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SP20-0002_Staff Report_Attach D- EIR

San Marcos City Council
May 10, 2022

Document
SP20-0002_Staff Report_Attach D- EIR
Meeting
May 10, 2022
Body
San Marcos City Council
Pages
8
Original file
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Text extracted from the city's file for reading and search. Open the original on legistar2.granicus.com. That file is the official record.

Under Near-Term + Project condition s, the 95th percentile queues at the locations listed above were calculated to be much less than the available storage during the AM and PM peak hours, as shown in Table 3.15 -4. The 95th -percentile queue is defined to be the queue length that has only a 5 - percent probability of being exceeded during the analysis time period. Therefore, the available storage is expected to contain the vehicular queues and no impact is identified.

Table 3.15-4. Vehicle Queue Summary
Intersection Movement Peak
Hour
Available
Storage
(feet)
Year 2025
with Project Queue
(feet)
E. Barham Drive /
Project Driveway (West)
WBL
AM
>500
<25
PM <25
NBL
AM
100
<25
PM <25
E. Barham Drive /
Project Driveway (East)
WBL
AM
>500
<25
PM <25
NBL
AM
100
<25
PM <25
E. Barham Drive /
La Moree Road EBR/Thru
AM
>500
51 PM 116
Source: LLG 2021
General Note: 95th percentile queues reported.

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Line of Sight Analysis
A line -of-sight assessment was conducted to determine if there is adequate sight distance for vehicles exiting the project site (LLG 2021). Sight distance is the length of roadway visible to a driver.

The driver of a vehicle departing a driveway should have an unobstructed view of oncoming traffic to anticipate and avoid potential collisions.

Two outbound maneuvers can be completed at the western driveway: the left-turn maneuver and the right-turn maneuver. The outbound left -turn maneuver requires first clearing eastbound thru traffic, then entering the westbound stream of traffic. The required sigh t distance for this maneuver is affected by the amount of time it takes the stopped vehicle to turn left, clear the eastbound traffic and reach average running speed of the westbound traffic without affecting the speed of approaching vehicles.

The outbound right-turn maneuver must have sufficient distance to permit entrance onto the intersection roadway and then accelerate to the posted speed limit without being overtaken by approaching vehicles.

Table 1 of the Intersection Sight Distance Guidelines (San Ma rcos 2020b) lists the minimum sight distance requirements for the left and right -turn maneuvers based on design speeds. The design speed of E. Barham Drive Barham is 50 miles per hour (mph), and therefore based on the Intersection Sight Distance Guidelines, 550 feet of sight distance for the left -turn maneuver (looking eastbound) and 480 feet of stopping sight distance for the right -turn maneuver (looking westbound) should be provided.

Based on the Sight Visibility Triangle exhibit prepared for the project (included in Appendix J of Appendix K of this EIR), an adequate amount of unobstructed sight distance is provided looking both to the east and west from both of the proposed driveways.

As such, because the proposed project would not include any hazardous design features or any incompatible uses, and because the project would be designed to provide safe movement throughout and around the project site, impacts would be less than significant.

Threshold #4: Result in inadequate emergency access.

The project has been designed to incorporate a secondary emergency access point, in addition to the two project driveways. A secondary emergency-only access is provided through the western boundary of the project site to 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. Driveways and alleys within the project site will be private.

Fire truck templates were run for the project to ensure acceptable access and operation. The fire truck templates are included in Appendix K of this document. There is adequate space for fire truck ingress, egress and turning movements within the project. Additionally, the project design has also been reviewed by the Fire Marshal and no issues related to inadequate emergency access were identified. Impacts will be less than significant.

3.15.5 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

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Guidelines Section 15130(b)(1)(A)(B), an adequate d iscussion 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 transportation , the cumulative an alysis 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.

Cumulative VMT Analysis
According to the City’s Transportation Impact Analysis Guidelines (San Marcos 2020b) if a land use project (or a component of a mixed -use project) is screened out of requiring a detailed existing VMT analysis or if it falls below the existing V MT thresholds outlined in Table 2 of the Transportation Impact Analysis Guidelines, it would also result in a less than significant cumulative impact.

For the proposed project, which proposes a residential use, a significant impact would occur if the project generates VMT per resident exceeding a level of 15 percent below the existing countywide average. As detailed in Section 3.15.4, the project will have a VMT per resident that exceeds this amount. A significant and unavoidable impact was identified.

Per the City's Transportation Impact Analysis Guidelines, if a project does not screen out, or exceeds the threshold, the project must demonstrate consistency with the City’s General Plan to result in a less than significant cumulative impact. If City staff de termines consistency with the General Plan, then the project would result in less than significant cumulative impacts. If the City determines inconsistency (due to proposed land uses and/or densities), a cumulative impact analysis would be required to determine if the project would result in a net increase in regional VMT.

Based upon the analysis presented in Section 3.10, Land Use, the proposed project was determined to be inconsistent with two policies of the Mobility Element of the General Plan. Further, because the proposed project results in a significant and unavoidable project -level VMT impact, it is also concluded that the project results in a
significant and un avoidable cumulative VMT impact. As a condition of project approval, the applicant/develop er/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: CFD2011-01 (Congestion Management).

Hazards Due to Design and Emergency Access
Site design hazards and emergency access are analyzed and addressed on a project -by-project basis. Impacts for the project in these two topical areas w ere determined to be less than significant.

Each of the projects in Table 2 -3 that includ ed development would be reviewed to ensure that the site design does not include any traffic related hazards and that there is adequate emergency access or required mitigation measures to reduce impacts . Therefore, no cumulative impact is identified.

3.15.6 Mitigation Measures
Impact TR-1 Conflict with Policies Addressing Roadways

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Implementation of mitigation measures LU -1, LU-2, and LU-3, which were identified in Section 3.10, Land Use, are applicable to this impact:

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.

MM-LU-2 The project shall 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 final project plans and shall be put in place prior to project operation.

MM-LU-3 The p roject 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 restric tion. The signage requirement shall be noted on the final project plans and shall be put in place prior to project operation.

Impact TR-2 Vehicle Miles Traveled
There are no applicable or feasible mitigation measures to reduce the project’s VMT impact. The impact remains significant and unavoidable.

3.15.7 Conclusion
Based upon the analysis presented in Section 3.15.4, the project will not have an impact related to a conflict with a program plan, ordinance or policy addressing the circulation system, including tra nsit, roadway, bicycle, and pedestrian facilities.

The project will result in a significant and unavoidable impact related to consistency with policies related to roadways. Based 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. Mitigation measures MM -LU-1, MM -LU-2 and MM -LU-3 would reduce this impact to below a level of significance. However, because the mitigation measure 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.

Project impacts related to hazards due to a design feature or incompatible use or inadequate emergency access were determined to be less than significant.

The project will have a significant and unavoidable impact related to VMT. While the project represents an increase in residential density on the project site compared to the residential density in TAZ 1026, this is not enough to offset the project’s incre ase in VMT in light of the City’s threshold .

The project’s net VMT per c apita is 17.07, which exceeds the 14.96 VMT per capita significance threshold.

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

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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 are included in Appendix K of this document. Of the various mitigation strategies that are presented in the VMT Mitigation Measures Memorandum (Kittelson & Associates 2020) as option for projects in the City, the majority are not applicable to the project based upon the type of use proposed and/or the location of the project. Each of the possible mitigation option s was reviewed by the project applicant and were determine to not be applicable to the project or not feasible.

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%. So even if there were feasible mitigation measures and all were implemented, the project would still be unable to reduce impacts to below a level of significance.

As such, there are no mitigation measures identified to reduce the project’s VMT. VMT impacts remain
significant and unavoidable.

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3.16 Tribal Cultural Resources
Introduction
This section analyzes the potential impacts of the proposed project on tribal cultural resources. As defined by Public Resources Code Section 21074, a tribal cultural resource is a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is 1) either on or eligible for the California Register of Historic Resources (CRHR) or a local historic register, or 2) determined by the City, at its discretion to treat the resources as a tribal cultural resource (Public Resources Code Section 5024.1). Cultural resources are further analyzed in Section 3.4, Cultural Resources, of the Environmental Impact Report (EIR).

The analysis in this section is based upon the following report prepared by ASM Affiliates (ASM) as on-site well as specific outreach and consultation with appropriate Tribes:
• Cultural Resources Inventory for the Barham Residential Project , San Marcos, California, November 3, 2020 (ASM 2020)
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 cultural resources study is included as Appendix F.1 of the EIR and the General Plan is available on the City’s web site. 16 Table 3.16-1 summarizes the cultural resources project - and cumulative- level impacts, by threshold.

Table 3.16-1. Tribal Cultural Resources Summary of Impacts Threshold of Significance Project-Level
Impact
Cumulative-
Level Impact
Impact After
Mitigation
#1 – Cause a substantial adverse change in
the significance of a tribal cultural resource,
defined in Public Resources Code Section
21074 as either a site, feature, place,
cultural landscape that is geographically
defined in terms of the size and scope of the
landscape, sacred place, or object with
cultural value to a California Native
American tribe, and that is listed or eligible
for listing in the California Register of
Historical Resources, or in a local register of
historical resources as defined in Public
Resources Code Section 5020.1(k).

Potentially
Significant
No Impact Mitigated to Less
Than Significant
#2 – Cause a substantial adverse change in
the significance of a tribal cultural resource,
defined in Public Resources Code Section
21074 as either a site, feature, place,
cultural landscape that is geographically
Potentially
Significant
No Impact Mitigated to Less
Than Significant

16 http://www.san-marcos.net/work/economic-development/general-plan

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Threshold of Significance Project-Level
Impact
Cumulative-
Level Impact
Impact After
Mitigation
defined in terms of the size and scope of the
landscape, sacred place, or object with
cultural value to a California Native
American tribe, and that is a resource
determined by the lead agency, in its
discretion and supported by substantial
evidence, to be significant pursuant to
criteria set forth in subdivision (c) of Public
Resources Code Section 5024.1. In applying
the criteria set forth in subdivision (c) of
Public Resources Code Section 5024.1, the
lead agency shall consider the significance
of the resource to a California Native
American tribe.

3.16.1 Existing Conditions
This section provides information on the archeological context of the project site. It also provides information on the outreach and consultation efforts with local T ribes, as required by existing regulations.

Natural Setting
As discussed in Section 2, Project Description, of this EIR, the project site is generally undeveloped but appears to have been disturbed historically based on the presence of non -native grassland distinct from adjacent habitats and visible in historical aerial photographs of the area. Remains of an early twentieth -century agricultural homestead and surrounding orchard in existence as early as 1947 are present on the site and have been evaluated for historical significance. The majority of the project site supports 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 lan d 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.

Historical Context
Native Americans have occupied San Diego County for the past 10,000 years. The Archaic Period extends back at least 7,200 years, possibly to as early as 9,000 years ago. Early Archaic occupations in San Diego County are most apparent along the coast and major drainage systems e xtending inland from the coastal plains. Coastal Archaic sites are generally characterized by cobble tools, basin metates, manos, discoidals, dart points, and flexed burials. Together, these elements typify the La Jolla complex, which appears as the early coastal manifestation of a more diversified way of life.

Around 2,000 years ago, people from the Colorado River region began migrating into southern California in what is known at the Late Prehistoric period. Late Prehistoric sites are generally characterized by small, pressure -flaked projectile points, ceramics, an emphasis on collecting,

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processing, and storing plant food, and cremations. Villages became increasingly permanent, providing opportunity for the creation of stationary milling stations and the use of mortars for acorn processing.

In more recent times, two main cultural groups occupied San Diego County: the Luiseño in the north and the Kumeyaay (or Diegueño) in the south.

Records Search
A records search was undertaken at the South Coastal Informa tion Center (SCIC) of the California Historical Resources Information System on September 16, 2020 by ASM. The records search encompassed a search radius of one mile around the project site. A total of 55 previous cultural resources reports have been condu cted within a mile radius of the project area. Six of these reports address areas that intersect or overlap with the project area. California Historical Resources Information System ( CHRIS) records indicate the presence of 24 previously recorded cultural resources within a one -mile radius of the project site. No cultural resources have been previously recorded within the project area.

In general, the sites that were previously recorded within a one -mile radius of the project site consist predominantly of prehistoric resources. Most of these prehistoric sites are lithic scatters and bedrock milling features. Two prehistoric sites were noted to contain habitation debris, and one site was noted to contain burials, indicating a more intensive use of those locations during the prehistoric period. Several remnants of historic period features associated with single family properties, including foundations, privies, trash scatters, walls, fences, and associated historic debris scatters have been recorded within one mile of the project site. Many of these sites were previously disturbed or destroyed by modern construction and development activities and are now characterized by sparse surficial, as well as sparse or relatively shallow subsurface deposits.

Tribal Coordination
A Sacred Lands File (SLF) search at the Native American Heritage Commission (NAHC) by ASM on September 25, 2020 . ASM received a response letter from the NAHC on October 5, 2020 stating that a search of the Sacred Lands File was negative.

A list of 31 Native American tribes that are traditionally and culturally affiliated with the geographic area of the proposed project was also provided by the NAHC. A project notification letter was sent to each of the Native American contacts provided by the NAHC on October 7, 2020 by ASM Affiliates .

Three responses were received, including from the Viejas Band of Kumeyaay Indians (Viejas Band) on October 9, 2020, the Rincon Band of Luiseño Indians (Rincon Band) on October 13, 2020, and the Jamul Indian Village of California on October 19, 2020.

The Viejas Band letter indicated that the site does have cultural significan ce or ties to the Kumeyaay Nation and they recommended contacting the San Pasqual Band of Mission Indians (San Pasqual Band) and also requested that the City follow all National Environmental Policy Act, CEQA, and Native American Grave Protection and Repatriation Act laws and that City immediately contact San Pasqual of any changes or inadvertent discoveries. The San Pasqual Band was contacted as part of ASM’s project notification letter process.

The Rincon Band letter indicated that they do not have knowledge of cultural resources within the proposed project area but that does not mean that none exist. They also requested that a cultural resources report be prepared and a Sacred Lands File search be conducted. The cultural resources

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report prepared for the project (ASM 2020) included a Sacred Lands File search and the results of the search and report have been provided to the Rincon Band.

The Jamul Indian Village of California letter defers to the wishes of a closer tribe for the proposed project. They defer to the Iipay Nation of Santa Ysabel or the Mesa Grande Band of Mission Indians.

The City has included the Iipay Nation of Santa Ysabel or the Mesa Grande Band of Mission Indians on its distribution list for all project notices.

The City sent out notices to Tribes consistent with the requirements of AB 52. The Rincon Band and the San Luis Rey band requested consultation.:

The City consulted with the Rincon Band and the Tribe requested the City’s s tandard cultural resources mitigation measures be applied to the project. These measures are included for the project (MM-CR-1a through MM-CR-1c). On May 19, 2021 the Rincon Band submitted a letter saying they had no further comments and requested to conclude consultation.

The City provided the San Luis Rey Band the proposed mitigation measures for cultural resources.

On June 8, 2021, the San Luis Rey Band submitted a letter to the City stating they had reviewed the measures and indicated that they adequately address the Tribe’s concerns. The Tribe also requested to conclude consultation.

On-site Resources
As detailed in Section 3.4, Cultural Resources, of the EIR, ASM conducted a pedestrian survey of the project site in October 2020. No prehistoric cultural material was identified on the ground surface of the project site . All rodent burrows and back dirt, and other portions of exposed ground were carefully examined but provided no evidence for the presence of prehistoric cultural resources in those areas. However, the majority of the project site is covered with vegetation, and the vegetation density effectively limited ground surface visibility in the majority of the project site during the pedestrian survey. Therefore, it is possible that prehistoric cultu ral materials are present on the ground surface within the project site that were not visible during the survey.

As identified in Section 3.4.4, while historical resources ( Barham-2020-ASM-HD-01) were identified on the project site, including several concrete and rock foundation remains, concrete rubble, historic debris scatters, and metal t-post and wire fencing remnants, the site was determined to be ineligible for listing in the California Register of Historical Resources (CRHR) under any of the four criteria.

3.16.2 Regulatory Setting
The following section provides a general description of the applicable regulatory requirements pertaining to tribal cultural resources. The analysis of tribal cultural resources is a State requirement under CEQA, as required by Assembly Bill (AB) 52, described below . The City also has goals and policies in the General Plan Conservation and Open Space Element related to cultural resources, as described below.

Federal
Please see Section 3.4.2 , Cultural Resources – Regulatory Setting, for a description of Federal regulations pertaining to cultural resources. There are no specific federal regulation s that pertain, specifically, to tribal cultural resources.

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State
Senate Bill 18
SB 18, approved in 2004, amends the California Civil Code and the California Government Code, requiring cities and counties to contact and consult with California Native American tribes prior to adopting or amending any general plan or specific plan, or desig nating land as open space in order to preserve or mitigate impacts to specified Native American places, features and objects that are located within the city’s or county’s jurisdiction. SB 18 also requires cities and counties to hold in strict confidence a ny information about the specific identity, location, character, or use of these resources. In 2005, OPR published Tribal Consultation Guidelines to guide cities and counties on the process of engaging in consultation in accordance with SB 18. The Native A merican Heritage Commission (NAHC) maintains a list of California Native American Tribes with whom cities and counties must consult pursuant to SB 18.

Assembly Bill 52
AB 52 was approved in 2014 and adds new requirements regarding consultation with Califor nia Native American Tribes and consideration of tribal cultural resources. The law went into effect on July 1, 2015 and after that date, if requested by a California Native American Tribe, lead agencies must consult prior to the release of a Negative Declaration, Mitigated Negative Declaration or Draft EIR.

Local
San Marcos General Plan Conservation and Open Space Element The Conservation and Open Space Element of the City’s General Plan does not contain any specific policies that address tribal cultural re sources; however, it does contain several policies pertaining to the protection of archaeological resources. The following goal and policies apply to the project:
• 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. • Goal COS -11: Continue to identify and evaluate cultural, historic, archaeological, paleontological, and architectural resources for protection from demolition and inappropriate actions.
o 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.

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 -1, the project is consistent with the applicable General Plan goals and policies pertaining to cultural resources.

3.16.3 Thresholds of Significance
The determination of significance for tribal cultural resources is based on CEQA Guidelines Appendix G. Impacts to tribal cultural resources would be significant if the proposed project would:
• Threshold #1: Cause a substantial adverse change in the significance of a tribal cultural resource that is listed or eligible for listing in the California Register of Historical Resources,

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or in a local register of historical resources as defined in Public Resources C ode Section 5020.1(k); or
• Threshold #2: Cause a substantial adverse change in the significance of a tribal cultural resource that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

3.16.4 Project Impact Analysis
Project grading activities will result in ground disturbance in those areas of the project site proposed for development. Ground disturbing activities can result in impacts to tribal cultural resources if they are present on the project site. Mitigation me asures have been identified in Section 3.4, Cultural Resources, to reduce the potential to impacts to unknown cultural resources to below a level of significance (MM CR -1a through MM -CR-1c and MM -CR-2). The following analysis discusses the potential for the project to have on tribal cultural resources.

Threshold #1: Cause a substantial adverse change in the significance of a tribal cultural resource that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k).

Based upon the cultural resources study prepared for the project (ASM 2020) 17 and consultation with local tribes, the project site does not contain any known tribal cultura l resources that are listed or eligible for listing in the CRHR or in a local register of historical resources. No prehistoric cultural material was identified on the ground surface of the project site . All rodent burrows and back dirt, and other portions of exposed ground were carefully examined but provided no evidence for the presence of prehistoric cultural resources in those areas. However, the majority of the project site is covered with vegetation, and the vegetation density effectively limited ground surface visibility in the majority of the project site during the pedestrian survey. Therefore, it is possible that prehistoric cultural materials are present on the ground surface within the project site that were not visible during the survey (Impact C R-1). Mitigation is required to reduce potential impacts to unknown subsurface resources. MM-CR-1a through MM-CR-1c provide for the presence of archaeological and Native American monitors during ground disturbing activities that would be able to identify any previously unidentified cultural resources, to prevent inadvertent disturbance of any intact cultural deposits t hat may be present. Should any resources be identified, implementation of MM -CR-1a through MM-CR-1c would ensure proper handling and treatment of such resources by providing for a proper evaluation to determine whether additional archaeological work is nec essary. To further ensure impacts to Native American archaeological resources are protected, implementation of MM - CR-1a through MM-CR-1c and MM-CR-2 provides additional protections for significant resources, and describes the process for proper treatment a nd handling to ensure impacts are minimized.

Implementation of this mitigation would reduce potential project -level impacts to tribal cultural resources to below a level of significance.

ASM identified several historic features on a slightly elevated knoll in the northeastern portion of the project site, including several concrete and rock foundation remains, concrete rubble, historic debris scatters, and metal t-post and wire fencing remnants. The cultural materials identified in association

17 Full references for documents cited in this section are included in Chapter 7, References, of this EIR.

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with the historic site would not be considered tribal cultural resources. A review of historic aerial photos indicated that the historic site appears to represent the remains of an early twentieth-century agricultural homestead and surrounding orchard in existence as ea rly as 1947. In accordance with CEQA and the cultural resource management requirements of the City of San Marcos, ASM prepared an archaeological significance evaluation to determine eligibility for listing in the CRHR. As discussed in Section 3.4 Cultural Resources, ASM determined that the site was not eligible for listing in the CRHR under any of the four criteria.

Threshold #2: Cause a substantial adverse change in the significance of a tribal cultural resource that is a resource determined by the lead ag ency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Secti on 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

The City has not identified any cultural resources to be present on the project site pursuant to Public Resources Code Section 5024.1. Based u pon the cultural resources study prepared for the project (ASM 2020) and consultation with local tribes, the project site does not contain any known tribal cultural resource that are significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1
. However, as described in Section 3.4, Cultural Resources, and as identified above, impacts to unknown subsurface archaeological resources may occur on the project site. Therefore, the project has the potential to disturb unide ntified archeological resources during project grading (Impact CR -1). MM -CR-1a through MM -CR-1c provide for the presence of archaeological and Native American monitors during ground disturbing activities that would be able to identify any previously uniden tified cultural resources, to prevent inadvertent disturbance of any intact cultural deposits that may be present. Should any resources be identified, implementation of MM-CR-1a through MM -CR-1c would ensure proper handling and treatment of such resources by providing for a proper evaluation to determine whether additional archaeological work is necessary.

To further ensure impacts to Native American archaeological resources are protected, implementation of MM -CR-1a through MM -CR-1c and MM-CR-2 provides add itional protections for significant resources, and describes the process for proper treatment and handling to ensure impacts are minimized. Implementation of this mitigation would reduce potential project -level impacts to tribal cultural resources
to below a level of significance.

3.16.5 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 Sec tion 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 tribal cultural resources , the cumulative analysis is based upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts on tribal cultural resources.

While no resources were identified on the project site during the cultural resources reconnaissance, it was determined that there could be a potential for unidentified resources to be encountered subsurface during project grading. Other cumulative projects would be required to a ssess the

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potential for impact to archaeological resources and provide mitigation measures or avoidance measures to reduce significant impacts to cultural resources consistent with the requirements of CEQA and the City. Additionally, the lead agency is req uired to consult with tribes pursuant to the requirements of SB 18 and/or AB 52 . The City requires standard conditions of approval related to construction monitoring by an archeologist to ensure there are no inadvertent impacts to archeological resources. Cumulative impacts would be less than significant.

3.16.6 Mitigation Measures
Mitigation measures MM-CR-1-a through MM-CR-1b and MM-CR-2 identified in Section 3.4, Cultural Resources, would reduce potential tribal cultural resources impacts to below a level of significance.

MM-CR-1a Pre-Excavation Agreement. Prior to the issuance of a Grading Permit, or ground disturbing activities, the Applicant/Owner shall enter into a Tribal Cultural Resources Treatment and Repatriation Agreement (Pre -Excavation Agreement) with a Traditionally and Culturally Affiliated Native American Tribe (TCA Tribe), identified in consultation with the City. The purpose of the Pre -Excavation Agreement shall be to formalize protocols and procedures between the Applicant/Owner and the TCA Tribe for the protection, treatment, and repatriation of Native American human remains, funerary objects, cultural and/or religious landscapes, ceremonial items, traditional gathering areas, and other tribal cultural resources. Such resources may be located within and/or discovered during ground disturbing and/or construction activities for the proposed project, including any additional culturally appropriate archaeological studies, excavations, geotechnical investigations, grading, preparation for wet and dry infrastructure, and other ground disturbing activities. Any project -specific Monitoring Plans and/or excavation plans prepared by the project archaeologist shall include the TCA Tribe requirements for protocols and protection of tribal cultural resources that were agreed to during the tribal consultation.

The landowner shall relinquish ownership of all non -burial related tribal cultural resources collected during construction monitoring and from any previous archaeological studies or excavations on the proj ect site to the TCA Tribe for proper treatment and disposition per the Pre -Excavation Agreement, unless ordered to do otherwise by responsible agency or court of competent jurisdiction.

The requirement and timing of such release of ownership, and the recip ient thereof, shall be reflected in the Pre -Excavation Agreement. If the TCA Tribe does not accept the return of the cultural resources, then the cultural resources will be subject to curation.

MM-CR-1b Construction Monitoring. Prior to the issuance of a G rading Permit or ground disturbing activities, the Applicant/Owner or Grading Contractor shall provide written documentation (either as signed letters, contracts, or emails) to the City’s Planning Division stating that a Qualified Archaeologist and Traditi onally and Culturally Affiliated Native American monitor (TCA Native American monitor) have been retained at the Applicant/Owner or Grading Contractor’s expense to implement the construction monitoring program, as described in the Pre - Excavation Agreement.

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The Qualified Archaeologist and TCA Native American monitor shall be invited to attend all applicable pre -construction meetings with the General Contractor and/or associated subcontractors to present the construction monitoring program. The Qualified Arch aeologist and TCA Native American monitor shall be present on site during grubbing, grading, trenching, and/or other ground disturbing activities that occur in areas of native soil or other permeable natural surfaces that have the potential to unearth any evidence of potential archaeological resources or tribal cultural resources. In areas of artificial paving, the Qualified Archaeologist and TCA Native American monitor shall be present on the site during grubbing, grading, trenching, and/or other ground disturbing activities that have the potential to disturb more than six inches below the original pre -project ground surface to identify any evidence of potential archaeological or tribal cultural re sources. No monitoring of fill material, existing or imported, will be required if the General Contractor or developer can provide documentation to the satisfaction of the City that all fill materials being utilized at the site are either: 1) from existing commercial (previously permitted) sources of materials; or 2) are from private or other non -commercial sources that have been determined to be absent of tribal cultural resources by the Qualified Archaeologist and TCA Native American monitor.

The Qualified Archaeologist and TCA Native American monitor shall maintain ongoing collaborative coordination with one another during all ground disturbing activities. The requirement for the construction monitoring program shall be noted on all applicable con struction documents, including demolition plans, grading plans, etc. The Applicant/Owner or Grading Contractor shall provide written notice to the Planning Division and the TCA Tribe, preferably through e - mail, of the start and end of all ground disturbing activities.

Prior to the release of any grading bonds, or prior to the issuance of any project Certificate of Occupancy, an archaeological monitoring report, which describes the results, analysis, and conclusions of the construction monitoring shall be submitted by the Qualified Archaeologist, along with any TCA Native American monitor’s notes and comments received by the Qualified Archaeologist, to the Planning Division Manager for approval. Once approved, a final copy of the archaeological monitoring rep ort shall be retained in a confidential City project file and may be released, as a formal condition of Assembly Bill (AB) 52 consultation, to the Rincon Band, the San Luis Rey Band, or any parties involved in the project specific monitoring or consultatio n process. A final copy of the report, with all confidential site records and appendices, will also be submitted to the South Coastal Information Center after approval by the City.

MM-CR-1c Unanticipated Discovery Procedures. Both the Qualified Archaeolog ist and the TCA Native American monitor may temporarily halt or divert ground disturbing activities if potential archaeological resources or tribal cultural resources are discovered during construction activities. Ground disturbing activities shall be temporarily directed away from the area of discovery for a reasonable amount of time to allow a determination of the resource’s potential significance. Isolates and clearly non -significant archaeological resources (as determined by the Qualified Archaeologist, in consultation with the TCA Native American monitor) will be minimally documented in the field. All unearthed archaeological resources

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or tribal cultural resources will be collected, temporarily stored in a secure location (or as otherwise agreed upon by the Qualified Archaeologist and the TCA Tribe), and repatriated according to the terms of the Pre -Excavation Agreement, unless ordered to do otherwise by responsible agency or court of competent jurisdiction.

If a determination is made that the archaeolog ical resources or tribal cultural resources are considered potentially significant by the Qualified Archaeologist, the TCA Tribe, and the TCA Native American monitor, then the City and the TCA Tribe shall determine, in consultation with the Applicant/Owner and the Qualified Archaeologist, the culturally appropriate treatment of those resources.

