic through the project site and to provide attractive frontages to residential lots.
Vehicle Queuing
Access to the project site will be via two unsignalized, full access driveways on E. Barham Drive as described above. A two- way left -turn lane along the project frontage on E. Barham Drive currently exists and will help facilitate left -turns into and out of the p roject site at the western driveway. The eastern driveway will also be full access. However, Per MM -LU-2 and MM-LU-3, left turns will not be permitted at either driveway during the PM Peak hour (4 PM to 6 PM).
In order to ensure the vehicle queue turning l eft into and out of the project site won’t exceed the available storage length, resulting in potential congestion and backups along E. Barham Drive and within the project site, an assessment of the potential left -turn queues at the project’s western driveway was conducted using the Synchro analysis software. An assessment of the potential eastbound right-turn / thru lane queue at the intersection of E. Barham Drive / La Moree Road was also conducted at the City’s request.