If the Qualified Archaeologist, the TCA Tribe, and the TCA Native American monitor cannot agree on the significance or mitigation for such resources, these issues wi ll be presented to the Planning Division Manager for decision. The Planning Division Manager shall make a determination based upon the provisions of CEQA and California Public Resources Code Section 21083.2(b) with respect to archaeological resources and C alifornia Public Resources Section 21704 and 21084.3 with respect to tribal cultural resources, and shall take into account the religious beliefs, cultural beliefs, customs, and practices of the TCA Tribe.

All sacred sites, significant tribal cultural resources, and/or unique archaeological resources encountered within the project area shall be avoided and preserved as the preferred mitigation. If avoidance of the resource is determined to be infeasible by the City as the Lead Agency, then the City shall re quire additional culturally appropriate mitigation to address the negative impact to the resource, such as, but not limited to, the funding of an ethnographic study and/or a data recovery plan, as determined by the City in consultation with the Qualified Archaeologist and the TCA Tribe. The TCA Tribe shall be notified and consulted regarding the determination and implementation of culturally appropriate mitigation and the drafting and finalization of any ethnographic study and/or data recovery plan, and/or other culturally appropriate mitigation. Any archaeological isolates or other cultural materials that cannot be avoided or preserved in place as the preferred mitigation shall be temporarily stored in a secure location on site (or as otherwise agreed upon by the Qualified Archaeologist and TCA Tribe), and repatriated according to the terms of the Pre -Excavation Agreement, unless ordered to do otherwise by responsible agency or court of competent jurisdiction.

The removal of any artifacts from the project site will be inventoried with oversight by the TCA Native American monitor.

If a data recovery plan is authorized as indicated above and the TCA Tribe does not object, then an adequate artifact sample to address research avenues previously identified for sit es in the area will be collected using professional archaeological collection methods. If the Qualified Archaeologist collects such resources, the TCA Native American monitor must be present during any testing or cataloging of those resources. Moreover, if the Qualified Archaeologist does not collect the cultural resources that are unearthed during the ground disturbing activities, the TCA Native American monitor may, at their discretion, collect said

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resources for later reburial or storage at a local curat ion facility, as described in the Pre-Excavation Agreement.

In the event that curation of archaeological resources or tribal cultural resources is required by a superseding regulatory agency, curation shall be conducted by an approved local facility within San Diego County and the curation shall be guided by California State Historical Resources Commission’s Guidelines for the Curation of Archaeological Collections. The City shall provide the Applicant/Owner final curation language and guidance on the proje ct grading plans prior to issuance of the grading permit, if applicable, during project construction. The Applicant/Owner shall be responsible for all repatriation and curation costs and provide to the City written documentation from the TCA Tribe or the c uration facility, whichever is most applicable, that the repatriation and/or curation have been completed.

Human Remains
MM-CR-2 Human Remains . As specified by California Health and Safety Code Section 7050.5, if human remains, or remains that are potentia lly human, are found on the project site during ground disturbing activities or during archaeological work, the person responsible for the excavation, or his or her authorized representative, shall immediately notify the San Diego County Medical Examiner’s Office by telephone. No further excavation or disturbance of the discovery or any nearby area reasonably suspected to overlie adjacent remains (as determined by the Qualified Archaeologist and/or the TCA Native American monitor) shall occur until the Medical Examiner has made the necessary findings as to origin and disposition pursuant to Public Resources Code 5097.98.

If such a discovery occurs, a temporary construction exclusion zone shall be established surrounding the area of the discovery so that the area would be protected (as determined by the Qualified Archaeologist and/or the TCA Native American monitor), and consultation and treatment could occur as prescribed by law. As further defined by State law, the Medical Examiner will determine within two working days of being notified if the remains are subject to his or her authority. If the Medical Examiner recognizes the remains to be Native American, and not under his or her jurisdiction, then he or she shall contact the Native American Heritage Commis sion by telephone within 24 hours. The Native American Heritage Commission will make a determination as to the Most Likely Descendent, who shall be afforded 48 hours from the time access is granted to the discovery site to make recommendations regarding cu lturally appropriate treatment.

If suspected Native American remains are discovered, the remains shall be kept in situ (in place) until after the Medical Examiner makes its determination and notifications, and until after the Most Likely Descendent is iden tified, at which time the archaeological examination of the remains shall only occur on site in the presence of the Most Likely Descendent. The specific locations of Native American burials and reburials will be proprietary and not disclosed to the general public. According to California Health and Safety Code, six or more human burials at one location constitute a cemetery (Section 8100), and

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disturbance of Native American cemeteries is a felony (Section 7052). In the event that the Applicant/Owner and the Most Likely Descendant are in disagreement regarding the disposition of the remains, State law will apply, and the mediation process will occur with the NAHC. In the event that mediation is not successful, the landowner shall rebury the remains at a locat ion free from future disturbance (see Public Resources Code Section 5097.98(e) and 5097.94(k)).

3.16.7 Conclusion
Based upon the cultural resources study prepared for the project (ASM 2020) and consultation with local tribes pursuant to SB 18 and AB 52, the proje ct site does not contain any known tribal cultural resource that are listed or eligible for listing in the CRHR or in a local register of historical resources.

However, as described in impacts to unknown subsurface archaeological resources may occur on the project site. Therefore, the proposed project has the potential to disturb unidentified archeological resources during project grading . Mitigation is required to reduce potential impacts to unknown subsurface resources. MM -CR-1a through MM -CR-1c provide f or the presence of archaeological and Native American monitors during ground disturbing activities that would be able to identify any previously unidentified cultural resources, to prevent inadvertent disturbance of any intact cultural deposits that may be present. Should any resources be identified, implementation of MM-CR-1a through MM -CR-1c would ensure proper handling and treatment of such resources by providing for a proper evaluation to determine whether additional archaeological work is necessary.

To further ensure impacts to Native American archaeological resources are protected, implementation of MM -CR-1a through MM -CR-1c and MM -CR-2 provides additional protections for significant resources, and describes the process for proper treatment and handling to ensure impacts are minimized. Implementation of this mitigation would reduce potenti al project -level impacts to tribal cultural resources to below a level of significance.

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3.17 Utilities and Service Systems
Introduction
This section identifies the existing service providers for utilities and service systems, including water, wastewater, stormwater drainage, electric power, natural gas, and telecommunications facilities and analyzes the ability of these providers to serve the proposed project based upon current utility infrastructure. A detailed energy consumption analysis is included in Section 3.5, Energy, of this EIR.

The analysis in this section relies on the following documents, which are included as Appendices N.1 and N.2 of the EIR18:
• Hallmark-Barham Water and Sewer Study, Final Technical Memorandum, prepared by Vallecitos Water District, October 23, 2020.
• Request for Comments on the 943 E. Barham Drive Project , a letter from Karen Falk, Engineering Manager at RDDMWD, April 6, 2021.

The sewer study technical memorandum considered sewage generation increases due to proposed densification from the proposed project. The Vallecitos Water District (VWD) study also analyzed the ability of VWD’s infrastructure to serve the pr oposed project and made recommendations for the capital improvements for demand generated by the proposed project.

Table 3.17-1 summarizes the utilities and service system analysis, by threshold.

Table 3.17-1. Utilities and Service Systems Summary of Impacts Threshold of Significance Project-Level
Impact
Cumulative-Level
Impact
Impact After
Mitigation
#1 - Require or result in the relocation
of reconstruction of new or expanded
water, wastewater treatment or
stormwater drainage, electric power,
natural gas, or telecommunications
facilities, the construction or
relocation of which could cause
significant environmental effects?
Less than
Significant
Less than
Significant
Less than
Significant
#2 - Have sufficient water supplies
available to serve the project and
reasonably foreseeable future
development during normal, dry, and
multiple dry years?
Less than
Significant
Less than
Significant
Less than
Significant
#3 - Result in a determination by the
wastewater treatment provider which
serves or may serve the project that it
has adequate capacity to serve the
Less than
Significant
Less than
Significant
Less than
Significant

18 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
project’s projected demand in
addition to the provider’s existing
commitments?
#4 – Generate solid waste in excess
of State or local standards, or in
excess of the capacity of local
infrastructure, or otherwise impair the
attainment of solid waste reduction
goals?
Less than
Significant
Less than
Significant
Less than
Significant
#5 – Comply with federal, state, and
local management and reduction
statues and regulations related to
solid waste?
Less than
Significant
Less than
Significant
Less than
Significant

3.17.1 Existing Conditions
The following provides background information about the water, wastewater, solid waste, and other utility service providers that will serve the proposed project. It references applicable water and wastewater agency planning documents.

Water Service Area
The project site lies within Rincon Del Diablo Municipal Water District (RDDMWD) Improvement District 1 service area and will be served by RDDMWD for potable water and for water for fire protection. RDDMWD supplies potable and recycled water to a population of 30,000 people through nearly 8,000 connections representing residential, agricultural, landscape, and commercial/industrial water uses. RDDMWD’s service area includes the Cities of Escondido, San Marcos, and San Diego, and various unincorporated areas of San Diego County.

RDDMWD serves two distinct geographical areas, both of which have different potable water portfolios. These geographical areas are delineated as Improvement District 1 (ID 1) and Improvement District A (ID A). The project site is locate d within ID 1 (RDDMWD 2020). ID -1 is by far the largest of the two improvement districts, containing approximately 85 percent of the District’s total active service land area (7,945 acres), and approximately 90 percent of its population. The land area of I D-1 is approximately evenly split between the City of Escondido and unincorporated County areas, and is dominated by residential, rural residential and agricultural land uses (RDDMWD 2014).

In fiscal year 2015, there were 6,814 municipal connections and 4,72-acre feet (AF) supplied.

Although RDDMWD provides recycled water to its customers for landscape and irrigation use, RDDMWD does not currently operate a wastewater collection or treatment system but rather purchases treated water from the City of Escondido’s Hale Avenue Resource Recovery Facility (HARRF) (RDDMWD 2016).

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Water Supply
RDDMWD is a member of the San Diego County Water Authority (SDCWA), thus eligible to purchase water transported into San Diego County via the massive aqueducts of SDCWA and its wholesaler, Metropolitan Water District (MWD) of Southern California. To understand water supply availability for the proposed project, it is important to begin with MWD and follow the water supply through these agencies.

MWD was formed in 1928 to develop, store and distribute supplemental water to southern California for domestic and municipal purposes. MWD consists of 26 -member agencies and has a service area covering six counties, 5,200 square miles, and 19 million people. MWD obtains water from local sources as well as the Colorado River (via the Colorado River Aqueduct) and the Sacramento -San Joaquin Delta (via the State Water Project). MWD’s 2015 Urban Water Management Plan (UWMP) documents the availability of these supplies to meet future demands. With a projected annual water demand of 5,234,000 acre feet per year (AFY) for 2020, the MWD 2015 UWMP concludes that, with implementation of required conservation measures, MWD has supply capabilities sufficient to meet expected demands through 2040 under n ormal, single dry, and multiple dry water years (MWD 2016). The 2020 UWMP is being developed as part of the 2020 Integrated Resources Plan planning process and has not yet been approved. The Draft 2020 UWMP identifies a projected annual water demand of 4,6 05,500 AFY for 2025 and concludes that MWD has supply capabilities sufficient to meet expected demands from 2025 through 2045 under normal, single dry, and multiple dry water years (MWD 2021).

SDCWA is the largest member agency of MWD. SDCWA was establishe d in 1943, and, according to its 2015 UWMP, supplies 75 to 95 percent of the water needs in San Diego County through five major pipelines (SDCWA 2016). SDCWA’s service area covers 1,486 square miles and a population of 3.2 million. Annual water demand as o f 2015 was 539,361 AFY. By 2040, total normal water demands are projected to reach 718,773 AF (including future conservation, demand associated with projected near -term annexations, and accelerated forecasted growth), which represents a 29 percent increase from the average 557,241 AF of demand that occurred over the period 2010 - 2015. Despite MWD records demonstrating sufficient supply exists to meet anticipated demand, for its analysis SDCWA assumed MWD would allocate available supply in multiple dry water years to ration emergency supply. Incorporating this assumption, SDCWA projects reliable water supply for its member agencies in normal and single dry water years but potential water shortages in multiple dry water years. This prudent planning and water s upply allocation would ensure reserve supply is not completely depleted and instead remains available for future dry water years or very severe shortage situations.

RDDMWD currently imports most of its potable, treated water from SDCWA, particularly from t he SDCWA First Aqueduct (which just completed major rehabilitation in January 2021), and all of its recycled water from the City of Escondido’s HARRF. In previous years, the Rincon ID 1 water delivery system consisted only of 100% imported water purchased from the SDCWA. Since 2016, ID 1 water supplies are augmented from time -to-time with water originating from the Twin Oaks Valley Water Treatment Plant (TOVWTP). TOVWTP water is a blend of treated SDCWA water and desalinated sea water from the Claude “Bud” Lewis Carlsbad Desalination Plant (Lewis Desal Plant). Originating from the Carlsbad Agua Hedionda Lagoon, the desalinated water is a superior quality water – free of salt as well as biological and organic compounds (RDDMWD 2020).

Per the RDDMWD 2015 UWMP, in 2015 total demand for potable water was 5,744 AFY. It should be noted water demands for FY 2015 were significantly less than those projected in the 2010 UWMP.

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This variance was due to mandatory water use restrictions in effect in response to the State Water Resources Control Board’s (SWRCB) emergency drought regulations, depressed economic conditions, and increased water prices. Additionally, RDDMWD was able to convert an SDG&E power plant cooling tower to recycled water in 2007, significantly reducing potable demand (RDDMWD 2016).

RDDMWD has estimated that future demands will increase at the same rate as the SANDAG- projected population growth rate for RDDMWD’s service area. RDDMWD expects to use additional recycled water beginning in 2025. Some of this recycled water will offset current potable demands for landscape irrigation.

Table 3.17 -2 below shows projected water demands for the years 2020 - 2040 as reported in the 2015 UWMP.

Table 3.17-2. RDDMWD Projected Water Demands in Acre Feet Per year Water Use Sectors 2020 2025 2030 2035 2040
Single Family 4,618 4,859 5,002 4,995 4,975
Multi-Family 763 803 827 825 822
Commercial 1,424 1,499 1,543 1,543 1,535
Landscape Irrigation 545 100 100 100 100
Agricultural Irrigation 65 68 70 70 70
Potential Near-Term Annexations 0 417 417 417 417
Losses 252 263 271 270 269
Potable Subtotal 7,668 8,009 8,229 8,219 8,188
Recycled- Cooling Tower 2,800 2,800 2,800 2,800 2,800
Recycled – Landscape 350 1,200 1,200 1,200 1,200
Recycled Water Subtotal 3,150 4,000 4,000 4,000 4,000
Total 10,818 12,009 12,229 12,219 12,188
Source: 2015 Urban Water Management Plan (RDDMWD 2016)
As shown in Table 3.17-2, reliable quantities of projected water supply for Years 2025 and 2030 are 8,009 acre -feet per year and 8,229 acre -feet per year, respectively. RDDMWD projects that with supplies provided by SDCWA and compliance with the Water Conservation Bill of 2009, no water shortages would occur in a normal year through 2040 (RDDMWD 2016). The 2020 UWMP is currently under development.

Water Shortage Contingency Planning
History of Drought in California
California has the nation’s most variable climate, and droughts are a recurring feature. Very wet and very dry years are both common, while “normal” years —widely used to d escribe average

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precipitation—are rare. Yet one dry year does not constitute a drought. Water stored in the state’s reservoirs and groundwater basins protect against individual dry years. Droughts occur when two or more successive years are very dry, and r eservoirs and groundwater reserves are depleted (PPIC 2021).

Climate change is making droughts more intense. The past two decades have been exceptionally warm and dry, and included the hottest drought (2011 ‒17) in the state’s recorded history. Warming is m aking droughts more intense. A “thirstier” atmosphere—a direct consequence of warming — increases evaporation, which reduces water availability for ecosystems and human uses. Warming is also decreasing the proportion of precipitation that falls as snow. Snowpack is an important part of the state’s water storage system, accounting for about 30% of water supply. “Snow droughts” make it harder to manage reservoirs for water supply and hydropower generation (PPIC 2021).

Significant recent droughts in California occurred in 1976-77, 1987-92, 2007-09, and most recently, December 2011 through March 2017 (PP IC 2021). In March 2015, during the last drought, California Governor Jerry Brown ordered mandatory water use reductions for the first time in California’s history, saying the state’s four -year drought had reached near -crisis proportions after a winter of record-low snowfalls. Governor Brown, in an executive order, directed the SWRCB to impose a 25 percent reduction on the state’s 400 local water supply agencies, which serve 90 percent of California residents. The specifics for how to accomplish this reduction were left to the water agencies. (Nagourney 2015). On April 7, 2017, Governor Brown issued Executive Order B -40-17 rescinding emergency drought regulations in the state. RDDMWD customers cumulatively saved almost 29% since June 2015. RDDMWD lifted emergency regulations but remained in Level 1 promoting voluntary actions for water conservation (Thomas and Murtland 2017).

In April 2021, Governor Newsom declared another drought emergency. The declaration was originally limited to two counties in northern California, Sonoma, and Mendocino. No mandatory water restrictions have been imposed (Kasler and Bollag 2021). On May 10, 2021, Governor Newsom expanded his drought emergency proclamation to include 39 more counties, but not San Diego County (State of California Office of Governor Newsom May 2021a). On October 19, 2021, Governor Newsom issued a proclamation extending the drought emergency statewide and encouraged Californians to increase their water conservation efforts as the western U.S. faces a potential third dry year. The proclamation added the eight counties not previously included in the drought state of emergency: Imperial, Los Angeles, Orange, Riverside, San Bernardino, San Diego, San Francisco and Ventura. (State of California Office of Governor Newsom October 2021b).

According to Governor Newsom’s Office (May 2021), extraordinarily warm temperatures in April and early May 2021 separate this critically dry year from all others on California record. California experienced an accelerated rate of snow melt in the Sacramento, Feather, and American River watersheds, which feed the major reservoirs of the state and federal water projects. This was exacerbated when much of the snowpack, sitting on very dry ground, seeped into the earth rather than flowing into rivers and streams and into these reservoirs. Warming temperatures also prompted water diverters below the dams to withdraw their water much earlier and in greater volumes than typical even in other recent critically dry years. These factors reduced expected water supplies by more than 500,000 AF, enough to supply up to one million households with water for a year. The drastic reduction in water supplies means these reservoirs are extremely low for water users, including farmers, and fish and wildlife in the counties the drought proclamation covers (State of California Office of Governor Newsom May 2021a).

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The Governor’s May 2021 proclamation directed the State Water Board to consider modifying requirements for reservoir releases and diversion limitations to conserve water upstream later in the year to maintain water supply, improve water quality and protect cold water pools for salmon and steelhead. The state of emergency also enables flexibilities in regulatory requirements and procurement processes to mitig ate drought impacts and directs state water officials to expedite the review and processing of voluntary transfers of water from one water right holder to another, enabling available water to flow where it is needed most (State of California Office of Gove rnor Newsom May 2021a).

According to the October 2021 proclamation, California is experiencing its worst drought since the late 1800s, as measured by both lack of precipitation and high temperatures. August 2021 was the driest and hottest August on record since reporting began and the water year that ended in September 2021, was the second driest on record. The October 2021 proclamation authorizes the Governor’s Office of Emergency Services to provide assistance and funding under the California Disaster Assistance Act to support the emergency response and delivery of drinking water and water for public health and safety. In addition, the proclamation requires local water suppliers to implement water shortage contingency plans that are responsive to local con ditions and prepare for the possibility of a third dry year (State of California Office of Governor Newsom October 2021b).

MWD Drought Response
In March 2021, MWD reported that it expects to receive less than one month’s usual supply of water in 2021 from the state water project, which on average provides about 30 percent of Southern California’s water supply. MWD is managing through this by taking advantages of wet years, like 2017 and 2019, to move as much water into storage as possible. The agency has increased its total storage capacity by 13 times since 1990, investing in surface and groundwater storage across the southwest. Not only has MWD built vital infrastructure, such as Diamond Valley Lake and the Inland Feeder pipeline, which allow surplus wate r to quickly be stored in local reservoirs, it also has forged partnerships with water agencies across California for groundwater banking and exchanges. And it collaborated with partners along the Colorado River to establish a program to store water in Lake Mead, known as Intentionally Created Surplus, to enable MWD to provide a full Colorado River Aqueduct supply in dry years like 2021. Taken together, MWD now has more water in these storage accounts than it ever has before – a total of 3.2 million acre-feet. An acre-foot is the amount used by three typical Southern California households in a year (Business Wire 2021).

On August 17, 2021, in response to the extreme drought conditions impacting Southern California, MWD’s Board of Directors declared a Water Supply Alert, calling for consumers and businesses to voluntarily reduce their water use and help preserve the region’s storage reserves. The board’s action urges residents, businesses, and agencies in MWD’s service area to lower the region’s water demand to stave off more severe actions in the future, which could include restricting water supplies to MWD’s 26 member agencies. The declaration comes a day after the Bureau of Reclamation declared a first -ever shortage on the Colorado River, which typically pr ovides about 25 percent of Southern California’s water needs.

Rincon Drought Response
RDDMWD Drought Response Plan was updated and adopted in May of 2015 as Ordinance No. 15 - 120.2 (RDDMWD 2015). The response plan was developed to provide a response strateg y as required by the California Water Code, by establishing methods and procedures to ensure that, in a time of shortage, available water resources are put to maximum beneficial use, and that the unreasonable method of use is prevented. The Response Plan c ontains four levels, and is consistent

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with current regional messaging (RDDMWD 2016). RDDMWD’s response plan includes four stages of response. These stages are shown in Table 3.17-3.

Table 3.17-3. RDDMWD Water Shortage Contingency Plan
Stage Description Percent Supply Reduction Water Supply Conditions 1 Drought Watch 10 Voluntary 10% Reduction
2 Drought Alert 20 Mandatory 11-20 % Reduction
3 Drought Critical 30 Mandatory 21-30 % Reduction
4 Drought Emergency 50 Mandatory 31% or More Reduction
Source: 2015 Urban Water Management Plan (RDDMWD 2016)
RDDMWD is able to monitor water consumption and several currently state -mandated water use restriction violations using existing meters. All water use in the RDDMWD District is metered using advanced metering infrastructure (RDDMWD 2016).

RDDMWD has adopted a Water Conservation Ethic which is supported by its Administration Code 4000 – Water Conservation and supported by Ordinance 15 -120.2, An Ordinance of the Rincon del Diablo Municipal Water District Finding the Necessity for and Adopting a Drought Response Plan (RDDMWD 2015). As responsible stewards of a natural resource, the District’s Board of Directors acknowledges that its service area is located within an inland region that is subject to wide variations in annual precipitation and desert-like climatic conditions. Dependent largely on water imported from North California and the Colorado River, the District maintains a “No Water Wasting” ethic on a daily basis regardless of drought conditions (RDDMWD 2016).

RDDMWD discourages the use of commercial single -pass laundry systems, single -pass decorative fountains, or any other device or action that wastes water or uses water unreasonably. Under non - drought conditions, customers are required to repair le aks within five days of notification by the District and to use recycled water for construction purposes where available. Prohibitions include (RDDMWD 2016):
• Allowing irrigation runoff to flow across paved surfaces such as driveways and streets • Using a hose without a positive shutoff nozzle/device to wash a vehicle • Hosing off hard surfaces such as driveways and sidewalks • Applying irrigation during or within 48 hours after measurable rainfall • Serving drinking water other than upon request in eating or drinking establishments • Irrigating ornamental turf on public medians with potable water • Providing hotel/motel guest with the option of not receiving daily laundered linens • Irrigating landscapes after 8 PM and before 9 AM
• Washing vehicles in hot weather conditions during times of high levels of evaporation

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Water Infrastructure
The project site is currently undeveloped. Potable water is delivered to the project area by an existing 8-inch waterline that currently terminates within the Mira Lago Community east of the project site.

Existing facilities throughout RDDMWD’s service area include various reservoirs, pipes, and pump stations. According to RDDMWD’s Water Master Plan, future water system and reliability projects over the next five to ten years will prima rily occur within the Harmony Grove Village development, a residential development within the County of San Diego and development to the immediate north and south. New storage and transmission mains will be constructed as the system expands and serves new development. These expansions would also strengthen the reliability of existing water systems to access available water storage, enhance fire flow capabilities and provide increased redundancy (RDDMWD 2014).

RDDMWD’s potable water distribution system includes 117 miles of water main (8-inches or larger in diameter), ten reservoirs with a total storage capacity of 25.7 million gallons (MG), and four pump stations. Average distribution is calculated at 10 million gallons per day (MGD). RDDMWD’s recycled water system consists of 6.7 miles of water mains (8 -inch or larger in diameter), two pump stations, and 75 service connections (RDDMWD 2016).

Per the Master Plan, ID -1 is supplied by the First Aqueduct from two flow control facilities (RDDMWD 2014). The stor age reservoirs in ID -1 North serve to provide hydraulic control for the Aqueduct water supply. A smaller booster pressure zone (Rockhoff Zone), with storage, is located in the far north. In this area RDDMWD has the ability, in emergencies, to take water fr om the Vista Irrigation District (VID) Vista Flume through an 8 -inch connection. A small triangular piece in the northeast corner of the District (known as the Laurashawn area) is served by Valley Center Municipal Water District (VCMWD), but will soon be c onverted to RDDMWD through an extension of a new RDDMWD water main. RDDMWD will maintain an emergency intertie with VCMWD to supply ID -1 North by gravity. Overall, ID -1 North performs well under normal operating water conditions. ID -1 North and South are o perated at slightly different hydraulic gradients, an important hydraulic distinction for operations. This allows for better flow control from the Aqueduct system and actually simplifies operations. In order to hydraulically separate the areas, a flow cont rol valve, known as the Metcalf Flow Control Valve (a 20 -inch plug valve) is throttled to hydraulically separate the system. By throttling and adjusting the valve position (number of turns) the District can also supply excess SDCWA water ordered in ID-1 North to ID-1 South (RDDMWD 2014).

First San Diego Aqueduct
The backbones of the SDCWA system are the First and Second San Diego Aqueducts with two branch lines. The First Aqueduct consists of Pipelines 1 and 2, which extend from the MWD’s Colorado River Aqueduct near San Jacinto, California, to the City of San Diego`s San Vicente Reservoir, approximately 15 miles northeast of the city. Pipeline 1, designed by the Bureau of Reclamation, was constructed by the Navy Department to relieve the water supply emerge ncy in San Diego County.

Pipeline 2, roughly paralleling the first, was designed and constructed by the Bureau of Reclamation.

The two pipelines share common tunnels and inverted siphons. They are operated as single units.

The 12.5-mile Fallbrook-Ocean Branch originates from the First Aqueduct at Rainbow and extends to Morrow Reservoir. The La Mesa -Sweetwater Branch also originates from the First Aqueduct at Slaughterhouse Canyon, and extends through Lakeside and El Cajon to Sweetwater Reservoir. A number of connecting pipelines have been constructed to provide flexibility in operating the system.

One pipeline runs from the Second Aqueduct at Twin Oaks Valley to refill the First Aqueduct north of

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Escondido with untreated water after the agencies to the north have utilized the original capacity of the aqueduct (U.S. Bureau of Reclamation [USBR] 2021).

The First San Diego Aqueduct is about 70 miles long and water flows by gravity from an intake at an elevation of 1500 feet (ft) to the San Vicente Reservoir at a n elevation of 760 ft. The first two miles, the tunnels, and certain other sections not readily accessible were built to full capacity during construction of the first pipeline. The remaining sections, approximately 60 miles, compose a double pipeline. The separate pipelines are precast concrete pipe. The design capacity of the First San Diego Aqueduct is 196 cubic feet per second. There are seven tunnels ranging in length from 500 to 5,700 feet. These tunnels, together with the diversion line to the regula ting reservoir and the short reaches of full capacity pipeline, total about 14 percent of the length of the aqueduct (USBR 2021).

The SDCWA completed a major rehabilitation project on the First Aqueduct in January 2021. The project renovated and replaced d ozens of structures on two large -diameter pipelines, including Pipeline 1, which delivered the first imported water to the San Diego region in 1947 and remains a vital part of the regional water delivery system (SDCWA 2021a).

The timely rehabilitation of t he First Aqueduct is part of the Water Authority’s proactive asset management program. A key element of providing safe and reliable water supplies is continually assessing the agency’s 310 miles of large -diameter pipeline and making the upgrades necessary to continue serving the region. The First Aqueduct project began in early 2019 and was one of the most complicated pipeline retrofits in the Water Authority’s history. The upgrades included replacing 14,500 linear feet of lining on the steel pipe sections of Pipeline 1, removing 16 associated structures, and retrofitting 46 structures, all while ensuring regional water service remained safe and reliable. In addition, redundant connections to six flow control facilities were added between the two pipelines to improve the aqueduct’s operational flexibility (SDCWA 2021a).

Twin Oaks Valley Treatment Plan (TOVWTP)
Since 2016, Rincon ID 1 water supplies are augmented from time-to-time with water originating from the Twin Oaks Valley Water Treatment Plant (TOVWTP). TOVWTP water is a blend of treated SDCWA water and desalinated sea water from the Claude “Bud” Lewis Carlsbad Desalination Plant (Lewis Desal Plant). Originating from the Carlsbad Agua Hedionda Lagoon, the desalinated water is a superior quality water – free of salt as well as biological and organic compounds.

The TOVWTP is a submerged membrane water treatment plant providing high -quality drinking water for San Diego County. When completed in 2008, it was the largest plant of its kind in the world.

Located next to the SDCWA’s aqueduct in a semirural area north of San Marcos, the high -capacity treatment plant can provide enough water to serve up to 220,000 households per year. Before construction of the TOVWTP, nearly half of San Diego County’s drinking wate r was purified by MWD.

Growth in San Diego and Riverside counties increased the need for treated water, particularly during warm periods when water use is highest. Completion of the Twin Oaks facility has avoided treated water shortfalls when temperatures rise. SDCWA’s water treatment plant increases the amount of treated water produced in and for San Diego County. It allows more local control of the county’s treated water supply and increases water reliability for the region (SDCWA 2020).

Conventional wate r treatment plants rely on gravity filters and chemical coagulants to remove the suspended solids and organic material in untreated water from rivers or lakes. In submerged membrane treatment, untreated water is filtered through membrane fibers. Pores in t he membranes are large enough for water molecules to pass through, but small enough to filter out the vast majority

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of bacteria and viruses. Contaminants that do pass through are eliminated by a disinfection process similar to conventional treatment (SDCWA 2020).

Claude “Bud” Lewis Carlsbad Desalination Plant
In November 2012, the SDCWA approved a 30-year Water Purchase Agreement with Poseidon Water for the purchase of up to 56,000 AF of desalinated seawater per year, which is approximately 10 percent of th e San Diego region’s water demand. Poseidon is a private, investor -owned company that develops water and wastewater infrastructure. Under the Water Purchase Agreement, Poseidon built the Claude “Bud” Lewis Carlsbad Desalination Plant, and a 10 -mile conveya nce pipeline to deliver desalinated seawater to the SDCWA’s aqueduct system. This new, drought -proof supply reduces the region’s dependence on supplies that are vulnerable to droughts, natural disasters, and regulatory restrictions (SDCWA 2021b).

Desalination uses reverse osmosis technology to separate water molecules from seawater. Water from the ocean is forced through thousands of tightly -wrapped, semipermeable membranes under very high pressure. The membranes allow the smaller water molecules to pass th rough, leaving salt and other impurities behind (SDCWA 2021b).

Wastewater Service Area
Vallecitos Water District (VWD or District) provides potable water and wastewater services within northern San Diego County, including service to the City of San Marcos; parts of the cities of Carlsbad, Escondido, and Vista; and unincorporated areas within the County of San Diego. In addition, The District wholesales recycled water to the City of Carlsbad and the Olivenhain Municipal Water District. provides wastewater an d reclamation services to a 23 -square mile area serving approximately 93,000 people within their service area, as well as commercial, light industrial, institutional, construction, landscape irrigation, and agricultural customers. Within the study area there are some rural areas that still use septic systems for sewage disposal, thus the District’s current 23 -square mile sewer service area is much smaller in size than its water service area, although the District’s sphere of influence is equal in size for b oth. The District has over 20,600 sewer service connections with 4 lift stations and approximately 270 miles of pipeline (VWD 2016).

VWD would also provide the proposed project’s wastewater service. The project site is located in VWD’s Sewer Improvement D istrict “A” for sewer service only. The site lies completely within VWD sewer shed 26C (VWD 2020).

Wastewater Infrastructure
VWD’s sewer service area is divided between two principal drainage basins which are named based on the treatment facility which serves it. The treatment facilities used by VWD are the Meadowlark Water Reclamation Facility (MRF) and the Encina Water Pollution Control Facility (EWPCF). A third drainage basin, referred to as the Northern Tributary Area (NTA), is located in the northern part of the VWD which naturally drains away from the District’s existing collection system. The NTA is entirely made up of rur al residential and agricultural land uses and is served by on -site septic systems or by a neighboring agency. Land uses within the NTA are not planned to change and as such it is assumed that on -site septic systems will continue to service this area in the future. The existing wastewater collection system includes treatment facilities, major conveyance facilities, gravity mains, trunk sewers, lift stations, siphons, and force mains.

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Meadowlark Water Reclamation Facility (MRF)
In 1958, an improvement district was formed to finance the construction of a wastewater collection system. A second improvement district was formed that same year to finance the construction of a wastewater treatment plant, which was completed in 1961. The MRF was ret rofitted in the early 1980’s with upgraded treatment technologies and a wastewater treatment and recycled water production capacity of up to 2 MGD. Expansion of MRF was completed in 2008 to expand and improve the biological processes, which allowed the pla nt to increase capacity and more efficiently treat the wastewater while using less treatment chemicals. It also increasing its recycled water production capacity to 5 MGD, leading to VWD now being able to recycle up to 74% of the wastewater generated in t he service area. MRF is located within the southwestern portion of VWD’s service area in Carlsbad.

MRF is essentially a scalping plant that extracts water for projection of recycled water. MRF treats wastewater to meet the stringent standards of California Title 22 and Waste Discharge Permit R9 - 2007-0018 issued by the Regional Water Quality Control Board (RWQCB) Region 9. The MRF has a capacity of 5 MGD for liquids treatment. Wastewater that is not rerouted to MRF flows directly to the Encina Water Pollutio n Control Facility (discussed below) in the City of Carlsbad for both liquids and solids treatment via a 24 -inch recycled water pipeline. MRF does not treat for solids; instead, solids are pumped from MRF to the EWPCF for treatment (VWD 2018).

Encina Water Pollution Control Facility
The Encina Wastewater Authority (EWA) is the primary wastewater treatment provider utilized by VWD. The Encina Water Pollution Control Facility (EWPCF) also serves the City of Carlsbad, City of Encinitas (Encinitas Sanitary Division), Leucadia Wastewater District and Buena Sanitation District (City of Vista). The EWA was established to provide for the day -to-day operation of the EWPCF (VWD 2018). Built in the mid -1960s and expanded through the years to increase quality of treated water, improve odor control, add a cogeneration facility that generates electricity, upgrade the solids treatment process to produce a high -quality fertilizer project, the EWPCF now has an increased treatment capacity of 43.3 MGD. EWPCF provides secondary wastewater treatment to approximately 379,000 residents.

EWPCF (Ocean) Outfall
EWMPCF’s ocean outfall consists of approximately 1,000 feet on land and extends approximately 7,900 feet into the Pacific Ocean. The outfall components include:
• Surge tower and an effluent pump station (required for high flows or high tides), located at the west side of the EWPCF near the main entrance along Avenida Encinas. • 200 feet of 84-inch diameter reinforced concrete pipeline (RCP) from the surge tower to just east of the railroad tracks.
• 6,400 feet of 48 -inch diameter RCP. This original outfall segment was built in 1965 and starts at the 84 -inch pipeline and continues west to a depth of approximately 80 -feet in the Pacific Ocean.
• 2,300 feet of 72 -inch diameter RCP. This ou tfall extension was constructed in 1974. It includes an 800-foot, 138-point diffuser located at depths ranging from 135 feet to 168 feet below mean lower low water (MLLW) levels (VWD 2018).

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EWPCF Peak Flow Management
Managing peak flows is an important ope rational consideration. The EWPCF employs peak flow management procedures and has constructed facilities to manage peak flows. The EWPCF peak flow facilities include an existing 8 million gallon (MG) open, rectangular storage tank for holding secondary effluent and a pump station allowing the secondary effluent to be diverted to the basin.

The plant has provisions to incrementally increase capacity by adding two more 8 MG basins in the future, for a maximum storage capacity of 24 MG. The member agencies’ ab ility to manage inflow and infiltration into the sewer system is a major factor in deferring additional peak flow facilities or future outfall upgrades at the EWPCF (VWD 2018).

EWPCF Capacity Rights
The District’s Unit I capacity rights were set forth in t he 1998 Revised Basic Agreement and included

7.54 MGD of liquids treatment capacity and 7.54 MGD of solids treatment capacity. The most recently completed Phase V Expansion of the EWPCF was primarily solids driven. With that expansion, VWD maintained its 7 .54 MGD of liquids treatment capacity, and increased its solids treatment capacity to 10.47 MGD. In 2014, EWA re -rated the EWPCF capacity and a “true -up” calculation was performed, which adjusted the District’s liquid capacity to 7.67 MGD (VWD 2018).

Wastewater Outfall Facilities
Recycled Water Failsafe Pipeline
A recycled water failsafe pipeline, ranging in diameter from 12 -inches to 24 -inches in diameter, extends from MRF to the EWPCF ocean outfall. The failsafe pipeline is primarily used to dispose of either secondary or tertiary effluent from MRF that is not pumped to the Mahr Reservoir or treated effluent that cannot be sold as tertiary. Westerly portions of the failsafe line have been oversized to accommodate Buena Sanitation District (BSD) and Carlsba d Municipal Water District (CMWD) flows from existing and planned reclamation plants in their service areas. The BSD’s Shadowridge Water Reclamation Plan also connects to this pipeline. Capacity rights in the failsafe pipeline were defined in the “San Marc os County Water District, Buena Sanitation District, and The City of Carlsbad Agreement for the Operation and Maintenance of an Ocean Failsafe Treated Effluent Outfall Pipeline,” dated October 26, 1981. The agreement divided the failsafe pipeline into thre e reaches, (VWD, Buena and Carlsbad) for the purposes of allocating capacity rights.

In the 2003 Recycled Water Agreement with CMWD, it is acknowledged that under certain operational scenarios, the full production of MRF may exceed the failsafe pipeline ca pacity of 3 MGD, and the Mahr Reservoir may be at capacity with no additional storage available. To accommodate this event, CMWD will provide adequate facilities and operational flexibility to allow the District to dispose of additional flow into the Carls bad recycled water distribution system.

Disposal is subject to the availability of adequate capacity at the EWPCF flow equalization facility (VWD 2018).

Land Outfall
A majority of VWD’s wastewater is conveyed to the EWPCF using VWD’s maintained Land Outfal l. The Land Outfall is approximately 8 miles long and conveys flow by gravity as well as pressure through siphon sections. These sections are numbered alphabetically from east to west. The eastern portions of the Land Outfall (Gravity Section A and Siphon Section A) are owned and operated wholly by VWD (VWD 2018). Per the sewer study prepared for the proposed project, the land outfall capacity controlled by VWD is 12.10 MGD (VWD 2020). The westerly facilities (Gravity Section B, Siphon

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Section B, Gravity Se ction C, Siphon Section C, Gravity Section D, and Siphon Section D) are owned by the VWD with shared capacity with the City of Vista and the City of Carlsbad (VWD 2018).

With the expanded production of recycled water at MRF from 2 MGD to 5 MGD, VWD is redu cing the amount of wastewater that flows through its land outfall to the EWPCF. Solids from the MRF are conveyed back to the EWPCF (VWD 2018).

As stated above, the MRF has a capacity of 5.0 MGD with a peak wet weather capacity of 8.0 MGD.

Combined with the 12.10 MGD capacity of the land outfall controlled by VWD, VWD has a combined peak wet weather wastewater collection capacity of 20.10 MGD (12.10 MGD + 8.0 MGD).

According to the water and sewer study technical memorandum prepared for the proposed project, average daily wastewater flow through the land outfall was approximately 7.5 MGD in 2014. This corresponds to a peak wet weather flow of 17.5 MGD, which falls within VWD’s combined peak wet weather collection capacity (VWD 2020).

Collection System Facilities
Sewer Gravity Mains
VWD has approximately 1.35 million feet (255 miles) of gravity sewer mains ranging in size from 4 - inches to 42-inches in diameter (VWD 2018).

Lift Stations
There are currently four wastewater lift stations in operation.

Lift Station 1 is located in the Encina Basin along San Marcos Boulevard. Lift Station 1 is designed to divert wastewater from entering the land outfall by pumping to the MRF. The station includes two grinders, four variable speed pumps, and a chemical feed sy stem. The facility currently operates at a capacity of 3,100 gallons per minute (GPM) (VWD 2018).

The Lake San Marcos Lift Station is located in the Meadowlark Basin and serves the Lake San Marcos community area. This facility serves the natural drainage a reas of Lake San Marcos and must reliably convey all flows from the lake-front community (VWD 2018).

The Questhaven Lift Station is located in the Meadowlark Basin adjacent to the San Elijo Hills Development and is the newest lift station in the VWD service area. The facility was built to serve a small development east of San Elijo Hills and eventually the southeast portion of the District (VWD 2018).

Montiel Lift Station is located in the Encina Basin along State Route 78 just east of Nordahl Road.

The Montiel Lift Station pumps flows via an 1,850 foot, 6 -inch diameter DIP force main in Montiel Road to Nordahl Road where flows are then conveyed via gravity to Lift Station 1. Removal of this pump station may be feasible if tributary flows are diverted to the City of Escondido via a new pipeline under Highway 78 (VWD 2018).

Flow Meters
VWD currently meters its wastewater collection system at 20 locations distributed throughout the collection system. Sewer flow meters provide critical data on wastewater flows a nd help pinpoint sources of inflow and infiltration within individual sewer basins. The flow meters also assist with hydraulic modeling, calibration of the hydraulic model and development of CIP projects. All the VWD flow meters are connected to its SCADA system, which allows VWD to be alerted when high flows or

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depths are being experienced. This allows VWD to determine blockages and avoid sanitary sewer overflows. The flow meters are also being used by VWD to aid in their smoke testing program by assisting in identifying locations of high inflow and infiltration, or “hot -spots.” If the flow meter shows signs of significant inflow, the area of influence or concern can be determined and scheduled for smoke testing. In general, the VWD’s metering program provi des sufficient coverage of the sewer collection system. VWD generally observes a residential - type flow pattern with low flows occurring in the early hours of the day, peak flows occurring in the early morning, average flows occurring in the mid-afternoon and peaking again in the evening. The historical flow meter data was utilized in the VWD sewer model calibration (VWD 2018).

Existing and Future VWD Wastewater Flows
The VWD 2018 Master Plan includes a wastewater system analysis assessing existing and projected wastewater flows, existing and projected capacity and needed capital improvements.

Existing Wastewater Flows
From 2010 through 2014 the District conveyed average annual wastewater flows of approximately

3.42 MGD to the EWPCF (including solids from th e MRF) and 3.65 MGD to the MRF. The total average annual (2010 -2014) wastewater flow amounts to 6.76 MGD. This average annual total is nearly identical (slightly higher) than the 6.71 MGD cited in the previous master plan, indicating that growth has been o ffset by conservation and water use efficiency. The wet weather maximum day flow for the Encina Basin between 2010 and June 2014 occurred during a series of storms culminating on December 22, 2010. This storm event resulted in a flow of 13.92 MGD to the EW PCF (including 0.60 MGD of solids from the MRF) and a peak flow at the MRF of 5.83 MGD. The total wet weather maximum day flow was 19.15 MGD. Table 3.17-4 summarizes the average annual and peak wet weather wastewater flows for VWD (VWD 2018).

Table 3.17-4. Existing (2010-2014) Wastewater Flow Summary Tributary Average Annual Flow
(MGD)
Wet Weather Maximum Day Flow (MGD)
(2010 Storm)
Peroxide Meter 3.42 13.92
Less Solids from Meadowlark (0.32) (0.60)
Subtotal Encina Basins (without
solids) 3.11 13.32
Lift Station 1 & Lake San
Marcos LS 2.74 4.00
Meadowlark Gravity 0.91 1.83
Subtotal Meadowlark Basin 3.65 5.83
Total District 6.76 19.15
Source: VWD 2018 Master Plan, page 7-16
Notes: Average flows are based on District’s January 2010 to June 2014 metered flow data.

Peak Wet Weather based on December 22,2010 storm event and is the peak hour flow during the storm event.

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Lift Station 1 and Lake San Marcos LS flows are combined since they operate together to divert flows to MRF.

Wet Weather Considerations
Peak (instantaneous) flows within a wastewater collection system occur under two general conditions: dry weather and wet weather. Dry weather peak flows are defined as peak instantaneous wastewater flows that occur on a daily basis without the influence of a storm event. Peak wet weather flows are defined as peak instantaneous wastewater flows that occur as a result of inflow and/or infiltration occurring during one or multiple storm events during the rainy season. Inflows include large flows over a short d uration coming from specific point sources (such as illicit connections to the sewer system from storm drains or roof drains). Infiltration includes flows coming from seepage into the sewer system (such as cracked sewer pipes or seepage at pipeline joints) .

Controlling wet weather peaking is important to avoid costly sewer system oversizing (VWD 2018).

Existing (2014) and Future Wastewater Flow Projections
Table 3.17-5 presents the existing and projected future average wastewater flows for the District at 5- year increments from the basis year of 2014 to 2035 and ultimate buildout conditions. These interim flow projections were estimated based upon SANDAG’s growth forecasts for the District (VWD 2018). As shown, VWD’s 2014 average daily wastewater flow was 7.5 MGD. The average annual flow projection for the ultimate condition is 14.4 MGD. This total is greater than the 2008 Master Plan’s ultimate flow projection of 13.3 MGD. This is due primarily to recently approved densification projects within the City of San Marcos. This total represents the maximum potential flow based on allowable land uses and existing flows. While the ultimate flow is potentially higher, continued conservation and water use efficiency would delay reaching ultimate conditions.

Table 3.17-5. Projected Wastewater Flows within VWD Service Area Year Average Annual Flows
(MGD)
Peak Dry Weather Flows
(MGD) (1)
Peak Wet Weather
Flows (MGD) (1)
Existing 2014 7.5 11.7 17.5
2020 8.7 13.2 20.0
2025 9.5 14.2 21.6
2030 9.6 14.4 21.9
2035 9.6 14.4 22.0
Ultimate 14.4 20.2 31.7
Ultimate w/ NTA (2) 15.2 21.2 33.4
Source: VWD 2018 Master Plan, page 7-19
Notes: (1) Peak flows were estimated by applying District Peaking Curves as presented in Chapter 6 of the 2018 Master Plan.
(2) NTA is the Northern Tributary Area, a separate drainage basin located in the northern part of VWD’s service area that drains away from the wastewater collection system. NTA flows were estimated and would need further evaluation if this area is to be connected into VWD/s sewer system.

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VWD Planned System-wide Wastewater Improvements
VWD’s 2018 Master Plan analyzed the existing wastewater system to determine size of pipeline replacements and extensions utilizing a hydraulic model developed by collecting the system’s physical data, estimating existing wastewater flows, and calibrating the model using actual meter data. The 2018 Master Plan does not include developments that were not approved prior to June 30, 2014. As development projects are proposed, the project proponen ts will be required to prepare a study that will, at a minimum, define the location and size of the sewer facilities required to serve the development, including the necessary regional collection, transfer, and treatment infrastructure (VWD 2018).

The 2018 Master Plan describes planned improvements to VWD’s existing wastewater facilities.

Projects are divided into phases of five -year increments through 2036 - Ultimate. According to the water and sewer study technical memorandum prepared for the proposed project, there are existing system deficiencies in pipe segments HB-29 through HB-31 under the peak wet weather flows during ultimate build-out conditions. The 2018 Master Plan identified pipe segments HB -29 through HB-31 for upsizing from 18 -inch and 24 -inch as CIP #SP- 25, a Phase 3 project. Phase 3 projects are planned for construction in the 2026-2030 timeframe (VWD 2020).

Solid Waste
Solid waste disposal in the City is provided by a private franchise hauler, EDCO Waste and Recycling (EDCO), a private wast e collection and recycling company which handles all residential, commercial, and industrial collections within the City. Waste collected by EDCO is hauled to the Escondido Transfer Station where it is then transported to the Sycamore Sanitary Landfill in Santee. Recyclable materials are processed at the Escondido Resource Recovery Transfer Station. The Escondido Transfer Station has a daily capacity of 2,500 tons. Solid waste is consolidated here and then trucked to a landfill for disposal. The site is per mitted to allow operations seven days per week, 24 hours per day (County of San Diego 2008). The Sycamore Sanitary Landfill has a daily permitted throughput of 5,000 tons/day of solid waste (CalRecycle 2019a) with an anticipated closure date of 2054. (County of San Diego 2018).

Electricity and Natural Gas
Electricity and natural gas would be provided by San Diego Gas & Electric (SDG&E). There is an existing 69 -kilovolt (kV) electrical transmission line at the project frontage with E. Barham Drive.

SDG&E also maintains a gas distribution system within E. Barham Drive. If the project utilizes gas utilities, the gas line will be extended to the project site through the same joint trench alignment as electrical, cable and telephone facilities.

3.17.2 Regulatory Setting
Existing federal, state, and local regulations related to water, wastewater, and solid waste that are applicable to the proposed project are summarized below.

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Federal
Clean Water Act
The federal Clean Water Act (CWA) establishes regulatory requirements for potable water supplies including raw and treated water quality criteria. The City of San Marcos is required to monitor water quality and conform to regulatory requirements of the CWA.

Resource Recovery and Conservation Act
The Resource Recovery and Conservation Act Subtitle D focuses on state and local governments as the primary planning, regulating, and implementing entities for the management of non -hazardous solid waste, such as household solid waste and nonhazardous industrial solid was te. Subtitle D provides regulations for the generation, transportation, and treatment, storage, or disposal of hazardous wastes.

State
California Green Building Standards Code (CCR, Title 24, Part 11 – CALGreen) In 2008, the California Building Standards C ommission 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 conservation, and interior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground -up, new construction of commercial, low -rise residential and state -owned buildings and schools and hospitals. The CALGreen 2019 standards became effective on January 1, 2020 (In ternational Code Council [ICC] 2019). The nonresidential mandatory standards require the following measures that relate to utilities and service systems (24 CCR Part 11):
• Mandatory reduction in indoor water usage through installation of separate submeters or metering devices, and compliance with specified flow rates for plumbing fixtures and fittings and faucets and fountains.
• Mandatory reduction in outdoor water usage through compliance with a local water efficient landscaping ordinance or the California D epartment of Water Resources’ Model Water Efficient Landscape Ordinance and installation for recycled water supply systems where available/applicable.
• 65% of construction and demolition waste must be diverted from landfills and 100% of trees, stumps, rocks , and associated vegetation and soils resulting primarily from land clearing shall be reused or recycled.
• Provide readily accessible areas for recycling that serve the entire building. • Mandatory inspections of energy systems to ensure optimal working efficiency. • Inclusion of electric vehicle charging stations or designated spaces capable of supporting future charging stations.

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The CALGreen standards also include voluntary efficiency measures that are provided at two separate tiers and implemented at the dis cretion of local agencies and applicants. These voluntary measures call for indoor and outdoor water use reduction, higher diversion of construction and demolition waste, further improvement in energy requirements, stricter water conservation, Increased p ercentage of recycled content in building materials, increase in permeable paving, cement reduction and cool/solar-reflective roofs.

Assembly Bill 939 and 341
In 1989, Assembly Bill (AB) 939, known as the Integrated Waste Management Act (California Public Resources Code, Section 40000 et seq.), was passed because of the increase in waste stream and the decrease in landfill capacity. The statute established the California Integrated Waste Management Board (CIWBM), 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% by 1995 and 50% by the year 2000.

AB 341 (2011) amended t he California Integrated Waste Management Act of 1989 to include a provision declaring that it is the policy goal of the state that not less than 75% of solid waste generated be source-reduced, recycled, or composted by the year 2020, and annually thereaft er. In addition, AB 341 required the California Department of Resources Recycling and Recovery (CalRecycle) to develop strategies to achieve the state’s policy goal. CalRecycle has conducted multiple workshops and published documents that identify priority strategies that CalRecycle believes would assist the state in reaching the 75% goal by 2020.

Senate Bill 221
Signed into law on October 8, 2001, SB 221 established a process whereby sufficient water supply must be identified and available for new development for any residential development of 500 homes or more, or, in the case wherein a water supplier has fewer than 5,000 service connections or the proposed development would increase the number of connections by at least 10 percent, unless there is proof o f adequate water over at least the next 20 years, including long periods of drought.

Due to the size of the proposed project, a water supply assessment and verification report pursuant to SB 221 and SB 610, described below, are not required.

Senate Bill 610
Signed into law October 9, 2001, SB 610 resulted in amendments to the Public Resources Code and the Water Code. Revising provisions established by SB 901, SB 610 requires that the planning agency determine whether a proposed project, subject to CEQA, mee ts any of the thresholds for requiring preparation of a water supply assessment. Specifically, if the project is a proposed development of more than 500 dwelling units (or equivalent), the planning agency must then request that the urban water supplier pre pare a water supply assessment. The assessment would include the identification of existing water entitlements, water rights, or water service contracts relevant to the water supply identified for the proposed project, and the amount of water received purs uant to such entitlements, rights, or contracts. Due to the size of the proposed project, a water supply assessment pursuant to SB 610 is not required.

Urban Water Management Plans
Urban water purveyors are required to prepare and update a UWMP every 5 yea rs. The UWMPs address water supply, treatment, reclamation, and water conservation, and contain a water shortage

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contingency plan. Local UWMPs, such as those prepared by RDDMWD and other water districts, are supplemental to the regional plans prepared by M WD. The Water Conservation Bill of 2009 (SBX7 -7) requires each urban retail water supplier to develop an urban water use target and an interim urban water use target. Notably, SBX7 -7 authorizes urban retail water suppliers to determine and report progress toward achieving these targets on an individual agency basis or pursuant to a regional alliance as provided in California Water Code (CWC) Section 10608.28(a). As described above, water service to the site is provided by RDDMWD. In accordance with this reg ulation, the RDDMWD prepared and their Board of Directors adopted its 2015 UWMP in 2016. RDDMWD’s UWMP includes estimated future water demands until 2040, using updated population projections and a conservative assumption that, in the absence of mandatory water conservation measures, per-capita consumption could rebound to its 2020 target value. Demands provided in RDDMWD’s UWMP have been coordinated with SDWCA, RDDMWD’s wholesale supplier. 2018 Making Water Conservation a Way of Life Laws
In 2018, two laws were passed that built on California’s ongoing efforts to make water conservation a way of life. They emphasized efficiency and stretching water supplies in cities and farms. Senate Bill 606 (Hertzberg) and Assembly Bill 1668 (Friedman) serve as a roa dmap for Californians to plan for dry conditions, and to work together for clean, reliable water supplies now and in the future.

In addition to water conservation targets, the bills outline certain roles and actions to be carried out by the California Depa rtment of Water Resources, the State Water Resources Control Board (State Water Board), and water suppliers. Future milestones include (DWR 2021):
• Beginning in November 2023, urban water suppliers will annually calculate a water efficiency standard based on the indoor and outdoor water needs of its service area. • The indoor water use standard is one of several metrics used to calculate the overall efficiency standard for a service area. The laws establish a standard of 55 gallons per person per day until Jan uary 2025, and then to 50 gallons per person per day in 2030. However, those targets are aggregated across the population in a service area and are not intended as enforceable standards for individuals.
• The State Water Board may initiate enforcement action s in 2025 against urban water suppliers if they fail to meet the standards. The standards are scheduled to go into effect in 2023 (DWR 2021).

Local
San Diego County Integrated Waste Management Plan
Pursuant to the IWMA, the Countywide Integrated Waste Mana gement Plan for San Diego County describes the goals, policies, and objectives of the county for coordinating efforts to divert, market, and dispose of solid waste during the planning period through the year 2017. Countywide policies for reducing waste and implementing the programs are identified in the individual jurisdiction SRREs and HHWEs and are intended to reduce costs, streamline administration of programs, and encourage a coordinated and planned approach to integrated waste management.

To avoid duplication of effort, all of the jurisdictions in the county participate in the San Diego County Integrated Waste Management Local Task Force (LTF). The LTF coordinates mandated planning, oversees implementation of new or countywide integrated waste management programs, and carries

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out an active legislative program. Regulatory reform, changes to state diversion requirements, and reduction of the costs of compliance are considered by the LTF, as well as other solid waste issues of regional or countywide concerns.

City of San Marcos Municipal Code
Title 8, Health and Sanitation
SMMC Title 8 contains regulations and provisions on sewers and sewage disposal plants, sewer connections, septic tanks, waste matter, garbage and refuse collection, and other matters concerning sanitation. Chapter 14.15 contains regulations concerning storm water management and discharge control. Chapter 14.24 contains regulations concerning underground utility facilities. Title 19 regulates subdivision requirements, including the installation of utility facilities and connections and payment or fees for such installations.

Title 20, Chapter 20.330 Water Efficient Landscaping Ordinance (WELO) The provisions of Title 20 of the San Marcos Municipal Code are referred to as the Zoning Ordinance.

The City of San Marcos Municipal Code Title 20, Section 20.330, details the City’s Water Efficient Landscape (WELO). In accordance with State law, SMMC Chapter 20.330 establishes specific standards for landscape and irrigation design and inst allation to ensure beneficial, efficient, and responsible use of water resources within the City.

City of San Marcos General Plan
The General Plan Conservation and Open Space Element includes one goal regarding water supply that is applicable to the proposed project:
• Goal COS -5: Reduce water consumption and ensure reliable water supply through water efficiency, conservation, capture, and reuse.
• The General Plan Conservation and Open Space Element also includes one goal and associated policy regarding solid waste that is applicable to the proposed project:
• Goal COS -10: Establish and maintain an innovative, sustainable solid waste collection, recycling, and disposal delivery system for present and future generations. o Policy COS-10.1: Promote the curbside recycling program to divert residential refuse from the landfills.

The General Plan Land Use and Community Design Element identifies the following goals and policies regarding utilities and services systems that are applicable to the proposed project:
• 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 developme nt timing that is guided by the adequacy of existing and/or expandable infrastructure, services, and facilities.

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• 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.
o Policy LU-13.1: Work closely with local and regional water providers to ensure high quality water supplies are available for the community.
o Policy LU -13.2: Actively promote water conservation programs aimed at reducing demand.
o Policy LU -13.3: Encourage exploration and use of deep underground wells to reduce reliance on treatable water.
• Goal LU -14: Wastewater: Ensure an adequate wastewater system for existing and future development.
o Policy LU -14.1: Work closely with local service providers to ensure an adequate wastewater system for existing and future development is in place. o Policy LU -14.2: Ensure development approval is directly tied to commitments for the construction or improvement of primary water, wastewater, and circulation systems.

The General Plan Land Use and Community Design Element also identifies the following goal and policies regarding solid waste that are applicable to the proposed project:
• Goal LU-16: Solid waste: reduce the amount of waste material entering regional landfills with an efficient and innovative waste management program.
o Policy LU-16.1: Work closely with local service providers to ensure adequate solid waste disposal, collection, and recycling services.
o 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 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 -5 in Section 3.10, the project is consistent with the applicable goals and policies.

3.17.3 Thresholds of Significance
The determination of significance for utilities and service s ystems is based on the Appendix G of the CEQA Guidelines. Utilities and services system impacts would be significant if the proposed project meets any of the following thresholds.
• Threshold #1: Require or result in the relocation of reconstruction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
• Threshold #2 - Have sufficient water suppli es available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years?

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• Threshold #3 - Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adeq uate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? • Threshold #4 – Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair t he attainment of solid waste reduction goals?
• Threshold #5 – Comply with federal, state, and local management and reduction statues and regulations related to solid waste?

3.17.4 Project Impact Analysis
As identified above, the project site is located within the RDDMWD water service area and within the VWD sewer service area.

Threshold #1: Require or result in the relocation of reconstruction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? Water
There is no existing water demand on the project site, since it is not developed. The proposed project would include development of 151 multi-family residential units. As such, the proposed project would increase the intensity of uses on the project site, resulting in increased water use. CalEEMod default water usage rates were used to estimate the anticipated water demand of the proposed project.

Based on the CalEEMod generation rates, water use per year would be 9.8 million gallons (Ldn 2021, Appendix H.1). The project site lies within RDDMWD’s Improvement District 1 water service area and will be served by RDDMWD for potable water and for water for fi re protection. RDDMWD has confirmed their ability to serve the project and has no environmental concerns (RDDMWD 2021, Appendix N.2).

RDDMWD currently imports all of its potable, treated water from SDCWA, particularly from the SDCQWA First Aqueduct, and al l of its recycled water from the City of Escondido’s HARRF. As such, RDDMWD does not currently have water treatment facilities. As discussed in its Water Master Plan, RDDMWD would seek to offset increases in potable water demand by expanding its recycled w ater distribution system or developing local water supplies, which are projected to increase from 280 AFY in 2020 to 900 AFY in 2035 (RDDMWD 2014). As such, the proposed project would not result in the construction of new water treatment facilities.

RDDMWD will extend the existing 8 -inch waterline that currently terminates within the Mira Lago community, through a portion of the project site to loop and connect to the existing 10 -inch VWD line in E. Barham Drive. Once operational, the project would connect into this new on -site line.

RDDMWD’s connection to the VWD waterline also provides a secondary water source if water service from RDDMWD is interrupted.

Water lines within the project site will consist of an 8 -inch fire main and a 4 -inch domestic main water line. Both lines will circulate beneath the main driveways throughout the project site as shown on Figure 2-12. The 8 -inch fire main will run under Private Driveway’s “A”, “B”, and “C”. The 4 -inch domestic water lines will loop through alley’s “A,” through “K” teeing off from driveway’s “A”, “B” and “C.” The 8-inch fire main and 6” domestic water lines will connect to the existing 10 -inch and 8-inch

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public water mains underneath E. Barham Drive. These improvements would occur within the project footprint, and environmental clearance for these impacts is covered under this EIR. For these reasons, the proposed project would not require or result in the relocation or construction of new water facilities. Impacts to water services would be
less than significant.

Wastewater
The analysis of wastewater infrastructure is based upon the water and sewer study technical memorandum prepared by VWD (VWD 2020). This study is included in Appendix N.1 of this EIR.

As described above, the proposed project would include development of 151 multi- family residential units. The project’s 2008 General Plan land use designation was Low Density Residential (Residential 4 -8 dwelling unit per acre [du/ac]). VWDs 2018 Master Plan based its ultimate wastewater generation pla nning on this approved land use and assumed the project site would generate approximately 13,000 gallons per day (GPD). The project is proposing a density increase with the proposed 151 multi -family residential units (Residential 15 -20 du/ac). The sewer st udy prepared for the proposed project estimated that the proposed project would generate approximately 33,000 gallons of wastewater per day. This is an increase in the projected average wastewater generation by 20,000 GPD (VWD 2020).

Wastewater Collection System Analysis Model Results
VWD modeled several wastewater scenarios to identify system impacts that may be created by the proposed sewer generation, and to recommend any improvements required to provide service to the project. Modeling focused not only on the sewer collection infrastructure in the direct vicinity of the project site, but also on all downstream infrastructure from the development to Lift Station No. 1 on San Marcos Boulevard that would be impacted by the project flows.

The modeling result s showed that there are existing system deficiencies in pipe segments HB -29 through HB -31 under the peak wet weather flows during ultimate build -out conditions. The wastewater flow from the proposed project would increase those deficiencies. However, the VWD 2018 Master Plan identified pipe segments HB -29 through HB-31 for upsizing from 18 -inch and 24- inch as CIP #SP- 25, a Phase 3 project. Phase 3 projects are planned for construction in the 2026 - 2030 timeframe. Per VWD, the projects included in the Maste r Plan will address and accommodate the pipeline deficiencies. Wastewater Capital Facility Fees paid by the project will be used towards the construction of these pipelines (VWD 2020).

Wastewater Lift Station Analysis
Per the VWD sewer study, the project is not located in a sewer shed that is served by a lift station.

Therefore, no lift station upgrades would be required (VWD 2020).

Parallel Land Outfall Analysis.

Per the sewer study prepared for the project, VWD has a combined peak wet weather wastewater collection capacity of 20.10 MGD. VWD’s 2014 average daily wastewater flow through the land outfall was 7.5 MGD. This corresponds to a peak wet weather flow of 17.5 MGD, which falls within VWD’s combined peak wet weather collection capacity.

The 2018 Maste r Plan estimated that, under approved land uses, VWD has an ultimate build -out average dry weather flow of 14.4 MGD. This corresponds to a peak wet weather flow of 31.7 MGD, which exceeds VWD’s combined peak wet weather collection capacity. To accommodate additional

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wastewater flows from planned development, the 2018 Water Plan recommended conveyance of peak flows to the EWPCF through a parallel land outfall.

The project proposes to generate 20,000 GPD of additional average wastewater flow that was not accounted for in the Land Outfall’s capacity studied in the 2018 Master Plan. However, per the sewer study prepared for the proposed project, VWD finds that outfall capacity is currently available to serve the project’s proposed wastewater generation. Wastewa ter Capital Facility Fees paid by the project will be used toward design and construction of a parallel land outfall to be sized to accommodate ultimate build-out wastewater flows.

Wastewater Treatment Facility Analysis
Because VWD utilizes both MRF and EW PCF for wastewater treatment, wastewater generated by the proposed project would be treated at either facility. MRF has liquids treatment capacity of up to 5 MGD with a peak wet weather capacity of 8 MGD. MRF does not have solids treatment capacity, and therefore all solids are treated at the EWPCF. The EWPCF is a regional facility with treatment capacity of up to 40.51 MGD (VWD 2020).

Solids Treatment Capacity
VWD currently owns 10.47 MGD of solids treatment capacity at EWPCF. VWD’s 2014 average daily wastewater flow was 7.5 MGD. Therefore, VWD concludes that adequate solids treatment capacity exists at this time to serve the project (VWD 2020). However, the ultimate average wastewater flow identified in the 2018 Master Plan is 14.4 MGD, resulting in a projected solids treatment capacity deficiency of 3.93 MGD (VWD 2020). Wastewater flows from the proposed project would contribute to that deficiency
Liquid Treatment Capacity
VWD currently owns 7.67 MGD of liquids treatment capacity at the EWPCF in addit ion to the liquids treatment capacity of 5.0 MGD at MRF for a total of 12.67 MGD of liquids treatment capacity. VWD’s 2014 average daily wastewater flow was 7.5 MGD. Therefore, VWD concludes that adequate solids treatment capacity exists at this time to se rve the project (VWD 2020). However, the ultimate average wastewater flow identified in the 2018 Master Plan is 14.4 MGD resulting in a projected liquids treatment capacity deficiency of 1.73 MGD (VWD 2020). Wastewater flows from the proposed project would contribute to that deficiency.

Ocean Disposal Capacity
VWD currently owns 10.47 MGD of ocean disposal capacity at the EWPCF. VWD’s 2014 average daily wastewater flow was 7.5 MGD. Therefore, VWD concludes that adequate ocean disposal capacity exists at this time to serve the project (VWD 2020). The ultimate average wastewater flow identified in the 2018 Master Plan is 14.4 MGD resulting in an ocean disposal deficiency of 3.93 MG (VWD 2020). Wastewater flows from the proposed project would contribute to that deficiency.

Wastewater Summary
Preliminary sewer design for the project concluded a 6 -inch PVC sewer main will be needed to adequately service individual homes and community areas discharging wastewater. Pipes will be located underneath the internal p rivate driveways and alleys. The internal sewer main will connect to the existing VWD 8 -inch sewer line located beneath E. Barham Drive via the primary project driveway.

Figure 2 -13 presents the sewer concept. These improvements would occur within the project footprint, and environmental clearance for these impacts is covered under this EIR.

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As discussed above, the project is expected to increase wastewater flows by 20,000 GPD than what was anticipated for the project site in the 2018 Master Plan. This would lead to an increase of 20,000 GPD in solids handling, liquids handling and ocean disposal capacity requirements at the EWPCF and an increase of 20,000 GPD in the parallel land outfall’s capacity requirement. VWD has determined that adequate wast ewater treatment and disposal capacity exists for the proposed project at this time. As discussed in the sewer study (Appendix N.1), the project applicant would be required to pay all applicable Wastewater Capital Facility fees in effect at the time servi ce is committed in accordance with District rules and regulations, and acceptance by VWD of all wastewater facilities required to be constructed for service to the project.

Under these conditions, and with consideration that proposed infrastructure is anal yzed throughout this EIR, the project would not exceed current capacities of the wastewater treatment system and would not significantly impact existing wastewater treatment systems. Therefore, the proposed project would not require or result in the reloca tion or construction of new wastewater facilities.

Impacts to water services would be less than significant.

Stormwater Drainage
As discussed in Section 3.9.4 (Hydrology and Water Quality), the proposed project would result in an increase of impervious areas to the site. If not carefully planned for, increased runoff from impervious surface can cause alterations to drainage courses. However, the proposed project has been designed to carefully handle runoff and to meet regulatory requirements t o ensure that post - development runoff quantities and rates are similar to or less than the pre -development condition.

Although the project would include new storm water infrastructure (biofiltration basin) to support project facilities, the proposed infras tructure has been accounted for and analyzed throughout this EIR. The project would not contribute a substantial amount of new stormwater runoff relative to existing conditions, and impacts are determined to be less than significant. Please refer to Section

3.9, Hydrology and Water Quality, for additional discussion related to drainage.

Electric Power
As discussed in Section 3.5.4, during construction, the amount of electricity used would be minimal because typical demand stems from the use of several const ruction trailers that are used by managerial staff during the hours of construction activities in addition to electrically powered hand tools. As discussed in Section 2.2.2.6, the proposed project would connect to the existing underground 69KV line at the project frontage with E. Barham Drive. This connection is accounted for in the project impact analysis and mitigation measures for the proposed project as a whole throughout this EIR.

During operations, proposed project is estimated to have a total electrical demand of approximately 767,483 kWh per year, which was estimated using CalEEMod (LDN 2021, Appendix H.1). The proposed project includes various on -site features and measures to reduce the proposed project’s energy consumption. Further, the proposed p roject 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 (California Energy Commission [CEC] 2018) bec ause the 2019 standards require solar photovoltaic systems for new homes. 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.

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Homes built in 2020 and beyond will be highly efficient and include solar photovoltaic generation to meet the home’s expected annual electric needs (CEC 2018). The project would install smart meters and programmable thermostats, cool roof materials, and ef ficient lighting in all buildings and light control systems, where practical, which would reduce lighting energy by 20%. Thus, the proposed project would not require or result in the relocation or construction of expanded electric power facilities. Impacts would be
less than significant.

Natural Gas
SDG&E maintains a gas distribution system within E. Barham Drive. If the project utilizes gas utilities, the gas line will be extended to the project site through the same joint trench alignment as electrical, cable and telephone facilities.

As discussed in Section 3.5.4, natural gas is not anticipated to be required during construction of the proposed project. Fuels used for construction would primarily consist of diesel and gasoline, which are discussed under the subsection Petroleum. Any minor amounts of natural gas that may be consumed as a result of proposed project construction would be temporary and negligible and would not have an adverse effect on the environment. As far as project operation, no natural gas will be used. Further, the proposed project is subject to statewide mandatory energy requirements as outlined in Title 24, Part 6, of the California Code of Regulations. Prior to project approval, the applicant would ensure that the proposed project wo uld meet Title 24 requirements applicable at that time, as required by state regulations through their plan review process. Thus, the proposed project would not require or result in the relocation or construction of new or expanded natural gas facilities. Impacts would be
less than significant.

Telecommunications
Communications systems for telephones, computers, and cable television are serviced by utility providers such as AT&T, Cox, Spectrum (formerly Time Warner), and other independent cable companies. However, no specific systems upgrades are proposed with this project, and the location and extent of future facilities is not known at this time. Thus, the project would not result in physical impacts associated with the construction of communications syste ms. Impacts would be less than
significant.

Threshold #2: Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? As discussed, the proposed project would be se rved by Rincon del Diablo Municipal Water District.

RDDMWD anticipates the demand of future development through their master planning process.

With development of MWD, SDCWA and RDDMWD’s supplies, along with compliance with the Water Conservation Bill of 2 009, no water shortages are anticipated within RDDMWD’s service area in single or multiple dry years through 2040 (RDDMWD 2016). According to RDDMWD’s UWMP, RDDMWD would have sufficient supplies available to serve its area during a normal, single dry, and multiple dry years.

SDCWA has invested in carryover storage supplies to assist in achieving reliability in dry years.

SDCWA’s carryover supplies include regional surface water storage and groundwater storage in the California Central Valley. In years where unanticipated shortages are experienced after expenditure of SDCWA carryover supplies, RDDMWD would respond to allocations in water demands as mandated by Metropolitan and/or SDCWA. Additionally, RDDMWD would implement its Drought Response Plan accordingly (RDDMWD 2016). The Drought Response Plan, which contains four-levels

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of drought response, provides a response strategy to ensure that, in a time of shortage, available water resources are put to the maximum beneficial use.

In 2015, RDDMWD’s actual water demand and supply was 8,882 acre -feet per year (RDDMWD 2016). It should be noted that water demands in 2015 were substantially less than those projected in the 2010 UWMP due to mandatory water use restrictions due to emergency drought regulations, increases water prices, and conversion of an SDG&E power plant to recycled water (RDDMWD 2016). As a comparison, actual water demand in 2010 was 9,380 acre -feet per year (RDDMWD 2016).

RDDMWD has estimated that future demands will increase at the same rate as the SANDAG - projected population growth rate for RDDMWD’s service area. RDDMWD’s UWMP utilizes SANDAG growth projections for its project planning. As the project is proposing a density increase, there would be a corresponding increase in water demand that would not have been included in the UWMP and Master Plan. The reliable quantities of projected water demands for Years 2025 and 2030 are 8,009 acre -feet per year and 8,229 acre -feet per year, respectively (RDDMWD 2016). CalEEMod assumed 9.8 million gallons of water per year or approximately 30 acre -feet per year. The estimated water consumption of the proposed project is approximately 0.37% of RDDMWD’s projected water demand for 2025 and 2030.

RDDMWD has a goal to supply the growth in demand arising from new d evelopment through a combination of recycled water and other possible new local sources of supply. RDDMWD anticipates adding this new supply in increments, reaching a cumulative total of 900 AF/YR by 2035. Per RDDMWD’s UWMP, RDDMWD will investigate a varie ty of options for providing new supply, including additional recycled water development, groundwater, and indirect or direct potable reuse. Since 2016, ID 1 water supplies are augmented from time -to-time with water originating from the Twin Oaks Valley Water Treatment Plant (TOVWTP). TOVWTP water is a blend of treated SDCWA water and desalinated sea water from the Claude “Bud” Lewis Carlsbad Desalination Plant (Lewis Desal Plant).

Originating from the Carlsbad Agua Hedionda Lagoon, the desalinated water is a superior quality water – free of salt as well as biological and organic compounds (RDDMWD 2020).

RDDMWD will construct new storage and transmission mains as the system expands and new development service is required. The project applicant will pay the Wa ter Capital Facility (Capacity) Fees that are in effect at the time of building pursuant to Ordinance NO. 21-98.2.

RDDMWD’s projected water supplies are 12,009 and 12,229 acre -feet per year, which reflect RDDMWD’s goal to supply the growth in demand arisin g from new development through a combination of increased recycled water usage and other potential local supply projects (RDDMWD 2016).

Considering existing and estimated future water demand, as described in RDDMWD’s UWMP, it is reasonably foreseeable that RDDMWD would have sufficient supplies to serve the proposed project and reasonably foreseeable future development during normal, dry, and multiple dry years. Further, the project site would be redeveloped in compliance with the California Green Building C ode (which implements water efficiency standards for appliances and fixtures), which would further reduce project water usage in combination with RDDMWD’s ongoing water conservation practices. For these reasons, impacts would be considered
less than significant.

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Threshold #3: Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
As discussed under Threshold #1, above, the project site is within VWD’s service area, which would provide service to the project. Due to proposed densification, the project is expected to increase wastewater flows by 20,000 GPD over what was assumed in the 2018 Mast er Plan. This would lead to an increase of 20,000 GPD in solids handling, liquids handling and ocean disposal capacity requirements at the EWPCF and an increase of 20,000 GPD in the parallel land outfall’s capacity requirement. VWD has determined that adequate wastewater treatment and disposal capacity exists for the proposed project at this time. As discussed in the sewer study (Appendix N.1), the project applicant would be required to pay all applicable Wastewater Capital Facility fees in effect at the time service is committed in accordance with District rules and regulations, and acceptance by VWD of all wastewater facilities required to be constructed for service to the project. Under these conditions, VWD has determined that adequate wastewater treatm ent and disposal capacity exists for the proposed project at this time (VWD 2020). Because the project would not exceed current capacities of the wastewater treatment system, impacts would be
less than significant.

Threshold #4: Generate solid waste in exc ess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? Construction of the proposed project would result in the generation of solid waste such as scrap lumber, concrete, residual wastes, packing materials, and plastics. The City works with EDCO to promote its construction and demolition material waste removal and recycling program.

Operation of the proposed project would represent an increase in intensity of u ses on the project site, which would likely be associated with increased generation of solid waste. The anticipated solid waste generation from the proposed project was estimated using CalEEMod, Version 2016.3.2, which estimated that the proposed project w ould generate approximately 69.5 tons of solid waste per year (Ldn 2021, Appendix H.1). This does not consider any waste diversion through recycling.

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 ( CalRecycle 2019b). Thus, the City is exceeding their current targets for diversion.

Solid waste generated by the proposed project would be collected and transported to the of Sycamore Sanitary Landfill by EDCO. The Sycamore Sanitary Landfill is owned by t he City of San Diego and operated by Allied Waste Industries, Inc. According to CalRecycle, the facility has a daily permitted capacity of 5,000 tons per day for solid waste (CalRecycle 2019a) with an anticipated closure date of 2054 (County of San Diego 2 018). As of August 2017, remaining capacity was 110,000,000 cy or approximately 86 million tons (County of San Diego 2018).

Solid waste generated by the proposed project during operation would be approximately 380 pounds per day, or 0.19 tons per day, assu ming no diversion. However, the proposed project would be required to comply with AB 341, which requires a 75 percent diversion rate by 2020. As such, assuming a 75 percent diversion rate, solid waste would be reduced to 95 pounds per day, or

0.0475 tons p er day, which would consist of 0.00095% of the landfill’s daily capacity. Thus, the project would contribute a minimal amount of solid waste to Sycamore Sanitary Landfill’s daily permitted capacity. As such, the proposed project’s solid waste generation ca n be accommodated at the landfill. The project would not generate solid waste in excess of state or local standards, or in

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excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. Impacts would be less than significant.

Threshold #5: Comply with federal, state, and local management and reduction statues and regulations related to solid waste?
The proposed project would comply with all federal, state, and local statues and regulations regarding solid waste. More specifically, the proposed project would comply with AB 341, which requires a 75 percent diversion rate by 2020. All solid waste facilities, including landfills, require solid waste facility permits to operate. In San Diego County, Public Resources Code (Sections 44001- 44018) and California Code of Regulations Title 27, Division 2, Subdivision 1, Chapter 4 (Section 21440 et seq.) authori zes the County Department of Environmental Health, Local Enforcement Agency to issue solid waste facility permits. Sycamore Sanitary Landfill is a permitted facility and EDCO is a licensed hauler. As such, the project would comply with existing regulations related to solid waste disposal and would not violate federal, state, or local management and reduction statutes and regulations related to solid waste. Impacts would be
less than significant.

3.17.5 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 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. For purposes of assessing the proposed project’s cumulative impact with respect to utilities and services systems, the cumulative analysis is based upon a combined list and plan project approach.

Water
Some of the cumulative projects included in Table 2-3 are within RDDMWD’s service area for potable water service and would contribute to the cumulative demand for water supply and water infrastructure. However, R DDMWD anticipates the demand of future development through their master planning process. According to RDDMWD’s UWMP, with development of MWD, SDCWA and RDDMWD’s supplies, along with compliance with the Water Conservation Bill of 2009, no water shortages a re anticipated within RDDMWD’s service area in single of multiple dry years through 2040. Not all cumulative projects included in Table 2 -3 fall into the RDDMWD’s service area; those that do not would be served by neighboring districts.

As described in Section 3.17.4, above, the proposed project would result in less than significant impacts to water supply services. RDDMWD has indicated there is sufficient water storage capacity to serve the project (RDDMWD 2021). RDDMWD has determined that with supplies pr ovided by SDCWA, and compliance with the Water Conservation Bill of 2009, no water shortages would occur in a normal year through 2040 (RDDMWD 2016). Further, according to RDDMWD’s Water Master Plan, future water system and reliability projects over the ne xt five to ten years will primarily occur within the Harmony Grove Village development, a residential development within the County, and development to the immediate north and south of this cumulative project. RDDMWD will construct new storage and transmis sion mains as the system expands and new development will be served, which is an already approved and separate project. These expansions would also strengthen the

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reliability of existing water systems to access available water storage, enhance fire flow capabilities, and provide increased redundancy. RDDMWD plans to continue its dependence on SDCWA for potable water supply, and the City of Escondido for recycled water. However, RDDMWD would seek to offset increases in potable water demand by expanding its recycled water distribution system or developing local water supplies, which are projected to increase from 280 AFY in 2020 to 900 AFY in 2035 (RDDMWD 2014). Other cumulative projects that are consistent with the land use assumptions made in RDDMWD’s UWMP would have already been accounted for in demand projections. Projects that are inconsistent with the land use assumptions made in RDDMWD’s UWMP would also be subject to CEQA and required to include water supply assessments to demonstrate adequate supply for development. Further, related projects would be required to show that adequate infrastructure exists to serve the related projects and mitigate any potential impacts to water infrastructure caused by the project. All projects would be required to pay app licable Capital Facility Fees to RDDMWD, required to go towards infrastructure improvements. Thus, cumulative impacts to water services would be
less than significant.

Wastewater
Cumulative projects that are within the VWD service area for wastewater services would contribute to the cumulative demand for wastewater services. VWD anticipates the demand of future development through their master planning process. Cumulative projects that are consistent with the land use assumptions made in VWD’s Master Plan would have already had their demand accounted for.

As discussed in Section 3.17.4, above, VWD has sufficient capacity to account for the proposed project’s increase in estimated wastewater generation rate. 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.

The cumulative projects that result in an increase in density or deve lopment over what was accounted for in VWD’s Master Plan would further exacerbate these deficiencies. Per VWD, payment of Wastewater Capital Facility fees would go toward projects identified with their 2018 Master Plan including upsizing applicable pipelines, and design and construction of a parallel land outfall (VWD 2020). The project applicant for the proposed project and for cumulative projects would be required to pay all applicable Wastewater Capital Facility fees in effect at the time service is committed in accordance with District rules and regulations, and acceptance by VWD of all wastewater facilities required to be constructed for service to the project. Thus, with payment of all applicable Wastewater Capital Facility fees to VWD, cumulative impacts to wastewater treatment facilities would be
less than significant.

Solid Waste
Future development projects would generate solid waste to be disposed of at the Sycamore Sanitary Landfill. According to CalRecycle, the facility has a daily permitted capacity of 5,000 tons/day for solid waste. As of August 2017, remaining capacity was 110,000,000 cy or approximately 86 million tons with an anticipated closure date of 2054 (County of San Diego 2018). Further, there are five other landfills in the County. This includes Borrego Landfill, with a remaining capacity of 111,504 cy and a closure date of 2046; Miramar Landfill, with a remaining capacity of 13,327,508 cy and a closure date of 2030); Otay Landfill, with a remaining capacity of 21,194,008 cy and closure date of 2030, and two Us Marine Corps landfills – Las Pulgas and San Onofre, with remaining capacities of 9,503,985 and 1,064,500 cy and 2059 and 2045 closure dates respectively (County of San Diego 2018). Thus, there is adequate capacity throughout the County to serve future development projects,

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including those identified on the cumulative project list (Table 2 -3). Cumulative impacts for solid waste would be less than significant.

3.17.6 Mitigation Measures
Impacts to utilities and service systems would be less than significant. Thus, no mitigation is required.

3.17.7 Conclusion
Development of the proposed project would result in an incremental increase in the need for water, wastewater, stormwater, and solid waste services. However, as outlined in the project imp act analysis above, Section 3.17.4, it is determined that water, wastewater, stormwater, and solid waste services would be adequate and
project- and cumulative -level impacts would be less than significant.

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4.0 Alternatives

4.1 Introduction to Alternatives
Section 15126.6 of the California Environmental Quality Act (CEQA) Guidelines states that the Environmental Impact Report (EIR) shall “describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project and evaluate the comparative merits of the alternatives.”
The range of alternatives evaluated in an EIR is governed by the “rule of reason” that requires the EIR set forth only those alternatives necessary to permit a reasoned choice. An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose implementation is remote and speculative [Section 15126.6(a) of the CEQA Guidelines].

In developing the alternatives to be addressed in this EIR, the potential alternatives were evaluated in terms of their ability to meet the basic objectives of the project, while reducing or avoiding the environmental impacts of the project identified in Section 3.0, Environmental Analysis, of the EIR.

In determining what alternatives should be considered in the EIR, it is important to acknowl edge the objectives of the project, the project’s significant effects, and unique project considerations. These factors are crucial to the development of alternatives that meet the criteria specified in Section 15126.6(a). Although, as noted above, EIRs mu st contain a discussion of “potentially feasible” alternatives, the ultimate determination as to whether an alternative is feasible or infeasible is made by the lead agency’s decision ‐making body, the San Marcos City Council (see PRC Section 21081[a] [3].)

4.2 Project Objectives
The following objectives of the Hallmark -Barham Specific Plan describe the purpose of the proposed project and provide a basis for identification of a range of reasonable alternatives evaluated in this EIR:
• 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;
• To the extent possible given the site constraints, maximize the opportunity to provide medium-density housing for the City of San Marcos in the 12.1 -15.0 dwelling unit density range which comparable to other medium -density housing developments near the Specific Plan Area.
• 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 na ture 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;

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• Design a safe and efficient circulation system that adequately s upports 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; • 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.

4.3 Project Alternatives Considered in This EIR

4.3.1 Description of Alternative
The following alternatives are under consideration for this project:
• No Project/No Development Alternative (Section 4.3.3) • No Project/ Existing Land Use Designation Alternative (Section 4.3.4) • Reduced Density Alternative (Section 4.3.5)
• Reduced Footprint Alternative (Section 4.3.6)
Alternatives considered and removed from further consideration are summarized in Section 4.4.

4.3.2 Summary of Impacts
Project- and cumulative -level impacts associated with implementation of the proposed project are evaluated in Sections 3.1 through 3.17 of this Draft EIR. As identified in Table 1 -1, in Chapter 1 (Summary), construction and/or operation of the proposed project would have the potential to cause the following significant but mitigable environmental impacts:
• Impact BIO-1: Potential to impact avian species protected under the Migratory Bird Treaty Act if t ree removal, vegetation removal, or other construction activities occur during the nesting season.
• Impact BIO -2: The project will directly impact 0.61 acres of Diegan coastal sage scrub ,

0.03 acres of Diegan coastal sage scrub – Baccharis dominated, and 9.50 acres of non - native grassland.
• Impact BIO -3: Potential for indirect impacts to sensitive habitats during project construction.
• Impact BIO-4: Potential for indirect impacts to sensitive habitats during project operation. • Impact CR-1a: Due to grading and ground disturbing activities, the project has the potential to impact unidentified archeological resources on the project site.

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• Impact CR -1b: Due to grading and ground disturbing activities, the project has the potential to impact unidentified historical resources underneath the project site. • Impact CR-2: There is a potential for project construction activities to disturb previously unidentified human remains on the project site.
• Impact GEO -1: Project grading may result in disturba nce of previously unknown paleontological resource.
• Impact LU -2a and LU -3a: 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 202 5 and Horizon Year 2050 With Project condition. The significant effect is only for the outbound left-turn. • Impact LU -2b and LU -3b: 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 202 5 and Horizon Year 2050 With Project condition. The significant effect is only for the outbound left-turn. • Impact N-1: Depending on the staging location of a rock drill, noise levels may exceed the 75 dBA exterior noise threshold.
• 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.
• 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 Nois e Element 65 dBA exterior noise threshold.
• 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.

Further, construction and/or operation of the proposed project would have the potential to cause the following significant and unavoidable environmental impacts:
• 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.
• 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.
• Impact TR -2: The project’s per capita VMT is 17.07, which exceeds the threshold of 14.96 VMT per capita.

4.3.3 No Project/No Development Alternative
Under the No Project/No Development Alternative, the proposed project would not be implemented, and the project site would remain undeveloped and in its current condition . No grading or

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construction would occur on the project site under this alternativ e. The project site is currently undeveloped and supports the following vegetation communities/land covers: non -native grassland with smaller areas of Diegan coastal sage scrub, Diegan coastal sage scrub – Baccharis dominated, developed, disturbed, ornamen tal and ruderal vegetation. Habitat on the project site would not be impacted under this alternative.

4.3.3.1 Comparison of the Effects of the No Project/No Development Alternative to the Proposed Project
Aesthetics
Under this alternative the project site would re main in its current condition and the visual character of the site would not change. The project site is currently vacant . Vegetation communities on the project site include non -native grassland with smaller areas of Diegan coastal sage scrub, Diegan coastal sage scrub – Baccharis dominated, developed, disturbed, ornamental and ruderal vegetation. The project site slopes generally from higher elevations (710 feet a bove mean sea level [amsl]) in the southeast to lower elevations (650 amsl) in the northwest o f the site. No grading or landform modification would occur under this alternative. This alternative would not add additional sources of lighting to the project site and vicinity. Compared to the proposed project, this alternative would reduce impacts. No aesthetics impacts would occur under the No Project/No Development Alternative.

Air Quality
Under the No Project/No Development Alternative, air emissions associated with project construction including emissions associated with blasting, rock crushing, gra ding, site preparation, site finishing and building finishing would not occur. Implementation of this alternative would not introduce any uses that could generate air emissions. Thus, compared to the proposed project, this alternative would not result in a ny air quality emissions. However, as discussed in Section 3.2.4, impacts to air quality for the proposed project would be less than significant and no mitigation would be required.

Compared to the proposed project, this alternative would reduce air qualit y emissions. No air quality impacts would occur under the No Project/No Development Alternative.

Biological Resources
The No Project/No Development Alternative would not require any ground -disturbing activities. As such, this alternative would avoid the impacts to 0.61 acre of Diegan coastal sage scrub, 0.03 acre of Diegan coastal sage scrub – Baccharis dominated, and 9.5 0 acres of non -native grassland (Impact BIO- 2). This alternative would also avoid potential impacts to nesting birds (Impact BIO -1), and potential indirect impacts to sensitive habitats during project construction an d operation (Impacts BIO-3 and BIO-4). The project does include mitigation measures to reduce these impacts to below a level of significance. However, because impacts to biological resources would be avoided under the No Project/No Development Alternative, mitigation measures MM-BIO-1 through MM-BIO-4 would not be implemented or required. Compared to the proposed project, th is alternative would eliminate the biological resources impacts . No biological resources impacts would occur under the No Project/No Development Alternative.

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Cultural Resources
The No Project/No Development Alternative would not require any ground -disturbing activities.

Therefore, there would be no potential to impact unknown archaeological and historical resources potentially located within the project site (Impact CR -1a and Impact CR -1b). Further, there would be no potential to disturb previously unidentified human remains that may be present on the project site (Impact CR-2). As such, mitigation measures MM -CR-1a through MM-CR-1c and MM-CR-2 would not be implemented or required. Although there may be a reduced level of direct impact to cultural resources, any previously undiscovered on -site resources could be subject to continued degradation due to lack of preservation of the undeveloped site. Compared to the proposed project, this No Project/No Development Alternative would result in a reduced level of impact to cultural resources as no ground disturbance would occur.

Energy
Under the No Project/No Development Alternative, there would be no energy use associated with construction and operation, since no development would occur. While impacts under the proposed project related to energy use were determined to be less than significant, the y would be completely eliminated under this alternative since there would be no ener gy use. C ompared to the proposed project, the No Project/No Development Alternative would eliminate the energy use identified for the project and there would be no energy impacts.

Geology and Soils
Under the No Project/No Development Alternative, the proje ct site would remain in its current state.

Existing topography and on-site soils would not be modified to accommodate proposed development.

Potential impacts to unknown paleontological resources (Impact GEO -1) that were identified for the project would be avoided under this alternative, as there would be no ground disturbing activities.

Compared to the proposed project, the No Project/No Development Alternative would reduce potential impacts related to geology and soils.

Greenhouse Gas Emissions
Under the No Project/No Development Alternative, greenhouse gas (GHG) emissions associated with electricity and natural gas use, water use, and solid waste handling associated with future residences would not occur. This alternative would not introduce any people or uses to the site that would generate greenhouse gas emissions. Additionally, since this alternative would not generate project-related trips, GHG emissions associated with vehicular trips would not occur. The proposed project’s GHG impacts were determined to be less than significant. Thus, compared to the proposed project, the No Project/No Development Alternative would result in a reduction of greenhouse gas emissions on the site and no impact would occur.

Hazards and Hazardous Materials
Under the No Proje ct/No Development Alternative, no uses would be introduced that could result in the use or generation of hazardous materials. While the proposed project’s hazards and hazardous materials impacts were less than significant, this alternative would further minimize potential impacts related to hazards and hazardous materials.

One area where the project does have a benefit related to hazards is in relation to wildfire risk. Since the proposed project would develop the site and also incorporate a 150 -foot manage d fuel

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modification buffer, it would eliminate sources of fire fuel (vegetation) on the project site which could provide a benefit to offsite development s in the event of wildlife. This benefit would not be realized under the No Project/No Development Alternative.

Hydrology and Water Quality
Under the No Project/No Development Alternative, no development would occur, and no impervious surfaces would be created. The existing on -site hydrologic conditions, drainage patterns, and drainage volumes would remain unaltered. Water quality would also remain unchanged. However, as described in Section 3.9, the proposed project’s impacts to hydrology and water quality would be less than significant. Thus, although the No Project/No Development Alternative would reduce potential hydrology and water quality impacts on site, this alternative would not eliminate any potential significant impacts to hydrology and water quality.

Land Use and Planning
Under this alternative, the project site would remain undeveloped and none of the discretionary approvals identified for the project would be required. The General Plan Amendment (GPA) to change the designations of the site from Mixed Use 3 (MU3) to Specific Plan Area (SPA), as well as a rezone of the site would not be required. A Conditional Use Permit would not be required as there would be no need for the use of a temporary rock crusher. Additionally, a Grading Variance would not be needed as there would not be any grading nor creation of slopes greater than 20 feet.

Since this alternative would not generate nor add any vehicular trips to the local circulation network, it would avoid the significant and unavoidable impacts related to increase in delay at Rancheros Drive/SR-78 WB Ramp in the AM and PM Peak hours in the Near Term 2 025 project condition (Impact LU-1 and TR-1). However, it should be noted that under existing conditions, this intersection operates at Level of Service (LOS) F . The existing traffic conditions at this location are already substandard and warrant a traffic signal. Under this alternative, the developer would not pay the regional and local Public Facilities Fees (PFF) development fees which would help fund the needed improvement of a traffic signal at this intersection. Since there would be no develop ment under this alternative, it would avoid the LOS -related impacts at the project driveways (Impacts LU -2a and LU - 2b). Since discretionary approvals would not be required under this alternative and this project would not generate any traffic, it would elimina te the significant and unavoidable land use impacts for the project.

Noise
The project site is currently vacant and does not generate any noise into the surrounding area. Under the No Project/No Development Alternative, the project site would remain undeve loped and would not create any new sources of construction or operational noise. Additionally, this alternative would not generate any of the noise associated with potential rock drilling and rock crushing that were identified for the proposed projects (Im pacts N-1 and N -2). Additionally, this alternative would not result in development that would be subject to elevated noise levels at sensitive receptors (Impacts N-3 and N -4). As such, Impacts N -1 through N -4 would not occur, and mitigation measures MM -N-1 through MM-4, outlined in Section 3.11.6, would not be required. As such, noise impacts under this alternative would be reduced as compared to the proposed project. No noise impacts would occur under the No Project/No Development Alternative.

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Population and Housing
The project site is currently vacant and located adjacent to existing residential uses to the east and southwest and a church and preschool to the west. The No Project/No Development Alternative would not induce population growth in the area, as no development would occur. As described in Section 3.12, the proposed project would add an additional 469 people on site but would not result in substantial population growth in the area. N o residents or housing would be added to the site under the No Pr oject/No Development Alternative, so this alternative would not contribute to meeting regional housing demands. Because this alternative does not result in the addition of people on site, beyond the current allowable residential uses on site, impacts would be reduced compared to the proposed project. No population and housing impacts would occur under the No Project/No Development Alternative.

Public Services
The No Project/No Development Alternative would not result in an increase in demand for public services, since no homes would be developed and there would not be additional residents moving into the area. Specifically, the No Project/No Development Alternative would not increase the demand for police and fire protection services, nor would this alternat ive increase demand for park, school, and library services. As stated in Section 3.13, public service impacts for the proposed project would be less than significant. Since this alternative would not result in additional residents on site, impacts on publi c services would be reduced, compared to the proposed project. No public services impacts would occur under the No Project/No Development Alternative. Under this alternative, the developer would not pay the regional and local Public Facilities Fees (PFF).

Additionally, no school fees would be paid under this alternative.

Recreation
Under the No Project/No Development Alternative, there would not be an increase in demand for park and recreation services. As such, payment of the City’s Public Facility Fees (PFF) by the applicant would not be required. Compared to the proposed project, the No Project/No Development Alternative would decrease impacts and no recreation impacts would occur under the No Project/No Development Alternative. Under this alternative, th e developer would not pay the Public Facilities Fees (PFF), a portion of which go towards funding park and recreation facilities and program.

Transportation
The No Project/No Development Alternative would not result in the generation of vehicular trips or result in an increase in vehicle miles traveled (VMT). Since this alternative would not generate any vehicular trips to the local circulation network, it would avoid the significant and unavoidable impacts related to increase in delay at the Rancheros Drive/SR-78 WB Ramp intersection in the AM and PM Peak hours in the Near Term 2025 project condition (Impact s LU-1 and TR-1). However, it should be noted that under existing conditions, this intersection operates at LOS F . The existing traffic conditions at th is location are already substandard and warrant a traffic signal. Under this alternative, the developer would not pay the regional and local Public Facilities Fees (PFF) which would help fund the needed improvement of a traffic signal at this intersection along with circulation streets and SR -78 interchanges within the City of San Marcos. Similarly, since there would be no development under this alternative, it would avoid the significant and unavoidable impact related to Vehicle Miles Traveled ( VMT). Compared to the proposed project, the No Project/No Development

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Alternative would eliminate all significant and unavoidable transportation impacts identified for the project. No transportation impact would be identified for the No Project/No Development Alternative.

Tribal Cultural Resources
The No Project/No Development Alternative would not require any ground -disturbing or other construction/development activities. Therefore, there would be no potential to impact unknown tribal cultural resources located within the project site. As such, mitigation measures MM -CR-1a through MM-CR-1c and MM -CR-2 would not be implemented or required . Although there may be a reduced level of direct impact to tribal cultural resources, any previously undiscovered on-site resources could be subject to continued degradation due to lack of preservation of the undeveloped site. Compared to the proposed pro ject, this alternative would result in a reduced level of impact to tribal cultural resources.

Utilities and Service Systems
No homes would be constructed under the No Project/No Development Alternative. As such, the re would be no increase in demand for wa ter service, wastewater service, stormwater capacity, energy, and solid waste handling services. As discussed in Section 3.17.4, project impacts related to utilities and services systems were determined to be less than significant . Because no development w ould occur under this alternative, the demand for utilities would be eliminated. Thus, impacts to utilities and service systems would be reduced compared to the proposed project . No utilities and service system impacts would occur for the No Project/No Development Alternative.

This alternative would not realize the benefit of the looped water line that would be constructed by the project applicant as part of the project. This water line extension and connection to VWD infrastructure would provide a backup w ater source for the Mira Lago community, located immediately east of the project site.

Conclusion
Since the No Project/No Development Alternative would not develop any homes on the project site, overall impacts would be less than with the proposed project or eliminated entirely. There are some benefits of the project that would not be realized under this alternative, including providing additional housing units as identified in the General Plan and a reduction of wildfire risk through vegetation removal and fire fuels management . Under this alternative there would not be any payment of Public Facilities Fess (PFF), which goes toward supporting variety of services and improvements in the City, including but not limited to Circulation Street, SR -78 Interchanges, NPDES, Tech Improvements, Parks, and Habitat Conservation. Similarly, this alternative would not contribute any school fees. This alternative would not realize the benefit of the looped water line that would be constructed by Rincon del Diablo Municipal Water District (RDDMWD) as part of the project. This water line extension and connection to VWD infrastructure would provide a backup water source for the Mira Lago community, located immediately east of the project site. Finally, t his alternative would not meet any of the project objectives (Table 4-1).

4.3.4 No Project/Existing Land Use Designation Alternative Under the No Project/Existing Land Use Alternative, the project site would be developed consistent with the site’s existing land use. Per the City’s Gen eral Plan, the project site has an existing General Plan Land Use designation of Mixed Use 3 (MU3), which is a mixed -use non-residential designation

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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). St ructured parking, while not required to achieve the maximum FAR, may be allowed. Shared parking arrange ments may also be allowed consistent with the nature of mixed uses. Typical uses include retail, commercial services, administrative and office uses, in stitutional 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).

Figure 4.3 -1 presents a development concept that would meet the MU3 requirements. It would include three 3 -story buildings on the project site for a total of 275,067 square feet (s.f.) of office use, 18,344 of retail use, and 879 parking spaces. The southern portion of the project site would be reserved for a minimum 150-foot fire fuel modification buffer. Overall, the development footprint and area of disturbance would be similar to that of the proposed project, but with different uses.

Vehicular trips under the No Project/Existing Land Use Alternative would be approximately four times higher than the proposed project. This alternative would generate approximately 5,41 0 ADT compared to the 1,208 ADT anticipated for the project.

4.3.4.1 Comparison of the Effects of the No Project/Existing Land Use Alternative to the Proposed Project
Aesthetics
The No Project/Existing Land Use Alternative would develop three 3 -story buildings and a parking garage. Proposed buildings would be a similar height as the proposed project but would be larger in bulk and scale. The proposed project includes 19 7 -Plex Bui ldings (133 units) and six 3 -plex buildings (18 units) and a recreation center dispersed throughout the project site at different orientations and grades to break up the bulk and scale of the project. Buildings under this alternative would be larger and pl aced on the northern portion of the site. This may result in a more visually dominating appearance from SR-78 compared to the project. However, through architectural features and varying facades as well as landscaping, it is expected that impacts would be less than significant.

Similar to the proposed project, this alternative would incorporate lighting for safety, security and way finding. Lighting would be required to comply with the City’s Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080 to minimize light pollution. The No Project/Existing Land Use Alternative would have a similar level of aesthetics impact as the proposed project and those impacts would be less than significant.

Air Quality
Under the No Project/Existing Land Use Alternative, air emissions associated with project construction including emissions associated with blasting, rock crushing, grading, site preparation, site finishing and building finishing would still occur and would be simil ar to those anticipated for the project.

Operationally, office and retail uses are not typically sources that create odors or significant air emissions from their day -to-day operations. Emissions from vehicles going to and from the projects

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site typically account for the largest portion of greenhouse gas emissions. The project’s TIA (Appendix K to the EIR) calculated potential ADT under the existing General Plan land use on the project site.

Vehicular trips an Existing Land Use alternative would be higher t han the proposed project. This alternative would generate approximately 5,410 ADT compared to the 1,208 ADT anticipated for the project, or more than four times the amount. As such, because this alternative would result in an increase of ADT on site, air q uality emissions would be greater when compared to the proposed project. However, air quality impacts under this alternative are still anticipated to be less than significant.

Biological Resources
The No Project/Existing Land Use Designation Alternative would have a similar level of biological resources impacts as the proposed project, since it would have a similar footprint of disturbance.

This would include 0.61 acre of Diegan coastal sage scrub, 0.03 acre of Diegan coastal sage scrub – Baccharis dominated, and 9.50 acres of non -native grassland as well as the potential for impact to nesting birds and potential indirect impacts to sensitive habitats during project construction an d operation. Biological resources mitigation measures identified for the propo sed project would be applicable to this alternative (MM-BIO-1 through MM-BIO-4) and would reduce the impacts to below a level of significance. This No Project/Existing Land Use Designation Alternative would have a similar level of biological resources impacts as the proposed project.

Cultural Resources
The No Project/Existing Land Use Designation Alternative would result in similar ground disturbance as the proposed project. Therefore, potential to impact unknown historical and archaeological resources potentially located within the project site as well as unidentified human remains would still occur. Cultural resources mitigation measures identified for the proposed project would be applicable to this alternative (MM-CR-1a, MM-CR-1b and MM-CR-2) and would reduce the impacts to below a level of significance. This No Project/Existing Land Use Designation Alternative would have a similar level of cultural resources impacts as the proposed project.

Energy
Construction-related energy use would be similar as the p roposed project. Operationally, office and retail uses have a higher energy demand than residential uses. Additionally, since this alternative would generate four times the ADT compared to the proposed project, fuel use would be higher under this alternative. Compared to the proposed project, energy demand would be higher than the No Project/Existing Land Use alternative, but is still expected to be less than significant.

Geology and Soils
Under the No Project/Existing Land Use Designation Alternative, although the project site would be developed with different land uses, ground -disturbance areas would be similar. Development under this alternative would be subject to the same potential seismic hazards such as rupture of a known active fault or seismic ground shaking. Further, as discussed above, due to the underlying geology of the site, the same amount of blasting would be required under this alternative.

This alternative would also require abiding by geological recommendations, such as the ones identified in the geotechnical evaluation. Compared to the proposed project, this alternative would result in the same level of impacts to geology and soils.

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Greenhouse Gas Emissions
Under the No Project/Existing Land Use Alternative, greenhouse gas emissions associated with project construction would still occur. Operationally, greenhouse gas emissions would be higher for this alternative than the proposed project. E missions from vehicles typically account for the largest portion of greenhouse gas em issions. The traffic impact analysis prepared for the project (Appendix K to the EIR), calculated potential ADT if a project was developed consistent with the current General Plan land use designation. Vehicular trips under this scenario would be higher th an the proposed project. This alternative would generate approximately 5,410 ADT compared to the 1,208 ADT anticipated for the project, or more than four times the amount. Under this alternative, operational GHG emissions are anticipated to be 3,269.10 MT/ Year, while the proposed project GHG emissions are modeled to be 949.79 MT/Year (LDN 2021b) . As such, because this alternative would result in an increase of ADT on site, greenhouse impacts would be greater when compared to the proposed project however it is anticipated that this alternative would implement all of the required CAP measures and greenhouse gas impacts would be less than significant.

Hazards and Hazardous Materials
The project site is currently vacant and is not listed on any hazardous materials sites. C onstruction and operation of an office and retail/commercial use, as contemplated under the No Project/Existing Land Use Alternative, is not expected to result in the rel ease of any significant hazardous materials or the routine transport, use, or disposal of such materials. Development under this alternative would not result in any safety hazards resulting from proximity to the McClellan -Palomar Airport, nor would this al ternative impair implementation of or physically interfere with emergency response or evacuation plans. Development under this alternative would b e constructed in accordance with all applicable fire codes and would incorporate an appropriate fire fuel modification zone. Impacts related to hazards and hazardous material would be less than significant for this alternative and would be similar to the proposed project.

Hydrology and Water Quality
The No Project/Existing Land Use Alternative would result in similar ground disturbance to the site.

As such, this alternative would introduce impervious surfaces at the site, similar to the proposed project. The existing on-site hydrologic conditions, drainage patterns, and drainage volumes would be modified. It is exp ected that this alternative would also incorporate all required and applicable best management practices in order to avoid any violations of water quality standards or otherwise modify or adversely affect surface and groundwater quality. As compared to the proposed project, this alternative would result in similar impacts and the impacts would be less than significant.

Land Use and Planning
Under the No Project/Existing Land Use Alternative , a General Plan Amendment and Rezone would not be required as the d evelopment would be consistent with the General Plan and zoning designation of the site, which is Mixed Use 3 (MU3).

The proposed project would result in significant impacts related to land use, specifically due to an inconsistency with policies in the Mob ility Element of the General Plan that address LOS. The proposed project would result in significant and unavoidable impacts at intersection of Rancheros Drive/ SR-78 WB in the AM and PM peak hours under Near Term 2025 With Project condition. Since the No Project/Existing Land Use Alternative would result in four times the ADT as the project (5,410

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ADT compared to 1,208 ADT) , this significant and unavoidable impact would still occur at this intersection. Similarly, the significant impact identified for the project related to left -turn movements out of the project driveways would also be anticipated under this alternative and would be mitigated through driveway turn restrictions, similar to the mitigation identified for the project.

In summary, this alternati ve would have a similar level of impact as the proposed project and would have significant and unavoidable land use impacts.

Noise
Construction-related noise under the No Project/Existing Land Use Alternative is expected to be similar to the proposed proje ct, since grading activities would still be required, and similar type s of equipment would be used. Blasting and rock crushing would still be required under this alternative and impacts identified for the project related to the staging location of rock dri lling and noise from rock crushing activities would still be expected under this alternative. Mitigation measures identified for the project (MM -N-1 and MM -N-2) would be applicable to this alternative and would reduce potential construction-related noise impacts to below a level of significance.

Operational noise generated under the No Project/Existing Land Use Alternative would be related to the noise generated on the project site from office and retail/commercial activities as well as trips generated by the project.

Similar to the proposed project, commercial uses , including office and retail , have an exterior noise standard of 65 dBA Leq. For non -residential noise sensitive land uses, such as those that would be developed under this alternative, the exterior noise level is defined as noise measured at the exterior area provided for public use (City of San Marcos 2017). If public use areas were incorporated into this alternative, they could experience elevated noise levels from offsite vehicular traffic ass ociated with SR-78 and E. Barham Drive. Mitigation measures, such as walls and/or berms, may be required to attenuate the noise. This is similar to what has been identified for the proposed project. It is expected that sound levels could be attenuated to b elow a level of significance, similar to the proposed project.

This alternative would generate more than four times the ADT as the project (5,410 ADT compared to 1,208 ADT). Therefore, offsite noise generated by the project would be higher under this alter native than the proposed project. Currently , there is 18,025 ADT on E. Barham Drive (LLG 2021). Since it takes a doubling of traffic to create a significant noise impact, this alternative would not result in a significant offsite noise impact associated with vehicular noise . Operationally, an office and retail/commercial development would typically have more daily activity compared to a residential project, which could result in more operational noise. Additionally, such buildings would typically require larger HVAC equipment, which can result in more noise compared to residential buildings.

However, such operational activities are not anticipated to be significant and HVAC equipment is typically shielded with rooftop parapets or other barriers which help to minimize noise.

Compared to the proposed project, this alternative would have a similar level of impact as the proposed project and all anticipated noise impacts could be mitigated to below a level of significance.

Population and Housing
The No Project/Existing Land Use Alternative would develop the site in a manner that is consistent with the City’ s General Plan and would, therefore, have been considered in the City’s growth

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assumptions. The proposed projec t would increase the population by approximately 469 residents.

However, this increase was determined to be less than significant. The No Project/Existing Land Use Alternative would not increase the population because no residential uses are included . The No Project/Existing Land Use Alternative would not create market rate/work force housing on the project site, which is needed in the City. Compared to the proposed proj ect, this alternative would have a similar level of impact and impacts would be less than significant.

Public Services
Similar to the proposed project, the No Project/ Existing Land Use Alternative would result in an increase in demand for public services, due to the construction of office and retail/commercial uses.

Specifically, this altern ative would increase the demand for police and fire protection services, as well as park, and library services over existing conditions. Since no residences would be constructed under this alternative there would be no increase in demand for school services. Development under this alternative would still be required to pay applicable Public Facilities Fees (PFF) and school fees, though the school fees would be at a reduced rate compared to the proposed project, since no residential uses are proposed. Simila r to the proposed project, impacts would be less than significant.

Recreation
The No Project/Existing Land Use Alternative is not anticipated to generate an increase in demand of recreational needs compared to the proposed project as no residential uses would be proposed.

Residential uses are the primary driver for demand for park and recreation services. Compared to the proposed project, this alternative would decrease the demand for park and recreation service and impacts would be less than significant.

Transportation
Under the No Project/Existing Land Use Alternative impacts associated with consistency with policies in the Mobility Element of the General Plan that address LOS are still anticipated. The proposed project would result in significant and unav oidable impacts at the intersection of Rancheros Drive/ SR-78 WB in the AM and PM peak hours under Near Term 2025 With Project condition. Since the No Project/Existing Land Use Alternative would result in four times the ADT as the project (5,410 ADT compared to 1,208 ADT), significant and unavoidable impacts would still occur at this intersection.

With regard to Vehicle Miles Traveled (VMT), based upon San Diego Association of Governments (SANDAG) screening maps, if the site was developed under the existing zoning, this alternative would exceed the significance threshold by 13.1%. This would require mitigation of 13.1% or more to reduce Vehicles Miles Traveled (VMT) to a less than significant level. Compared to the project, there may be additional mitigation measures available to reduce Vehicle Miles Traveled ( VMT) since an office and commercial use has more Vehicle Miles Traveled (VMT) reduction strategies available.

Such strategies could include employer carpool/vanpool programs, employer transit subsidies, and telecommute/alternative work schedules. Depending on the mix of reduction strategies an employer implements and the number of employees who participate, it could be possible to reduce the Vehicle Miles Traveled (VMT) impact to be below a level of sign ificance for this alternative. Compared to the proposed project this alternative could reduce the Vehicles Miles Traveled (VMT) impact, however the significant and unavoidable impacts related to inconsistency with the Mobility Element of the General Plan would still occur.

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Tribal Cultural Resources
The No Project/Existing Land Use Designation Alternative would result in similar ground disturbance as the proposed project. Therefore, the potential to impact tribal cultural resources would still be possible under this alternative. Cultural resources mit igation measures identified for the proposed project would be applicable to this alternative (MM -CR-1a, MM -CR-1b and MM -CR-2) and would reduce the impacts to below a level of significance. This No Project/Existing Land Use Designation Alternative would have a similar level of tribal cultural resources impacts as the proposed project.

Utilities and Service Systems
The No Project/Existing Land Use Alternative would result in an increase in utilities and service systems, including water, wastewater, stormwater infrastructure, and solid waste service over existing conditions through the development of new office and retail/commercial uses. For sewer service, Vallecitos Water District (VWD) estimates 1,500 gallons per day (gpd)/acre for commercial uses. Residential uses are calculated at 3,300 gpd/acre. Therefore, the demand for sewer services would be decreased under this alternative. Rincon del Diablo Municipal Water District (RDDMWD) does not publish water demand rates; however, residential uses typically resul t in more water use than office and retail uses. Compared to the project, this alternative would decrease the demand for water and sewer service but would still be required to pay all applicable water and sewer fees. Storm water infrastructure is anticipat ed to be similar as the proposed project as a similar amount of impervious surface would be created. Solid waste generated would not differ significantly under this alternative. Utilities and service system impacts would be less than significant under the No Project/Existing Land Use Alternative and would reduce water and sewer demand compared to the proposed project.

Conclusion
The No Project/Existing Land Use Alternative would result in a more intensive use on the project site, including more than four ti mes the trip generation compared to the proposed project (5,410 ADT compared to 1,208 ADT). This results in a corresponding proportional increase in air and greenhouse gas emissions and noise from vehicles compared to the proposed project. Footprint - specific impacts, such as those related to biological resources, cultural and tribal cultural resources, and geology and soils would be similar as the proposed project as the same amount of site area would be disturbed. This alternative would not generate any s tudents for SMUSD and would reduce demand for water and sewer service compared to the proposed project. Depending on the mix of Vehicle Miles Traveled (VMT) reduction strategies an employer implements and the number of employees who participate, it could b e possible to reduce the Vehicle Miles Traveled (VMT) impacts to below a level of significance. This alternative could meet some of the project objectives, as shown in Table 4-1.

4.3.5 Reduced Density Alternative
Under the Reduced Density Alternative, the project site would be developed with 74 residential units for a density of 7 du/acre. Such a density could support a mix of single -family and multi -family residential units. The southern portion of the project site would be reserved for a minimum 150 -foot fire f uel modification buffer. Overall, the development footprint and area of disturbance would be similar to that of the proposed project, but with less density of residential units.

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Vehicular trips under this alternative would be reduced compared to the propos ed project.

Depending on the type and number of units developed under this alternative (single family and multifamily), this alternative would generate between 592 and 740 ADT. Compared to the proposed project, which generates 1,208 ADT, this alternative w ould reduce ADT by at least 38% and up to 50%.

4.3.5.1 Comparison of the Effects of the Reduced Density Alternative to the Proposed Project Aesthetics
Development under the Reduced Density Alternative would include a mix of single family and multifamily residential units and could include buildings up to three stories high. Compared to the proposed project, there would be less overall development on the project site. Development would still be visible from SR -78. Similar to the proposed project, this alternative wo uld incorporate lighting for safety, security and way finding. Lighting would be required to comply with the City’s Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080 to minimize light pollution. The Red uced Density Alternative would have a similar level of aesthetics impact as the proposed project and those impacts would be less than significant.

Air Quality
Under the Reduced Density Alternative, air emissions associated with construction including emissions associated with blasting, rock crushing, grading, site preparation, site finishing and building finishing would still occur and would be similar to those anticipated for the project.

Operational emissions under this alternative would be similar to the project, since a similar use is proposed, but since fewer residential units would be constructed, area source emissions would be proportionally decreased. Vehicular trips under the Reduced Density Alternative would be lower than the proposed project. Depe nding on the type and number of units developed under this alternative (single family and multifamily), this alternative would generate between 592 and 740 ADT.

Compared to the proposed project, which generates 1,208 ADT, this alternative would reduce ADT by at least 38% and up to 50%. As such, because this alternative would result in a decrease of ADT, vehicular-related air emissions would be reduced when compared to the proposed project and impacts would be less than significant.

Biological Resources
The Reduced Density Alternative would have a similar level of biological resources impacts as the proposed project, since it would have a similar footprint of disturbance.

This would include 0.61 acre of Diegan coastal sage scrub, 0.03 acre of Diegan coastal sage scrub – Baccharis dominated, and 9.50 acres of non -native grassland as well as the potential for impact to nesting birds and potential indirect impacts to sensitive habitats during p roject construction an operation. Biological resources mitigation measures identified for the proposed project would be applicable to this alternative (MM-BIO-1 through MM-BIO-4) and would reduce the impacts to below a level of significance. This Reduced D ensity Alternative would have a similar level of biological resources impacts as the proposed project.

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Cultural Resources
The Reduced Density Alternative would result in similar ground disturbance as the proposed project.

Therefore, potential to impact unk nown historical and archaeological resources potentially located within the project site as well as unidentified human remains would still occur. Cultural resources mitigation measures identified for the proposed project would be applicable to this alterna tive (MM- CR-1a, MM-CR-1b and MM-CR-2) and would reduce the impacts to below a level of significance. This Reduced Density Alternative would have a similar level of cultural resources impacts as the proposed project.

Energy
Construction related energy demands would be similar as the proposed project. However, energy use associated with operation of the Reduced Density Alternative would be less compared to the proposed project since the number of units would be decrease d from 151 units to 74 units.

Similarly, energy use associated with vehicle fuel would be reduced since this alternative would reduce the number of trips by at least 38%. Compared to the proposed project, the Reduced Density Alternative reduces the amount of energy used and impacts would be less than significant.

Geology and Soils
Ground disturbance under the Reduced Density Alternative would be similar as the proposed project .

Development under this alternative would be subject to the same potential seismic hazards such as rupture of a known act ive fault or seismic ground shaking. Further, as discussed above, due to the underlying geology of the site, the same amount of blasting would be required under this alternative.

This alternative would also require abiding by geological recommendations, su ch as the ones identified in the geotechnical evaluation. Compared to the proposed project, this alternative would result in the same level of geology and soils impacts.

Greenhouse Gas Emissions
Under the Reduced Density Alternative, greenhouse gas emissions associated with project construction would still occur. Operational emissions under this alternative would be similar to the project, since a similar use is proposed. However, vehicular emissions typically account for the largest portion of greenhouse g as emissions. Vehicular trips under the Reduced Density A lternative would be lower than the proposed project. Depending on the type and number of units developed under this alternative (single family and multifamily), this alternative would generate betwee n 592 and 740 ADT. Compared to the proposed project, which generates 1,208 ADT, this alternative would reduce ADT by at least 38% and up to 50%. As such, because this alternative would result in a decrease of ADT on site, greenhouse gas emissions would be reduced when compared to the proposed project and greenhouse gas impacts would be less than significant.

Hazards and Hazardous Materials
The project site is currently vacant and is not listed on any hazardous materials sites. C onstruction and operation of this alternative would result in a similar level of hazards and hazardous materials risk as the proposed project since a similar type of use is proposed (residential use). Development under this alternative would not result in any safety hazards resulting from proximity to the McClellan-Palomar Airport, nor would this alternative impair implementation of or physically interfere with emergency r esponse or evacuation plans . Development under this alternative would b e constructed in accordance with all applicable fire codes and would incorporate an appropriate fire

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fuel modification zone. Impacts related to hazards and hazardous material would be l ess than significant for this alternative and would be similar to the proposed project.

Hydrology and Water Quality
The Reduced Density Alternative would result in ground disturbance to the site. As such, this alternative would introduce impervious surfaces at the site, similar to the proposed project. The existing on-site hydrologic conditions, drainage patterns, and drainage volumes would be modified. It is expected that this alternative would also incorporate all required and applicable best management practices in order to avoid any violations of water quality standards or otherwise modify or adversely affect surface and groundwater qu ality. As compared to the proposed project, this alternative would result in similar hydrology and water quality impacts and the impacts would be less than significant.

Land Use and Planning
Under the Reduced Density Alternative , a General Plan Amendment a nd Rezone would still be required. The proposed project would result in significant impacts related to land use, specifically due to an inconsistency with policies in the Mobility Element of the General Plan that address LOS.

The proposed project would res ult in significant and unavoidable impacts at intersection of Rancheros Drive/ SR -78 WB in the AM and PM peak hours under Near Term 2025 With Project condition. While the Reduced Density Alternative would decrease ADT by 38%, this impact would still occur at this intersection as the existing LOS at this intersection is already below an acceptable level.

Similarly, the significant impact identified for the project related to left -turn movements out of the project driveways would also be anticipated under this alternative and would be mitigated through driveway turn restrictions, similar to the mitigation identified for the project. In summary, this alternative would have a similar level of land use and planning impact as the proposed project and would have significant and unavoidable land use impacts.

Noise
Construction-related noise under the Reduced Density Alternative is expected to result in a similar level of noise as the proposed project, since grading activities would still be required and similar types of equipment would be used. Blasting and rock crushing would still be required under this alternative and impacts identified for the project related to the staging location of rock drilling and noise from rock crushing activities would still be expected u nder this alternative. Mitigation measures identified for the project (MM-N-1 and MM-N-2) would be applicable to this alternative and would reduce potential construction-related noise impacts to below a level of significance.

Operational noise generated un der the Reduced Density Alternative would be related to the noise generated on the project site from residential uses as well as trips generated by the project. Similar to the proposed project, significant impacts related to elevated noise levels associate d with SR -78 and E. Barham Drive would be expected under this alternative. Mitigation measures, such as walls and/or berms, would be required to reduce the impact to below a level of significance. This is similar to what has been identified for the propose d project. It is expected that sound levels could be attenuated to below a level of significance, similar to the proposed project.

This alternative would generate less vehicular trips than the proposed project . Therefore, offsite noise generated by the project would be less under this alternative than the proposed project .

Compared to the proposed project, this alternative would have a similar level of impact , with a

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reduction in offsite noise associated with vehicular traffic. Similar to the proposed proje ct, all anticipated noise impacts could be mitigated to below a level of significance.

Population and Housing
The Reduced Density Alternative would result in an increase the population of the City by approximately 230 residents. The proposed project would increase the population by approximately 469 residents. However, this increase was determined to be less than significant. This alternative would create less market rate/work force housing on the project site compared to the proposed project. Compared to the proposed project, this alternative would have a similar level of impact and impacts would be less than significant.

Public Services
Similar to the proposed project, the Reduced Density Alternative would result in an increase in demand for public servic es due to the construction of residential uses on the project site.

Specifically, this alternative would increase the demand for police and fire protection services, schools, as well as park, and library services over existing conditions. Compared to the p roposed project, fewer students would be generated since fewer residential units would be constructed.

Development under this alternative would still be required to pay applicable Public Facilities Fees (PFF) and school fees. The amount of Public Facilities Fees (PFF) paid under this alternative would be less than compared to the project since fewer residential uses would be constructed. The amount of school fees paid to SMUSD would be less under this alternative. Similar to the proposed project, impacts would be less than significant.

Recreation
Similar to the proposed project, the Reduced Density Alternative would result in an increase in demand for park and recreation facilities. Development under this alternative would still be required to pay applicable Public Facilities Fees (PFF) and school fees, however the amount of fees paid would be less since fewer residential units would be constructed. Additionally, this alternative would be required to provide common open space and private open space per City r equirements. Similar to the proposed project, impacts would be less than significant.

Transportation
Under the Reduced Density Alternative, impacts associated with consistency with policies in the Mobility Element of the General Plan that address LOS are s till anticipated. The proposed project would result in significant and unavoidable impacts at the intersection of Rancheros Drive/ SR -78 WB in the AM and PM peak hours under Near Term 2025 With Project condition. While the Reduced Density Alternative would decrease ADT by 38% to 50% , this impact would still occur at this intersection due to its unacceptable LOS under existing condition. Given the site’s suburban location and proposal for residential uses under this alternative, Vehicle Miles Traveled ( VMT) impacts are still anticipated under this alternative and would remain significant and unavoidable. In summary, this alternative would have a similar level of impact as the proposed project and would have significant and unavoidable transportation impacts.

Tribal Cultural Resources
The Reduced Density Alternative would result in similar ground disturbance as the proposed project.

Therefore, potential to impact tribal cultural resources would still be possible under this alternative.

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Cultural resources mitiga tion measures identified for the proposed project would be applicable to this alternative (MM-CR-1a, MM-CR-1b and MM-CR-2) and would reduce the impacts to below a level of significance. The Reduced Density Alternative would have a similar level of tribal c ultural resources impacts as the proposed project.

Utilities and Service Systems
The Reduced Density Alternative would result in an increase in utilities and service systems, including water, wastewater, stormwater infrastructure, and solid waste service t hrough the development of 74 residential units . However, compared to the project, this alternative would decrease the overall increase in demand since fewer residences would be constructed. Development under this alternative would still be required to pay all applicable water and sewer fees. Storm water infrastructure is anticipated to be similar as the proposed project as a similar amount of impervious surface would be created. Solid waste generated would be reduced under this alternative. Utilities and se rvice system impacts would be less than significant under the Reduced Density Alternative and would reduce water and sewer demand solid waste generation compared to the proposed project.

Conclusion
The Reduced Density Alternative would reduce the number of residential units constructed on the project site. This results in a corresponding decrease in vehicular trips by approximately 38% to 50% and a corresponding decrease in air and greenhouse gas emissions and noise from offsite tr affic compared to the proposed project. Public services, utilities and service systems, and energy demands would also proportionally decrease. Footprint specific impacts, such as those related to biological resources, cultural and tribal cultural resources , and geology and soils would be similar as the proposed project since a similar area of disturbance would occur under this alternative. This alternative would contribute less Public Facilities Fees (PFF) and school fees since fewer residential units would be constructed. This alternative would meet the majority of the project objectives as detailed in Table 4-1.

4.3.6 Reduced Footprint Alternative
A Reduced Footprint Alternative was analyzed as it would result in less grading and site disturbance compared to the project. For the Reduced Footprint Alternative, the southernmost row of residential buildings proposed by the project would be eliminated. This includes eight 7 -plex buildings and one 3-plex building. Under the Reduced Foot Alternative, the site would be developed with 92 multifamily residential units. The southern portion of the project site would still be subject to a minimum 150 - foot fire fuel modification buffer.

Vehicular trips under this alternative would be reduced compared to the proposed project. This alternative would generate 736 ADT. Compared to the proposed project, which generates 1,208 ADT, this alternative would reduce ADT by 39%.

4.3.6.1 Comparison of the Effects of the Reduced Footprint Alternative to the Proposed Project Aesthetics
Development under the Reduced Footprint Alternative would still develop three-story high multifamily residential building and a recreation center. Compared to the proposed project, there would be less overall development on the project site. Development would still be visible from SR -78. Similar to the

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proposed project, this alternative would incorporate lighting for safety, security and way finding.

Lighting would be required to comply with the City’s Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080 to minimize light pollution. The Reduced Footprint Alternative would have a similar level of aesthetics impact as the proposed project and those impacts would be less than significant.

Air Quality
Under the Reduced Footprint Alternative, air emissions associated with construction including emissions associated with blasting, rock crushing, grading, site preparation, site finishing and building finishing would still occur . The emission would be reduced, since the overall footprint of disturbance would be less so less earthwork activity would be required.

Operational emissions under this alternative would be similar to the project, since a similar use is proposed, but since fewer residential units would be const ructed, area source emissions would be proportionally decreased. Vehicular emissions typically account for the largest portion of greenhouse gas emissions. Vehicular trips under the Reduced Footprint Alternative would be lower than the proposed project. Th is alternative would generate 736 ADT. Compared to the proposed project, which generates 1,208 ADT, this alternative would reduce ADT by 39%. As such, because this alternative would result in a decrease of ADT, air emissions would be reduced when compared to the proposed project and impacts would be less than significant.

Biological Resources
The Reduced Footprint Alternative would have a result in less site disturbance since a smaller area would be graded. This would result in less impact to vegetation, pr imarily nonnative grassland . This alternative would still have a potential to impact sensitive species, nesting birds, and have the potential to result in indirect impacts related to project construction. Biological resources mitigation measures identified for the proposed project would be applicable to this alternative (MM -BIO-1 through MM -BIO-4) and would reduce the impacts to below a level of significance. This Reduced Footprint Alternative would reduce the amount of nonnative grassland impacts compared to the proposed project. Similar to the proposed project, this alternative would reduce biological resources impacts to below a level of significance.

Cultural Resources
The Reduced Footprint Alternative would result in less ground disturbance as the proposed project.

However, the potential to impact unknown historical and archaeological resources potentially located within the project site as well as unidentified human remains would still occur. Cultural resources mitigation measures identified for the proposed project would be applicable to this alternative (MM - CR-1a, MM-CR-1b and MM-CR-2) and would reduce the impacts to below a level of significance. This Reduced Footprint Alternative would have a slighted reduced level of potential impacts to cultural resources compared to the project since less of the site would be graded.

Energy
Construction related energy demands would be similar as the proposed project. However, energy use associated with operation of the Reduced Footprint Alternative would be less co mpared to the proposed project since the number of units would be decreased from 151 units to 92 units.

Similarly, energy use associated with vehicle fuel would be reduced since this alternative would

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reduce the number of trips by 39%. Compared to the prop osed project, the Reduced Footprint Alternative reduces the amount of energy used and impacts would be less than significant.

Geology and Soils
Ground disturbance under the Reduced Footprint Alternative would be reduced compared to the proposed project. Development under this alternative would be subject to the same potential seismic hazards such as rupture of a known active fault or seismic ground shaking. Further, as discussed above, due to the underlying geology of the site, the same amount of blasting w ould be required under this alternative. This alternative would also require abiding by geological recommendations, such as the ones identified in the geotechnical evaluation. Compared to the proposed project, this alternative would result in the same level of impacts to geology and soils.

Greenhouse Gas Emissions
Under the Reduced Footprint Alternative, greenhouse gas emissions associated with project construction would still occur. Operational emissions under this alternative would be similar to the project, since a similar use is proposed. However, vehicular emissions typically account for the largest portion of greenhouse gas emissions. Vehicular trips under the Reduced Footprint Alternative would be lower than the proposed project. This alternative woul d generate between 736 ADT.

Compared to the proposed project, which generates 1,208 ADT, this alternative would reduce ADT by 39%. As such, because this alternative would result in a decrease of ADT on site, greenhouse gas would be reduced when compared to the proposed project and impacts would be less than significant.

Hazards and Hazardous Materials
The project site is currently vacant and is not listed on any hazardous materials sites. Construction and operation of this alternative would result in a simi lar level of hazards and hazardous materials risk as the proposed project since a similar type of use is proposed (residential use). Development under this alternative would not result in any safety hazards resulting from proximity to the McClellan-Palomar Airport, nor would this alternative impair implementation of or physically interfere with emergency response or evacuation plans . Development under this alternative would be constructed in accordance with all applicable fire codes and would incorporate an appropriate fire fuel modification zone. Impacts related to hazards and hazardous material would be less than significant for this alternative and would be similar to the proposed project.

Hydrology and Water Quality
The Reduced Footprint Alternative woul d result in ground disturbance to the site. As such, this alternative would introduce impervious surfaces at the site, though to a lesser degree compared to the project due to a reduced development footprint. The existing on -site hydrologic conditions, drainage patterns, and drainage volumes would be modified. It is expected that this alternative would also incorporate all required and applicable best management practices in order to avoid any violations of water quality standards or otherwise modify or adv ersely affect surface and groundwater quality. As compared to the proposed project, this alternative would result in similar impacts and the impacts would be less than significant.

4.0 Alternatives

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Land Use and Planning
Under the Reduced Footprint Alternative, a General Pl an Amendment and Rezone would still be required. The proposed project would result in significant impacts related to land use, specifically due to an inconsistency with policies in the Mobility Element of the General Plan that address LOS.

The proposed pro ject would result in significant and unavoidable impacts at intersection of Rancheros Drive/ SR -78 WB in the AM and PM peak hours under Near Term 2025 With Project condition. While the Reduced Footprint Alternative would decrease ADT by 39%, this impact wo uld still occur at this intersection as the existing LOS at this intersection is already below an acceptable level. Similarly, the significant impact identified for the project related to left -turn movements out of the project driveways would also be anticipated under this alternative and would be mitigated through driveway turn restrictions, similar to the mitigation identified for the project. In summary, this alternative would have a similar level of impact as the proposed project and would have significant and unavoidable land use impacts.

Noise
Construction-related noise under the Reduced Footprint Alternative is ex pected to result in a similar level of noise as the proposed project, since grading activities would still be required and similar types of equipment would be used. Blasting and rock crushing would still be required under this alternative and impacts ident ified for the project related to the staging location of rock drilling and noise from rock crushing activities would still be expected under this alternative. Mitigation measures identified for the project (MM-N-1 and MM-N-2) would be applicable to this alternative and would reduce potential construction-related noise impacts to below a level of significance.

Operational noise generated under the Reduced Footprint Alternative would be related to the noise generated on the project site from residential uses as well as trips generated by the project. Similar to the proposed project, significant impacts related to elevated noise levels associated with SR -78 and E. Barham Drive would be expected under this alternative. Mitigation measures, such as walls and/or berms, would be required to reduce the impact to below a level of significance. This is similar to what has been identified for the proposed project. It is expected that sound levels could be attenuated to below a level of significance, similar to the proposed project.

This alternative would generate less vehicular trips than the proposed project (39% reduction) .

Therefore, offsite noise generated by the project would be less under this alternative than the proposed project. Compared to the proposed project, this alternative would have a similar level of impact, with a reduction in offsite noise associated with vehicular traffic. Similar to the proposed project, all anticipated noise impacts could be mitigated to below a level of significance.

Population and Housing
The Reduced Footprint Alternative would result in an increase the population of the City by approximately 286 residents. The proposed project would increase the population by approximately 469 residents. However, this increase was determined to be less than significant. This alternative would create less market rate/work force housing on the project site compared to the proposed project. Compared to the proposed project, this alternative would have a similar level of impact and impacts would be less than significant.

4.0 Alternatives

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Public Services
Similar to the proposed project, the Reduced Footprint Alternative would result in an increase in demand for public services due to the construction of residential uses on the project site.

Specifically, this alternative would increase the demand for police and fire protection services, schools, as well as park, and library services ove r existing conditions. Compared to the proposed project, fewer students would be generated since fewer residential units would be constructed.

Development under this alternative would still be required to pay applicable Public Facilities Fees (PFF) and school fees. The amount of Public Facilities Fees (PFF) paid would be less than compared to the project since fewer residential uses would be constructed. Similarly, the amount of school fees paid to SMUSD would be less under this alternative. Similar to the proposed project, impacts would be less than significant.

Recreation
Similar to the proposed project, the Reduced Footprint Alternative would result in an increase in demand for park and recreation facilities. Development under this alternative would still be required to pay applicable Public Facilities Fees ( PFF) and school fees. Additionally, this alternative would be required to provide common open space and private open space per City requirements. Similar to the proposed project, impacts would be less than significant.

Transportation
Under the Reduced Footprint Alternative, impacts associated with consistency with policies in the Mobility Element of the General Plan that address LOS are still anticipated. The proposed project would result in significant and unavoidable impacts at the intersection of Rancheros Drive/ SR -78 WB in the AM and PM peak hours under Near Term 2025 With Project condition. While the Reduced Footprint Alternative would decrease ADT by 39%, this impact would still occur at this inte rsection due to its unacceptable LOS under existing condition. Given the site’s suburban location and proposal for residential uses under this alternative, Vehicles Miles Traveled ( VMT) impacts are still anticipated under this alternative and would remain significant and unavoidable. In summary, this alternative would have a similar level of impact as the proposed project and would have significant and unavoidable transportation impacts.

Tribal Cultural Resources
The Reduced Footprint Alternative would resu lt in less ground disturbance as the proposed project.

However, the potential to impact tribal cultural resources within the project site would still occur.

Cultural resources mitigation measures identified for the proposed project would be applicable to this alternative (MM-CR-1a, MM-CR-1b and MM-CR-2) and would reduce the impacts to below a level of significance. This Reduced Footprint Alternative would have a slighted reduced level of potential impacts to tribal cultural resources compared to the project since less of the site would be graded.

Utilities and Service Systems
The Reduced Footprint Alternative would result in an increase in utilities and service systems, including water, wastewater, stormwater infrastructure, and solid waste service through t he development of 92 residential units. However, compared to the project, this alternative would decrease the overall increase in demand since fewer residences would be constructed. Development under this alternative would still be required to pay all appl icable water and sewer fees. Storm water infrastructure is anticipated to be similar as the proposed project as a similar amount of impervious

4.0 Alternatives

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 4-24
surface would be created. Solid waste generated would be reduced under this alternative. Utilities and service sy stem impacts would be less than significant under the Reduced Footprint Alternative and would reduce water and sewer demand solid waste generation compared to the proposed project.

Conclusion
The Reduced Footprint Alternative would reduce the number of residential units constructed on the project site. This results in a corresponding decrease in vehicular trips by approximately 39% and a corresponding decrease in air and greenhouse gas emissions and noise from offsite traffic compared to the proposed pro ject. Public services, utilities and service systems, and energy demands would also proportionally decrease. Footprint specific impacts, such as those related to biological resources, cultural and tribal cultural resources, and geology and soils would be less than the proposed project since less ground disturbing activities would be required . The amount of Public Facilities (PFF) paid would be less than compared to the project since fewer residential uses would be constructed. Similarly, the amount of schoo l fees paid to SMUSD would be less under this alternative. This alternative would meet the majority of the project objectives as detailed in Table 4 -

1. 4.4 Alternatives Considered But Rejected
State CEQA Guidelines Section 15126.6(c) provides guidance in selecting a range of reasonable alternatives for the project. The EIR should also identify any alternatives that were considered by the lead agency, but were rejected during the planning or scoping process and briefly explain the reasons underlying the lead age ncy’s determination. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts. State CEQA Guidelines Section 15126.6(c) provides the following guidance in selecting a range of reasonable alternatives for the project. There are many factors that may be taken into account when addressing the feasibility of range of potential alternatives for the project, such as site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, contro l, or otherwise have access to the alternative site (or the site is already owned by the proponent). The alternatives discussion shall include those that could feasibly accomplish most of the basic objectives of the project, and could avoid or substantiall y lessen one or more of the significant effects. The EIR should also identify any alternatives that were considered by the lead agency, but were rejected during the planning or scoping process and briefly explain the reasons underlying the lead agency's determination.

The EIR need not discuss every alternative to the project. A range of alternatives that are “reasonable” for analysis have been evaluated and are discussed above in Section 4.3, Project Alternatives Considered in this EIR. The following descri bes other alternatives considered by the City but dismissed from further evaluation in this EIR, and a brief description of the reasons for their rejection.

4.4.1 Alternative Location
Pursuant to Section 15126.6(f)(2) of the CEQA Guidelines, the City considered the potential for alternative locations to the project. There are sites within the City of an approximately equivalent size to the project site that could be redeveloped with a residential project; however, the project applicant

4.0 Alternatives

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 4-25
does not control another si te within the City of comparable land area that is available for development of the proposed project. One of the factors for feasibility of an alternative is “whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.” Because the City is highly urbanized and is largely built out, obtaining another site of a similar size in a similar location is not considered feasible. It should also be noted that the project site is surrounded by development and located adjacent to existing transportation and utility infrastructure.

As such, an alternative location was ultimately rejected from further analysis in the EIR.

4.5 Environmentally Superior Alternative
Table 4 -2 provides a qualitative comparison of the impacts for each alt ernative compared to the proposed project. As shown in Tables 4-1 and 4-2, the No Project/No Development Alternative would eliminate all of the significant impacts identified for the project. However, the No Project/No Development Alternative would not mee t any of the project objectives. Additionally, there is no certainty that the project site would remain undeveloped in perpetuity. CEQA Guidelines Section 15126.6(e)(2) states that if the No Project alternative is identified as the environmentally superior alternative, then an environmentally superior alternative should be identified among the other alternatives.

Among the other alternatives, not including the proposed project, the Reduced Footprint Alternative is the environmentally superior alternative be cause it would provide a reduced level of impact in some environmental analysis areas including air quality, greenhouse gas, noise, public services, recreation, and utilities/service systems. Additionally, footprint specific impacts, such as those related to cultural and tribal resources, biological resources, and geology and soils would be reduced compared to the proposed project, since less ground disturbing activities would be required.

Mitigation measures would still be required to mitigate impacts to b iological resources, cultural resources, geology and soils, noise, tribal cultural resource, and land use (partially mitigated).

Due to the project site being located in a suburban setting and the limited options available to mitigate Vehicle Miles Travele d ( VMT) impacts for residential projects , the Reduced Footprint Alternative would still result in significant and unavoidable transportation impacts due to Vehicle Miles Traveled (VMT). Similarly, due to existing degraded LOS at the intersection of Rancheros Drive/ SR-78 WB, this alternative would still result in significant and unavoidable impacts in the AM and PM peak hours under Near Term 2025 With Project condition. Even though payment of funds to the City’s Congestion Management Community Facilities Di strict ( CFD) and Public Facilities Fees (PFF) that addresses congestion would occur, the needed improvements at this intersection to improve LOS are within Caltrans jurisdiction, not the City’s. Therefore, the City cannot control the timing of the installation of the improvements and it cannot be conclusively stated that the intersection improvements would be in place in time. Thus, the inconsistency with policies in the Mobility Element related to LOS will remain and the significant and unavoidable land use and transportation impacts would still occur under the Reduced Footprint Alternative.

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 4-26

Table 4-1. Summary of Alternatives and Project Objectives Objective Proposed
Project
No Project/No
Development
No Project/Existing
Land Use
Alternative
Reduced Density
Alternative
Reduced
Footprint
Alternative
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.

Meets
objective
Does not meet
this objective
Does not meet this
objective
Meets objective Meets objective
To the extent possible given the site constraints,
maximize the opportunity to provide medium-
density housing for the City of San Marcos in the

12.1-15.0 dwelling unit density range which
comparable to other medium-density housing
developments near the Specific Plan Area.

Meets
objective
Does not meet
this objective
Does not meet this
objective
Does not meet
this objective
Does not meet
this objective
Create a development which accommodates
appropriate recreational open space for the
anticipated residents expected to reside within
the Specific Plan Area.

Meets
objective
Does not meet
this objective
Does not meet this
objective
Could be
designed in a
manner that
meets this
objective
Could be
designed in a
manner that
meets this
objective
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.

Meets
objective
Does not meet
this objective
Could be designed
in a manner that
meets this
objective
Could be
designed in a
manner that
meets this
objective
Could be
designed in a
manner that
meets this
objective

4.0 Alternatives

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 4-27
Objective Proposed
Project
No Project/No
Development
No Project/Existing
Land Use
Alternative
Reduced Density
Alternative
Reduced
Footprint
Alternative
Design a safe and efficient 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.

Meets
objective
Does not meet
this objective
Could be designed
in a manner that
meets this
objective
Could be
designed in a
manner that
meets this
objective
Could be
designed in a
manner that
meets this
objective
Develop a financing plan that provides for the
efficient and timely provision of infrastructure
and public services prior to and as development
occurs.

Meets
objective
Does not meet
this objective
Could be designed
in a manner that
meets this
objective
Could be
designed in a
manner that
meets this
objective
Could be
designed in a
manner that
meets this
objective
Implement a maintenance program which will
ensure all common areas are maintained to
standards set forth in the City’s General Plan.

Meets
objective
Does not meet
this objective
Could be designed
in a manner that
meets this
objective
Could be
designed in a
manner that
meets this
objective
Could be
designed in a
manner that
meets this
objective
Finance and/or contribute to all appropriate
community and citywide infrastructure as
warranted.

Meets
objective
Does not meet
this objective
Meets objective Meets objective
but would
contribute less
compared to the
proposed
project.

Meets objective
but would
contribute less
compared to the
proposed
project.

4.0 Alternatives

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 4-28
Table 4-2. Comparison of Impacts of Proposed Project and Alternatives Environmental Topic Proposed
Project
No Project/No
Development
Alternative
No Project/Existing Land Use
Designation Alternative
Reduced Density
Alternative
Reduced
Footprint
Alternative
Aesthetics LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Same)
LTS
(Same)
Air Quality LTS No Impact
(Reduced)
LTS
(Increased)
LTS
(Reduced)
LTS
(Reduced)
Biological Resources LTSM No Impact
(Reduced)
LTSM
(Same)
LTSM
(Same)
LTSM
(Reduced)
Cultural Resources LTSM No Impact
(Reduced)
LTSM
(Same)
LTSM
(Same)
LTSM
(Reduced)
Energy LTS No Impact
(Reduced)
LTSM
(Increased)
LTSM
(Reduced)
LTSM
(Reduced)
Geology and Soils LTSM No Impact
(Reduced)
LTSM
(Same)
LTSM
(Same)
LTSM
(Reduced)
Greenhouse Gas Emissions LTS No Impact
(Reduced)
LTS
(Increased)
LTS
(Reduced)
LTS
(Reduced)
Hazards and Hazardous
Materials LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Same)
LTS
(Same)
Hydrology and Water Quality LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Same)
LTS
(Same)
Land Use and Planning SU No Impact
(Reduced)
SU
(Same)
SU
(Same)
SU
(Same)
Noise LTSM No Impact
(Reduced)
LTSM
(Increased)
LTSM
(Reduced)
LTSM
(Reduced)
Population and Housing LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Same)
LTS
(Same)
Public Services LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Reduced)
LTS
(Reduced)

4.0 Alternatives

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 4-29
Environmental Topic Proposed
Project
No Project/No
Development
Alternative
No Project/Existing Land Use
Designation Alternative
Reduced Density
Alternative
Reduced
Footprint
Alternative
Recreation LTS No Impact
(Reduced)
No Impact
(Reduced)
LTS
(Reduced)
LTS
(Reduced)
Transportation SU No Impact
(Reduced)
SU
(Reduced for VMT, Increased for
ADT generation)
SU
(Same)
SU
(Same)
Tribal Cultural Resources LTSM No Impact
(Reduced)
LTSM
(Same)
LTSM
(Same)
LTSM
(Reduced)
Utilities and Service Systems LTS No Impact
(Reduced)
LTS
(Reduced)
LTS
(Reduced)
LTS
(Reduced)
Notes: Impact Status: LTS = Less than significant impact; LTSM = Less than significant with mitigation; SU = Significant and unavoidable

4.0 Alternatives

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 4-30
Figure 4.3-1. No Project/Existing Land Use Designation Alternative

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 5-1

5.0 Environmental Effects Found not to be Significant
The City of San Marcos completed an Initial Study for the proposed project in accordance with Sections 21000 -21189 of the Public Resources Code and Section 15063 of the California Environmental Quality Act (CEQA) Guidelines. A Notice of Preparation (NOP) was p repared by the City and mailed to applicable agencies, organizations, and neighboring property owners. The NOP is included in Appendix C.19
As required by Section 15128 of the CEQA Guidelines, the following is a discussion of the environmental effects that were considered as a part of the Initial Study but were determined to have “No Impact”, and, therefore, are not discussed in detail in the Environmental Impact Report (EIR).

In some instances, complete environmental issue areas were eliminated during the NOP process, including agriculture/forestry resource s and mineral resources . In other instances, some of the specific CEQA thresholds were eliminated during the Initial Study process.

5.1 Agriculture and Forestry Resources
Threshold of Significance : Convert Pr ime Farmland, Unique Farmland, or Farmland o f Statewide Importance (Farmland) as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non -agricultural use.

The project site is not mapped as prime farmland, unique farmland, or farmland of statewide importance, as determined by the Farmland Mapping and Monitoring Program, as shown on Figure 4-4 (Agricultural Areas) in the San Marcos General Plan (San Marcos 2012) . Therefore, the project would not result in the conversion of prime farmland, unique farmland, or farmland of statewide importance. No impact is identified for this issue area.

Threshold of Significance : Conflict with existing zoning for agricultural use, or a Williamson Act contract.

The project site has a General Plan designation of Mixed Use 3 (MU3) and a zoning designation of Mixed‐Use‐3 (MU‐3). The project site does not support zoning for an agricultural use. The Williamson Act, also known as the California Land Conservation Act of 1965, enables local governments to enter into contracts with private landowners for the purpose of restricting s pecific parcels of land to agricultural or related open space use. In return, landowners receive property tax assessments which are much lower than normal because they are based upon farming and open space uses as opposed to full market value. The project site is not located within a Williamson Act contract area. Therefore, the project would not conflict with existing zoning for agricultural use or a Williamson Act contract.

19 The Initial Study, NOP, and comment letters received on the NOP are included in Appendix B and C of this EIR.

5.0 Environmental Effects Found not to be Significant
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 5-2
Threshold of Significance: Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)).

Forest land is defined as “land that can support ten percent native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality , recreation, and other public benefits” (California Public Resources Code Section 1220(g)). Timberland is defined as “land, other than land owned by the federal government and land designated by the board as experimental forest land, which is available for, and capable of, growing a crop of trees of a commercial species used to produce lumber and other forest products, including Christmas trees” (California Public Resources Code Section 4526). A Timberland Production Zone is defined as “an area which has b een zoned pursuant to Section 51112 or 51113 and is devoted to and used for growing and harvesting timber, or for growing and harvesting timber and compatible uses” (California Public Resources Code Section 51104(g)).

The project site has a General Plan de signation of Mixed Use 3 (MU3) and a zoning designation of Mixed‐Use‐3 (MU‐3). A General Plan Amendment and Rezone is proposed for the project to change these designations to Specific Plan Area (SPA). The proposed project is not located in an area that is zoned for forest land, timber land or for timber production. Implementation of the proposed project would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production. No impact is identified and this topic.

Threshold of Significance : Result in the loss of forest land or conversation of forest land to non - forest use.

The project site does not support forests, nor is there any forest land adjacent to the project site. The project site is deve loped. Therefore, the proposed project would not result in the loss of forest land or the conversion of forest land to non‐forest use. No impact is identified for this issue area.

Threshold of Significance: Involve other changes in the existing environment that, due to their location or nature, could result in conversion of Farmland, to non -agricultural use or conversion of forest land to non-forest use.

The project would not result in any other changes to the existing environment that would, due to their location or nature, results in the conversion of Farmland, to non ‐agricultural use or conversion of forest land to non ‐forest use. There is no agricultural activity on the project site. No impact is identified for this issue area.

5.2 Geology and Soils
Threshold of Significance : Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of wastewater.

Septic tanks and alternative wastewater disposal systems are not proposed as part of the project.

The project will receive wastewater service from Vallecitos Water District (VWD) and VWD has indicated they can serve the project (VWD 2020). Therefore, no impact is identified for this issue area.

5.0 Environmental Effects Found not to be Significant
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 5-3
A discussion of additional geology and soils significance thresholds is provided in Section 3.6., Geology and Soils.

5.3 Hydrology and Water Quality
Threshold of Significance : In flood hazards, tsunami or seiche zones, risk release of pollutants due to project inundation.

Per the Federal Emergency Management Agency’s (FEMA) Flood Insurance Rate Map Numbers 06073C1052G and 6073C1055G, the project site is not located within a 100- year flood hazard area (FEMA 2012). The project site is approximately 6.5 miles inland from the Pacific Ocean and would not be subject to inundation by tsunami. Given that the project site is not located near a large standing body of water, inundation by seiche (or standing wave) is considered negligible. No impact is identified for this issue area.

A discussion of additional hydrology and water quality significance thresholds is provided in Section

3.9, Hydrology and Water Quality.

5.4 Land Use and Planning
Threshold of Significance: Physically divide an established community The project site is currently undeveloped. The project proposes residential uses in an area that is already developed with similar uses, and as such, would be compatible with existing uses. The project would not physically divide an established com munity. No impact is identified for this issue area.

A discussion of additional land use and planning significance thresholds is provided in Section 3.10, Land Use and Planning.

5.5 Mineral Resources
Threshold of Significance : Result in the loss of availabilit y of a known mineral resource that would be of value to the region and the residents of the state According to the City of San Marcos General Plan Conservation & Open Space Element, the City has land classified in all four Mineral Resource Zones (MRZ) (Cit y of San Marcos 2013). California does not require that local governments protect land designated as MRZ ‐1, MRZ‐3, or MRZ ‐4. However, the City is responsible for recognizing lands designated as MRZ ‐2 and protecting these areas from premature development incompatible with mining. The lands designated as MRZ ‐2 include small portions between Double Peak, Mt. Whitney, and Franks Peak; and small portions in the northern Sphere of Influence within Twin Oaks Valley Neighborhood. These locations do not overlap with the proposed project site; therefore, no loss of known mineral resources would occur. No impact would occur.

Threshold of Significance : Result in the loss of availability of a locally -important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan The proposed project site is not designated as a locally important mineral resource recovery site on any local general plan, specific plan, or other land use plan (City of San Marcos 2013). Due to t he location and the nature of the proposed project, there would be no impact to mineral resources.

5.0 Environmental Effects Found not to be Significant
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 5-4

5.6 Noise
Threshold of Significance : For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project are to excessive noise levels?
The proposed project is not located within the vicinity of a private airstrip . The public airport closest to the project site is the McClellan -Palomar Airport, located approximately 7.5 miles to the west .

According to the ALUCP for the McClellan -Palomar Airport, the project site is not located within the existing or future 60 dB CNEL noise contour of the airport (San Diego County Regional Airport Authority 2011). Therefore, people residing or working in the project ar ea would not be exposed to substantial airport noise. This topic will not be analyzed in the EIR.

5.7 Population and Housing
Threshold of Significance : Displace substantial numbers of existing housing or people, necessitating the construction of replacement housing elsewhere
There is no existing housing on the project site. Therefore, the project will not remove existing housing. The project proposes 151 housing units which would add to the housing stock in the City.

No impact is identified for this issue area.

A discussion of additional population and housing significance thresholds is provided in Section

3.12, Population and Housing.

5.8 Wildfire
Threshold of Significance : A significant wildfire would be identified if the project was located in or near a state responsibility area or lands classified as very high fire hazard severity zone and would:
• Substantially impair an adopted emergency response plan or emergency evacuation plan; • Due to slope, prevailing wind, and other factors exacerbate wildlife risk, and thereby, expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of wildfire;
• Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; or • Expose people or structure to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability or drainage changes.

The project site is not located in or near a State Responsibility Area (SRA) nor is the site on or n ear lands classified as a very high fire hazard severity zone. SRA is the area of the state where the State of California is financially responsible for the prevention and suppression of wildfires. SRA does not include lands within city boundaries or in federal ownership. As such, the project site is located in a Local Responsibility Area and fire services are provided by the San Marcos Fire Department.

The project site is located within 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

5.0 Environmental Effects Found not to be Significant
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 5-5
areas also identified as 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 t o further minimize fire risk to the proposed development . The existing highly developed areas and development of the project site would not exacerbate wildfire risk with respect to exposure of project occupants to pollutant concentrations from a wildfire, uncontrolled spread of wildfire, or alter post - fire slope stability. The project would also not require the installation or maintenance of associated infrastructure that may exacerbate fire risk. Thus, the proposed project would result in less than significant impacts related to wildfire.

Threshold of Significance : Displace substantial numbers of existing housing or people, necessitating the construction of replacement housing elsewhere
There is no existing housing on the project site. Therefore, the project will not remove existing housing. The project proposes 151 housing units which would add to the housing stock in the City.

No impact is identified for this issue area.

A discussion of additional population and housing significance thresholds is provided in Section

3.12, Population and Housing.

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 6-1

6.0 Other CEQA Considerations

6.1 Significant and Unavoidable Impacts
California Environmental Quality Act (CEQA) Guidelines, Section 15126.2(b), requires that a n Environmental Impact Report (EIR) describe any significant impacts that cannot be avoided, including those impacts that can be mitigated but not reduced to a less -than-significant level.

Chapter 3, Environmental Analysis, of this EIR describes the potent ial environmental impacts of the proposed project and recommends mitigation measures to reduce impacts, where feasible.

As discussed in this EIR, implementation of the proposed project would result in significant and unmitigated impacts related to land use and transportation, as detailed below:
• Impact LU -1: Inconsistency with Mobility Element (Rancheros Drive/SR -78 WB – Near Term 2025 During AM and PM Peak Hour exceeds acceptable LOS) • Impact TR-1: Conflict with Policies Addressing Roadways • Impact TR-2: Vehicle Miles Traveled
These significant impacts cannot be mitigated to a less than significant level, and therefore, are considered significant and unavoidable impacts. Refer to Section 3.10, Land Use and 3.15, Transportation, of this EIR for additional information.

6.2 Growth Inducement
Section 15126.2(d) of the CEQA Guidelines mandates that the growth inducing nature of a proposed project be discussed. This CEQA Guideline states the growth-inducing analysis is intended to address the potential for the proposed p roject to “foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment.” Further, the CEQA Appendix G Checklist (Population and Housing) also mandates that a CEQA document s peak to the proposed project’s likelihood to induce substantial population growth in an area, either directly (e.g., by proposing new homes or businesses) or indirectly (e.g., through extension of roads or other infrastructure).

A project may be distinguis hed as either facilitating planned growth or inducing unplanned growth.

Facilitating growth is related to the establishment of direct employment, population, or housing growth that would occur within a project site. Inducing growth is related to lowering or removing barriers to growth or by creating an amenity or facility that attracts new population/economic activity.

For purposes of this EIR analysis, a significant growth inducement impact would occur if the proposed project, and associated infrastructure improvements, directly or indirectly removes obstacles to growth such that the induced growth would significantly burden existing community services, the environment or cause a demand for General Plan Amendments. This section contains a discussion of the growth inducing factors related to the proposed project and as defined under CEQA Guidelines, Section 15126.2(d). A project is defined as growth inducing when it directly or indirectly:
• Fosters population growth;
• Includes the construction of additional housing in the surrounding environment;

6.0 Other CEQA Considerations

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 6-2
• Removes obstacles to population growth;
• Taxes existing community service facilities, requiring construction of new facilities that could cause significant environmental effects; and/or
• Encourages or facilitates other activities that could significantly affect the environments, either individually or cumulatively.

It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.

As discussed in Section 3.12, Population and Housing, of the EIR, the proposed project would directly induce growth through the development of 151 multi -family residential dwelling units, resulting in a gross density of approximately 1 4.3 dwelling units pe r 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, indirect ly 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 surrounding 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. Th erefore, the project’s induced population would exceed these projections. However, determination of impacts related to population growth are based upon whether the induced growth would be considered substantial.

As shown in Table 3.12 -2, the City’s populat ion is projected to grow from 98,9 15 people in 2020 to 109,095 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 av ailable 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 that there are adequate sites available with appropriate designations/zoning to accommodate the remaining RHNA allocation for the current Housing Element planning p eriod, the City has the discretion to adjust allocated housing units/sites as necessary to balance proposed plans for residential development with approved/constructed residential 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.

6.3 Significant Irreversible Environmental Changes
CEQA Guidelines, Section 15126.2(c), r equires that an EIR identify any significant irreversible environmental changes associated with the proposed project. Such changes include, for example, the intensification of land use or irreversible damage from environmental accidents associated with the proposed project.

Implementation of the proposed project would result in irreversible environmental changes. Approval of the project would involve the development of 151 multi- family residential units and associated open space and infrastructure improveme nts. Development would result in direct impacts to

6.0 Other CEQA Considerations

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 6-3
biological resources through the removal of vegetation (see Section 3.3). Although mitigated to a less-than-significant level, such impacts would be considered irreversible.

Further, construction and/or op eration of the proposed project would require the use of resources that include, but are not limited to, soils, gravel, concrete, and asphalt, lumber and other related forest products, petrochemical construction materials, steel, copper, and other metals, water, fuels, and energy. As such, the proposed project would result in the short -term and long-term use of fossil fuels and other nonrenewable resources.

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 7-1

7.0 References
Project Description (Section 2.0)
City of San Marcos. 2012. City of San Marcos General Plan, Land Use and Community Design Element. Adopted February 14.
https://www.san-marcos.net/home/showpublisheddocument/8480/636570701878000000 Viewed May 24, 2021
City of San Marco 2021. Zoning Ordinance, Section 20.225.060- Mixed Use 3 (SP) Zone. Adopted November 13, 2012. Last Supplemented March 31, 2021.
https://library.municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20. 225MIUSZO_S20.225.060MIUS3SPZO Viewed May 24, 2021
GEOCON Incorporated. 2020. Phase I and Phase II Environmental Site Assessment (ESA Report), 943 Barham Drive San Marcos, California. March 9. Appendix I.

Rincon del Diablo Municipal Water District (RDDMWD) 2021. Letter from Karen Falk, Engineering Manager. April 6. Appendix N.2
Rocks Biological Consulting (RBC).2020a. Barham Drive Residential Project Biological Technical Report. October 27. Appendix E.1
Vallecitos Water District (VWD). 2020. Hallmark - Barham Water and Sewer Study. Work Order #234061. Final Technical Memorandum. October 23. Appendix N.1 Aesthetics (Section 3.1)
ASM Affiliates. 2020. Cultural Resources Inventory for the East Barham Residential Project, San Marcos, San Diego County, California. November 3. Appendix F.1.

ASM Affiliates. 2021. Archaeological Significance Evaluation for the Barham Residential Project, San Marcos, San Diego County, California. April. Appendix F.2.

Caltrans (California Department of Transportation). 2011. Officially Designated State Scenic Highways. https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community- livability/lap-liv-i-scenic-highways Viewed May 24, 2021.

City of San Marcos. 2012. City of San Marcos General Plan, Conservation and Open Space Element.

Adopted February 14.
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City of San Marcos. 2021a. Zoning Ordinance, Section 20.300.080- Light and Glare Standards.

Adopted November 13, 2012, Last Supplemented March 31, 2021. https://library.municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20. 300SIPLGEDEST_S20.300.080LIGLST Viewed May 24, 2021

7.0 References
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 7-2
City of San Marcos. 2021b. Zoning Ordinance, Section 20.260-Ridgeline Protection & Management Overlay Zone.
https://library.municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO Viewed May 24, 2021
Rocks Biological Consulting (RBC).2020a. Barham Drive Residential Project Biological Technical Report. October 27. Appendix E.1
United States Census Bureau (USCB). 2019. Quick Facts Escondido City, San Marcos City, California, United States.
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Air Quality (Section 3.2)
California Air Resources Board (CARB). 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October 2000. https://ww2.arb.ca.gov//sites/default/files/classic/diesel/documents/rrpfinal.pdf Viewed March 25, 2021
California Air Resources Board (CARB). 2016. Ambient Air Quality Standards. May 4. http://www.arb.ca.gov/research/aaqs/aaqs2.pdf Viewed March 23, 2021.

LDN Consulting. 2021a. Air Qu ality Assessment, East Barham Residential Development Project, City of San Marcos, CA. September 23. Appendix D
Office of Environmental Health Hazards Assessment (OEHHA). 2015. Air Toxics Hot Spots Program - Risk Assessment Guidelines - Guidance Manual for Preparation of Health Risk Assessments.

February. https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf Viewed March 25, 2021
San Diego Air Pollution Control District (SDAPCD). 1976. Regulation IV; Rule 51: Public Nuisance. https://www.sdapcd.org/content/dam/sdc/apcd/PDF/Rules_and_Regulations/Prohibitions/APCD_ R50-1-51.pdf Viewed March 25, 2021
San Diego Air Pollution Control District (SDAPCD). 1996. Regulation XII; Rule 1210: Toxic Air Contaminant Public Health Risks- Public Notification and Risk Reduction. https://www.sdapcd.org/content/dam/sdc/apcd/PDF/Rules_and_Regulations/Toxic_Air_Cotaminan ts/APCD_R1210.pdf Viewed March 25, 2021
San Diego Air Pollution Control District (SDAPCD). 1998. Regulation II; Rule 20.2: New Source Review Non-Major Stationary Sources.
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2.pdf Viewed March 25, 2021
San Diego Air Pollution Control District (SDAPCD). 2005. Measures to Reduce Particulate Matter in San Diego County. December.
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7.0 References
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San Diego Air Pollution Control District (SDAPCD). 2016. 2016 Regional Air Quality Strategy for San Diego County. December.
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San Diego Air Pollution Control District (SDAPCD). 2020. 2020 Plan for Attaining the National Ambient Air Quality Standards for Ozone in San Diego County. October. https://www.sandiegocounty.gov/content/dam/sdc/apcd/PDF/Air%20Quality%20Planning/Att%20A %20(Attainment%20Plan)_ws.pdf Viewed March 25,2021
San Diego Air Pollution Control District (SDAPCD). 2021. Attainment Status. https://www.sdapcd.org/content/sdc/apcd/en/air-quality-planning/attainment-status.html Viewed March 23, 2021.

United States Environmental Protection Agency (USEPA). 1995. EPA-AP 42, Fifth Edition Compilation of Air Pollutant Emission Factors. https://www.epa.gov/air-emissions-factors-and-quantification/ap- 42-compilation-air-emissions-factors Viewed March 25, 2021 United States Environmental Protection Agency (USEPA). 2017. Volatile Organic Compounds’ Impact on Indoor Air Quality.
https://www.epa.gov/indoor-air-quality-iaq/volatile-organic-compounds-impact-indoor-air-quality Viewed March 25,2021
Biological Resources (Section 3.3)
Baldwin, B.G., D.H. Goldman, D.J. Keil, R. Patterson, and T.J. Rosatti (eds). 2012. The Jepson Manual:

Vascular Plants of California, Second Edition, Thoroughly Revised and Expanded. University of California Press, Berkeley, California. 1400 pp.

City of San Marcos. 2001. Natural Community Conservation Plan for the City of San Marcos. San Marcos Subarea Plan Public Review Draft.
https://www.sandag.org/uploads/publicationid/publicationid_153_8102.pdf Viewed March 25,2021
City of San Marcos. 2012. City of San Marcos General Plan, Conservation and Open Space Element.

Adopted February 14.
https://www.san-marcos.net/home/showpublisheddocument/8478/636597348039500000 Viewed May 24, 2021
SANDAG. 2003. North County Multiple Habitat Conservation Program. https://www.sandag.org/index.asp?projectid=97&fuseaction=projects.detail Viewed March 25,2021 Helix Environmental Planning, Inc. (HELIX). 2020. Jurisdictional Findings for 943 Barham Drive Project Site, San Marcos, CA. Memorandum. May 27. Appendix E.4.

Holland, R. F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California.

Unpublished document, California Department of Fish and Game, Natural Heritage Division.

Sacramento, CA.

7.0 References
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Rocks Biological Consulting (RBC). 2020a. Barham Drive Residential Project Biological Technical Report. October 27. Appendix E.1
Rocks Biological Consulting (RBC). 2020b. 45-Day Report for Coastal California Gnatcatcher Surveys for the Barham Drive Residential Project, City of San Marcos, San Diego, California. July 15. Appendix E.2
Rocks Biological Consulting (RBC).2020c. Special-Status Plant Survey Results for the Barham Drive Residential Project, San Marcos, California. June 17. Appendix E.3 U.S. Fish and Wildlife Service (USFWS). 1997. Coastal California Gnatcatcher (Polioptila californica californica) Presence/Absence Survey Protocol. 5 pages. https://www.fws.gov/ventura/docs/species/protocols/cagn/coastal-gnatcatcher_survey- guidelines.pdf Viewed May 24, 2021
Cultural Resources (Section 3.4)
ASM Affiliates. 2020. Cultural Resour ces Inventory for the East Barham Residential Project, San Marcos, San Diego County, California. November 3. Appendix F.1 ASM Affiliates. 2021. Archaeological Significance Evaluation for the Barham Residential Project, San Marcos, San Diego County, California. April. Appendix F.2 Parker, P.L. and T.F. King. 1998. National Register Bulletin 38: Guidelines for the Evaluation and Documentation of Traditional Cultural Properties. National Register of Historic Places, U.S. National Park Service. https://www.nps.gov/subjects/nationalregister/upload/NRB38-Completeweb.pdf Viewed May 25, 2021
United States Census Bureau (USCB). 2019. Quick Facts Escondido City, San Marcos City, California, United States.
https://www.census.gov/quickfacts/fact/table/escondidocitycalifornia,sanmarcoscitycalifornia,US/P ST045219 Viewed 5/24/21
Energy (Section 3.5)
California Air Pollution Control Officers Association (CAPCOA). 2010. Quantifying Greenhouse Gas Mitigation Measures. August
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California Air Resources Board (CARB). 2012. California Air Resources Board Approves Advanced Clean Car Rules. https://ww2.arb.ca.gov/news/california-air-resources-board-approves-advanced- clean-car-rules Viewed March 27,2021.

California Air Resources Board (CARB). 2013. California’s Greenhouse Gas Vehicle Emission Standards under Assembly Bill 1493 of 2002 (Pavley) Accessed December 2017. http://arb.ca.gov/cc/ccms/ccms.htm.

California Air Resources Board (CARB). 2018. EMFAC 2017 Web Database (v1.0.2). https://www.arb.ca.gov/emfac/2017/ Viewed June 4, 2021

7.0 References
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California Department of Transportation (CALTrans). 2009. 2008 California Motor Vehicle Stock, Travel and Fuel Forecast. June. http://www.energy.ca.gov/2008publications/CALTRANS-1000-2008- 036/CALTRANS-1000-2008-036.PDF. Viewed June 4, 2021.

California Energy Commission (CEC). 2014 California Energy Demand Updated Forecast, 2015–2025. December. https://www.dtsc-ssfl.com/files/lib_ceqa/ref_draft_peir/Chap4_13- EnergyConsump/68441_CEC-200-2014-009-SD.pdf Viewed May 6, 2021 California Energy Commission (CEC). 2015. “2016 Building Energy Efficiency Standards Frequently Asked Questions.”
https://www.energy.ca.gov/sites/default/files/201905/2016_Building_Energy_Efficiency_Standard s_FAQ.pdf Viewed May 4, 2021
California Energy Commission (CEC). 2017. 2016 Weekly Fuels Watch Report. http://www.energy.ca.gov/almanac/petroleum_data/fuels_watch/reports/2016_Weekly_Fuels_Wat ch_RPT.xlsx. Accessed December 2017.

California Energy Commission (CEC). 2018. “2019 Building Energy Efficiency Standards Frequently Asked Questions.” March
https://www.energy.ca.gov/sites/default/files/2020-
03/Title_24_2019_Building_Standards_FAQ_ada.pdf Viewed May 4, 2021 California Energy Commission (CEC). 2019. California Energy Consumption Databased. Accessed May 6, 2019. http://www.ecdms.energy.ca.gov/elecbycounty.aspx California Public Utility Commission (CPUC). 2016. Biennial RPS Program Update. January 1. file:///C:/Users/melys/Downloads/FINAL%2012302015%20Section%20913_6%20Report%20(4).p df Viewed May 6,2021
California Public Utility Commission (CPUC). 202 1. Natural Gas and California. https://www.cpuc.ca.gov/natural_gas/ Viewed May 5,2021 LDN Consulting, Inc. 2021b. Greenhouse Gas Assessment, East Barham Residential Development Project. City of San Marcos, CA. November 17. Appendix H.1 San Diego Gas & Electric (SDG&E). 2018. 2018 Individual Integrated Resource Plan of San Diego Gas & Electric Company. August 1 . https://www.sdge.com/sites/default/files/regulatory/R.16-02- 007%20SDGE%20IRP%202018%20Plan%20Final.pdf Viewed May 10,2021 San Diego Gas & Electric (SDG&E). 2021. Our Company. https://www.sdge.com/more- information/our-company Viewed May 4, 2021.

The Climate Registry. 2018. Default Emission Factors. May 1. https://www.theclimateregistry.org/wp-content/uploads/2018/06/The-Climate-Registry-2018- Default-Emission-Factor-Document.pdf Viewed May 11, 2021 Geology and Soils (Section 3.6)
California Department of Conservation 2019.EQ Zapp: California Earthquake Hazards Zone Application. April 4. https://maps.conservation.ca.gov/cgs/EQZApp/app/ Accessed May 26, 2021

7.0 References
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California Geological Survey (CGS), 2002, California Geomorphic Provinces Note 36, Electronic Copy, Revised December 2002. https://www.contracosta.ca.gov/DocumentCenter/View/34134/CGS- 2002-California-Geomorphic-ProvincesNote-36-PDF Viewed March 21, 2021 City of San Marcos. 2012. City of San Marcos General Plan, Safety Element. Adopted February 14. https://www.san-marcos.net/home/showpublisheddocument/8476/636573113845230000 Viewed May 24, 2021
County of San Diego. 2009. Guidelines for Determining Significance for Paleontological Resources.

Modified January 15, 2009. https://www.sandiegocounty.gov/dplu/docs/Paleo-Guidelines.pdf.

Viewed March 21, 2021
GEOCON. 2020. Geotechnical Investigation – 943 Barham Drive San Marcos, California. June 17.

Appendix G.

Kennedy, M.P., and S.S. Tan, 2007, Geologic Map of the San Diego 30’ x 60’ Quadrangle, California, California Geological Survey, Regional Geologic Map Series No. 3, scale 1:100,000. https://www.conservation.ca.gov/cgs/Documents/Publications/Regional-Geologic- Maps/RGM_002/RGM_002_Oceanside_2007_Pamphlet.pdf Viewed March 22, 2021 Greenhouse Gas (Section 3.7)
California Air Resources Board (CARB). 2012. California Air Resources Board Approves Advanced Clean Car Rules. https://ww2.arb.ca.gov/news/california-air-resources-board-approves-advanced- clean-car-rules Viewed March 27,2021.

California Air Resources Board (CARB). 2014. First Update to the AB 32 Scoping Plan. May. https://ww2.arb.ca.gov/sites/default/files/classic//cc/scopingplan/2013_update/first_update_cli mate_change_scoping_plan.pdf Viewed March 27,2021.

California Air Resources Board (CARB). 2017. California’s 2017 Climate Change Scoping Plan.

November. https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf Viewed March 27,2021
California Air Resources Board (CARB). 2021a. Advanced Clean Car Program. https://ww2.arb.ca.gov/our-work/programs/advanced-clean-cars-program/about Viewed March 27,2021.

California Air Resources Board (CARB). 2021b. Senate Bill 375 Regional Plan Climate Targets. https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-program/regional-plan-targets Viewed March 27,2021
California Energy Commission (CEC). 2015. “2016 Building Energy Efficiency Standards Frequently Asked Questions.” https://www.energy.ca.gov/sites/default/files/2019- 05/2016_Building_Energy_Efficiency_Standards_FAQ.pdf Viewed May 4, 2021 California Energy Commission (CEC). 2018. “2019 Building Energy Efficiency Standards Frequently Asked Questions.” March https://www.energy.ca.gov/sites/default/files/2020- 03/Title_24_2019_Building_Standards_FAQ_ada.pdf Viewed May 4, 2021

7.0 References
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 7-7
California Public Utilities Commission (CPUC). 2016. Biennial RPS Program Update - In Compliance with Public Utilities Code Section 913.6. Retrieved from:
http://www.cpuc.ca.gov/uploadedFiles/CPUC_Website/Content/Utilities_and_Industries/Energy/Re ports_and_White_Papers/FINAL12302015Section913_6Report.pdf CAPCOA. (2021). CalEEMod Verision 2020.4.0 Calcuation Details (Appendix A). Retrieved from http://www.aqmd.gov/docs/default-source/caleemod/user-guide-2021/appendix-a2020-4-

0.pdf?sfvrsn=6
City of San Marcos. (2020). Final Climate Action Plan and Appendix D Guidance to Demonstrating Consistency with the City of San Marcos Climate Action Plan for Discretionary Projects Subject to CEQA and City of San Marcos Climate Action Plan Consistency Review Checklist. https://www.san- marcos.net/departments/development-services/planning/climate-action-plan Viewed March 27,2021
Environmental Progection Agency (EPA, U).1995. EPA-AP 42, Fifth Edition Compilation of Air Pollutant Emission Factors. US EPA. Retrieved from https://www.epa.gov/air-emissions-factors-and- quantification/ap-42-compilation-air-emissions-factors Viewed May 10, 2021 Environmental Protection Agency (EPA) and National Highway Traffic Safety Administration (NHTSA). 2016. Regulations and Standards: Heavy-Duty. EPA and DOT Finalize Greenhouse Gas and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles. August https://nepis.epa.gov/Exe/ZyPDF.cgi/P100P7NL.PDF?Dockey=P100P7NL.PDF Viewed May 10, 2021
IPCC. (2007). IPCC Fourth Assessment Report: Climate Change 2007 : Working Group I: The Physical Science Basis. Chapter 2, Changes in Atmospheric Constituents and in Radiative Forcing. https://www.ipcc.ch/site/assets/uploads/2018/02/ar4-wg1-chapter2-1.pdf Viewed March 27, 2001
LDN Consulting, Inc. 2021b. Greenhouse Gas Assessment, East Barham Residential Development Project. City of San Marcos, CA. November 16. Appendix H.1 LLG Engineers. 2021. Transportation Impact Analysis & Local Transportation Analysis - Hallmark Barham Specific Plan. May 10. Appendix K
San Diego Association of Governments (SANDAG). Draft 2021 Regional Plan. https://sdforward.com/mobility-planning/2021-regional-plan-draft San Diego Association of Governments (SANDAG). 2013. 2050 Series 13 Regional Growth Forecast for City of San Marcos and San Diego Region
http://datasurfer.sandag.org/download/sandag_forecast_13_jurisdiction_san-marcos.pdf Viewed and Data Extracted on May 5, 2021
South Coast Air Quality Management District. SCAQMD. 2008. http://www.aqmd.gov/docs/default - source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/year-2008-2009/ghg- meeting-6/ghg-meeting-6-guidance-document-discussion.pdf.

7.0 References
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 7-8
Hazards and Hazardous Materials (Section 3.8)
American Society for Testing and Materials (ASTM). 2013. Designation E 1527-13 Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process.

GEOCON Incorporated. 2020. Phase I and Phase II Environmental Site Assessment (ESA Report), 943 Barham Drive San Marcos, California. March 9. Appendix G.

City of San Marcos. 2012. City of San Marcos General Plan, Safety Element. Adopted February 14. https://www.san-marcos.net/home/showpublisheddocument?id=8476 Viewed March 31, 2021 San Diego County Regional Airport Authority. 2011. McClellan-Palomar Airport Land Use Compatibility Plan. January 25. Amended March 4, 2010 and December 1, 2011. http://www.san.org/DesktopModules/Bring2mind/DMX/Download.aspx?Command=Core_Download &EntryId=2991&language=en-US&PortalId=0&TabId=225 Viewed March 31, 2021 Hydrology/Water Quality (Section 3.9)
Carlsbad Watershed Management Area Responsible Agencies. 2018. Carlsbad Watershed Management Area Water Quality Improvement Plan. May.
http://www.projectcleanwater.org/watersheds/carlsbad-wma/#plan Viewed May 2, 2021 City of San Marcos. 2017. City of San Marcos Jurisdictional Runoff Management Plan. January. https://www.san-marcos.net/home/showpublisheddocument?id=15523 Viewed March 1, 2021 County of San Diego. 2020. BMP Design Manual for Permanent Site Design, Storm Water Treatment and Hydromodification Management. September 15.
https://www.sandiegocounty.gov/content/sdc/dpw/watersheds/DevelopmentandConstruction/BMP _Design_Manual.html Viewed February 26, 2021.

Federal Emergency Management Agency (FEMA). 2012. Flood Insurance Rate Map No. 06073C0794G.
https://msc.fema.gov/portal/search?AddressQuery=943%20E.%20Barham%20Drive%20San%20M arcos%2C%20Ca#searchresultsanchor Viewed May 26, 2021
SB&O. 2020a. Preliminary Drainage Report - 943 Barham Drive San Marcos, CA 92078. June 15.

Appendix J.1.

SB&O. 2020b. Priority Development Project (PDP) Storm Water Quality Management Plan (SWQMP) For 943 Barham Drive San Marcos, CA 92078. June 19. Appendix J.2.

Regional Water Quality Control Board San Diego Region. 1994. Water Quality Control Plan for the San Diego Basin (9). September 8.
https://www.waterboards.ca.gov/sandiego/water_issues/programs/basin_plan/docs/R9_Basin_Pla n.pdf Viewed March 8, 2021

7.0 References
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 7-9
Regional Water Quality Control Board San Diego Region. 2015. Order No. R9-2015-0100. An Order Amending Order No. R9-2013-001, NPDES No. CAS 010266, As Amended by Order No. R9-2015- 001. National Pollutant Discharge Elimination System (NPDES) Permit and Waste Discharge Requirements for Discharges from the Municipal Separate Storm Sewer Systems (MS4s) Draining the Watersheds within the San Diego Region.
https://www.waterboards.ca.gov/sandiego/board_decisions/adopted_orders/2015/R9-2015- 0100.pdf Viewed March 5,2021.

Land Use and Planning (Section 3.10)
City of San Marcos. 2012. City of San Marcos General Plan, Land Use and Community Design Element. Adopted February 14. https://www.san-
marcos.net/home/showpublisheddocument/8480/636570701878000000 Viewed June 1, 2021 City of San Marcos. 2020. Transportation Impact Analysis Guidelines. November https://www.san-marcos.net/home/showpublisheddocument?id=25036 Viewed March 15, 2021 City of San Marco 2021. Zoning Ordinance, Section 20.225.060- Mixed Use 3 (SP) Zone. Adopted November 13, 2012. Last Supplemented March 31, 2021.
https://library.municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20. 225MIUSZO_S20.225.060MIUS3SPZO Viewed May 24, 2021
Linscott Law & Greenspan (LLG). 2021. Transportation Impact Analysis & Local Transportation Analysis Hallmark Barham Specific Plan, San Marcos California. May 10. Appendix K San Diego Association of Governments (SANDAG). 2002. Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region
http://www.sandag.org/uploads/publicationid/publicationid_1140_5044.pdf Viewed May 10, 2021 Noise (Section 3.11)
California Department of Transportation (Caltrans) 2020. Transportation and Construction Vibration Guidance Manual. April. https://dot.ca.gov/-/media/dot-media/programs/environmental- analysis/documents/env/tcvgm-apr2020-a11y.pdf Viewed April 5, 2021 City of San Marcos. 20 17. San Marcos Municipal Code. Chapter 20.300.070 Performance Standards.
https://library.municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20. 300SIPLGEDEST_S20.300.070PEST Viewed April 6, 2021
Federal Transit Administration (FTA) 2018. Transit Noise and Vibration Impact Assessment Manual.

September.
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise- and-vibration-impact-assessment-manual-fta-report-no-0123_0.pdf Viewed April 5, 2021 LDN Consulting. 2011. San Marcos Rock Crusher Noise.

LDN Consulting. 2021c. Noise Assessment East Barham Residential Development Project City of San Marcos, CA. September 23. Appendix L.

7.0 References
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 7-10
Linscott Law & Greenspan (LLG) . 202 1. Transportation Impact Analysis & Local Transportation Analysis Hallmark Barham Specific Plan, San Marcos California. May 10. Appendix K.

Population and Housing (Section 3.12)
City of San Marcos. 2021. Public Review Draft 2021-2029 Housing Element. https://sanmarcos.generalplan.org/s/Consolidated-Draft-2021-2029-San-Marcos-HE.pdf Viewed May 28, 2021
Department of Finance, California (DOF). 2020. E-5 Population and Housing Estimates for Cities, Counties, and the State - January 1, 2020.
https://dof.ca.gov/Forecasting/Demographics/Estimates/E-5/ Accessed March 15, 2021.

San Diego Association of Governments (SANDAG) 2004. Regional Comprehensive Plan for the San Diego Region. July.
https://www.sandag.org/programs/land_use_and_regional_growth/comprehensive_land_use_and_ regional_growth_projects/RCP/rcp_final_complete.pdf Viewed May 28, 2021 San Diego Association of Governments (SANDAG). 2013. 2050 Series 13 Regional Growth Forecast For City of San Marcos and San Diego Region
https://datasurfer.sandag.org/ Viewed and Data Extracted on May 5, 2021 San Diego Association of Governments (SANDAG) 2020. Final 6th Cycle Regional Housing Needs Assessment Plan. July 10.
https://www.sandag.org/uploads/projectid/projectid_189_27782.pdf Viewed May 5, 2021 Public Services (Section 3.13)
California State University San Marcos. 2021. Borrowing Books and Media. https://biblio.csusm.edu/content/borrowing-policies-books-and-media Viewed May 28, 2021.

City of San Marcos. 2012a. City of San Marcos General Plan. Parks, Recreation and Community Health Element. Adopted February 14.
https://www.san-marcos.net/home/showpublisheddocument/8477/636573113841930000 Viewed May 28, 2021
City of San Marcos. 2012b. San Marcos General Plan EIR. Adopted February 14.

City of San Marcos.2021a. Fire Department Overview
https://www.san-marcos.net/departments/public-safety/fire-department/department-overview Viewed May 28,2021
City of San Marcos. 2021b. Parks & Recreation Facilities Directory https://www.san-marcos.net/departments/parks-recreation/parks-recreation-facilities Viewed May 28, 2021
Palomar College. 2021. Library FAQ. https://www2.palomar.edu/pages/library/library-faq/ May 28, 2021.

San Diego County Library. 2021a. San Marcos Branch Library. http://www.sdcl.org/locations_SM.html Viewed May 28, 2021

7.0 References
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 7-11
San Diego County Library. 2021b. About the Library. https://www.sdcl.org/aboutus.html Viewed May 28, 2021
San Diego County Sheriff’s Department. 2021. San Marcos Station. https://www.sdsheriff.gov/Home/Components/FacilityDirectory/FacilityDirectory/40/61 Viewed May 28,2021
San Marcos Fire Department. 2021. Email from Jason Nailon, Fire Marshal/Battalion Chief. April 15.

Appendix M.

San Marcos Unified School District. 2020. Residential and Commercial Developer Fees. https://www.smusd.org/departments/facilities_planning_and_development/residential_and_comm ercial_developer_fee_summary Viewed May 28,2021
San Marcos Unified School District. 2021. Letter from Tova Corman, Executive Director, Facilities Planning & Development. May 11. Appendix M.

Serra Cooperative Library System. 2016. About Ser ra. Last updated 2016. https://www.serralib.org/ Viewed May 28, 2021
Recreation (Section 3.14)
City of San Marcos. 2012a. City of San Marcos General Plan. Parks, Recreation and Community Health Element. Adopted February 14.
https://www.san-marcos.net/home/showpublisheddocument/8477/636573113841930000 Viewed May 28, 2021
City of San Marcos. 2017. Parks Master Plan Update. November. http://www.san-marcos.net/home/showdocument?id=18032 Viewed March 15, 2021.

City of San Marcos. 2021. Parks & Recreation Facilities Directory https://www.san-marcos.net/departments/parks-recreation/parks-recreation-facilities Viewed May 28, 2021
Department of Finance, California (DOF). 2020. E-5 Population and Housing Estimates for Cities, Counties, and the State - January 1, 2020.
https://dof.ca.gov/Forecasting/Demographics/Estimates/E-5/ Accessed March 15, 2021.

San Diego Association of Governments (SANDAG). 2013. 2050 Series 13 Regional Growth Forecast For City of San Marcos and San Diego Region
https://datasurfer.sandag.org/ Viewed and Data Extracted on May 5, 2021 Transportation (Section 3.15)
California 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).
http://www.capcoa.org/wp-content/uploads/downloads/2010/09/CAPCOA-Quantification-Report-9- 14-Final.pdf Viewed June 1, 2021
City of San Marcos. 2012. Bicycle and Pedestrian Plan.

7.0 References
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 7-12
City of San Marcos. 2020a. Intersection Sight Distance Guidelines, December 2. https://www.san-marcos.net/home/showdocument?id=11097 Viewed June 1, 2021 City of San Marcos. 2020b. Transportation Impact Analysis Guidelines. November https://www.san-marcos.net/home/showpublisheddocument?id=25036 Viewed March 15, 2021 Kittelson & Associates. 2020. VMT Mitigation Measures Memorandum. October 9. https://www.san- marcos.net/home/showpublisheddocument?id=25036 Viewed June 1, 2021 Linscott Law & Greenspan (LLG). 2021. Transportation Impact Analysis & Local Transportation Analysis Hallmark Barham Specific Plan, San Marcos California. May 10. Appendix K San Diego Association of Governments (SANDAG). 2002. Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region
http://www.sandag.org/uploads/publicationid/publicationid_1140_5044.pdf Viewed May 10, 2021 Tribal Cultural Resources (Section 3.16)
No references identified.

Utilities and Service Systems (Section 3.17)
Business Wire. 2021. Southern California Prepared for Drought With Metropolitan Investments in Storage, Conservation, Diverse Supplies. March 31.
https://www.businesswire.com/news/home/20210331005944/en/Southern-California-Prepared- for-Drought-With-Metropolitan-Investments-in-Storage-Conservation-Diverse-Supplies Viewed May 28, 2021
California Department of Resources Recycling and Recovery (CalRecycle). 2019a. Facility/Site Summary Details: Sycamore Landfill (37-AA-0023).
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1798?siteID=2871 Viewed March 14, 2021.

California Department of Resources Recycling and Recovery (CalRecycle). 2019b. Jurisdiction Diversion/ Disposal Rate Summary.
https://www2.calrecycle.ca.gov/LGCentral/DiversionProgram/JurisdictionDiversionPost2006 Viewed May 4, 2021
California Energy Commission (CEC). 2018. “2019 Building Energy Efficiency Standards Frequently Asked Questions.” March
https://www.energy.ca.gov/sites/default/files/2020-
03/Title_24_2019_Building_Standards_FAQ_ada.pdf Viewed May 4, 2021 County of San Diego. 2008. Integrated Waste Management Plan. Non-Disposal Facility Element for the County Unincorporated Area. July.
http://www.sandiegocounty.gov/content/dam/sdc/common_components/images/dpw/recyclingpdf s/2008NDFE1.pdf Viewed March 14, 2021.

County of San Diego. 2018. Five-Year Review Report of the Countywide Integrated Waste Management Plan.
https://www.sandiegocounty.gov/content/dam/sdc/dpw/SOLID_WASTE_PLANNING_and_RECYCLIN G/Files/2.%20Five-YearReview-%20Final.pdf Viewed March 14, 2021.

7.0 References
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 7-13
Department of Water Resources, California (DWR). 2021. Fast Facts on the Water Conservation Legislation. https://water.ca.gov/-/media/DWR-Website/Web-Pages/Programs/Water-Use-And- Efficiency/Make-Water-Conservation-A-California-Way-of-Life/Files/PDFs/Water-Conservation- Legislation-Fact-Sheet_a_y19.pdf Viewed on May 3,2021.

International Code Council (ICC) 2019. 2019 California Green Building Standards Code (CAL Green).

California Code of Regulations, Title 24, Part 11. July https://calgreenenergyservices.com/wp/wp- content/uploads/2019_california_green_code.pdf Viewed March 14,2021 Kasler and Bollag. 2021.Gavin Newsom Declares a Drought Emergency – But It’s Limited to Two Counties in California. The Sacramento Bee. https://www.sacbee.com/news/california/water-and- drought/article250843019.html Viewed May 4, 2021
Metropolitan Water District of Southern California (MWD). 2016. 2015 Urban Water Management Plan (UWMP). June.
http://www.mwdh2o.com/PDF_About_Your_Water/2.4.2_Regional_Urban_Water_Management_Pla n.pdf Viewed May 3 ,2021
Metropolitan Water District of Southern California (MWD). 2021a. Draft 2020 Urban Water Management Plan (UWMP). February.
http://www.mwdh2o.com/PDF_About_Your_Water/Draft_Metropolitan_2020_UWMP_February_202

1.pdf Viewed March 9,2021
Metropolitan Water District of Southern California (MWD). 2021b. Metropolitan Declares Water Supply Alert in Response to Severe Drought. https://www.mwdh2o.com/newsroom-press- releases/metropolitan-declares-water-supply-alert-in-response-to-severe-drought/ Viewed November 4, 2021.

Nagourney, Adam. 2015. California Imposes First Mandatory Water Restrictions to Deal with Drought. The New York Times. https://www.nytimes.com/2015/04/02/us/california-imposes-first- ever-water-restrictions-to-deal-with-drought.html Viewed May 2, 2021 Public Policy Institute of California (PPIC). 2021. Just the Facts. Droughts in California. https://www.ppic.org/publication/droughts-in-california/ Viewed May 4, 2021 Rincon del Diablo Municipal Water District (RDDMWD) 2014. Water Master Plan Update. April. https://rinconwater.org/wp-content/uploads/2018/12/Water-Master-Plan-2014.pdf Viewed May 2, 2021
Rincon del Diablo Municipal Water District (RDDMWD) 2015. An Ordinance of the Rincon del Diablo Municipal Water District Finding the Necessity For and Adopting a Drought Response Ordinance. https://rinconwater.org/wp-content/uploads/2019/02/Ordinance-15-120.2.pdf Viewed May 3, 2021
Rincon del Diablo Municipal Water District (RDDMWD) 2016. 2015 Urban Water Management Plan.

June 28. https://rinconwater.org/wp-content/uploads/2018/12/Urban-Water-Management-Plan- 2015.pdf Viewed May 2, 2021
Rincon del Diablo Municipal Water District (RDDMWD) 2020. About Us Our Water. https://rinconwater.org/about-us/our-water/ Viewed May 2, 2021

7.0 References
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 7-14
Rincon del Diablo Municipal Water District (RDDMWD) 2021. Letter from Karen Falk, Engineering Manager. April 6. Appendix N.2
San Diego County Water Authority (SDCWA). 2016. 2015 Urban Water Management Plan (UWMP).

June. https://www.sdcwa.org/wp-content/uploads/2020/12/UWMP2015.pdf Viewed March 9, 2021
San Diego County Water Authority (SDCWA). 2020. Twin Oaks Valley Water Treatment Plant.

February. https://www.sdcwa.org/wp-content/uploads/2020/11/twinoaksvalley-wtp-fs.pdf Viewed May 3, 2021
San Diego County Water Authority (SDCWA). 2021a. News Release- Major Rehabilitation of Historic First Aqueduct Complete. January 21. https://www.sdcwa.org/major-rehabilitation-of-historic-first- aqueduct-complete/ Viewed May 3, 2021
San Diego County Water Authority (SDCWA). 2021b. Seawater Desalination. https://www.sdcwa.org/your-water/local-water-supplies/seawater-desalination/?q=/seawater- desalination Viewed May 3, 2021
State of California Office of Governor Gavin Newsom. 2021a. Governor Newsom Expands Drought Emergency to Klamath River, Sacramento-San Joaquin Delta, and Tulare Lake Watershed Counties.

May 10. https://www.gov.ca.gov/2021/05/10/governor-newsom-expands-drought-emergency-to- klamath-river-sacramento-san-joaquin-delta-and-tulare-lake-watershed-counties/ Viewed May 28,2021
State of California Office of Governor Gavin Newsom. 2021b. Governor Newsom Expands Drought Emergency Statewide, Urges Californians to Redouble Water Conservation Efforts. October 19. https://www.gov.ca.gov/2021/10/19/governor-newsom-expands-drought-emergency-statewide- urges-californians-to-redouble-water-conservation-efforts/ Viewed November 4, 2021 Thomas and Murtland. 2017. Rincon Water Applauds Decision Lifting Emergency Drought Regulations. Escondido Times – Advocate. April 19. https://www.times- advocate.com/articles/rincon-water-applauds-decision-lifting-emergency-drought-regulations/ Viewed May 4, 2021
United States Bureau of Reclamation (USBR) 2021. Projects and Facilities – San Diego Project. https://www.usbr.gov/projects/index.php?id=389 Viewed May 3, 2021 Vallecitos Water District (VWD). 2016. 2015 Urban Water Management Plan Water, Wastewater and Recycled Water Master Plan. https://www.vwd.org/home/showpublisheddocument?id=4126 Viewed March 12, 2021
Vallecitos Water District (VWD). 2018. 2018 Water, Wastewater and Recycled Water Master Plan.

October. https://www.vwd.org/home/showdocument?id=10656 Viewed March 11, 2021 Vallecitos Water District (VWD). 2020. Hallmark- Barham Water and Sewer Study. Work Order #234061. Final Technical Memorandum. October 23. Appendix N.1

7.0 References
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 7-15
Alternatives (Section 4.0)
City of San Marcos. 2012. City of San Marcos General Plan, Land Use and Community Design Element. Adopted February 14.
https://www.san-marcos.net/home/showpublisheddocument/8480/636570701878000000 Viewed May 24, 2021
City of San Marcos. 2017. San Marcos Municipal Code. Chapter 20.300.070 Performance Standards.
https://library.municode.com/ca/san_marcos/codes/code_of_ordinances?nodeId=TIT20ZO_CH20. 300SIPLGEDEST_S20.300.070PEST Viewed April 6, 2021
Linscott Law & Greenspan (LLG) . 202 1. Transportation Impact Analysis & Local Transportation Analysis Hallmark Barham Specific Plan, San Marcos California. May 10. Appendix. K Environmental Effects Found Not to be Significant (Section 5.0) CalFire. 2009. Very High Fire Hazard Severity Zone in LRA as Recommended by CAL FIRE (for San Marcos). https://osfm.fire.ca.gov/media/5970/san_marcos.pdf Viewed June 4, 2021 City of San Marcos. 2012. City of San Marcos General Plan, Conservation and Open Space Element and Safety Element. Adopted February 14.
https://www.san-marcos.net/home/showpublisheddocument?id=8476 , https://www.san- marcos.net/home/showpublisheddocument/8478/636597348039500000 Viewed May 24, 2021 City of San Marcos. 2012b. San Marcos General Plan EIR. Adopted February 14.

Federal Emergency Management Agency (FEMA). 2012. Flood Insurance Rate Map No. 06073C0794G.
https://msc.fema.gov/portal/search?AddressQuery=943%20E.%20Barham%20Drive%20San%20M arcos%2C%20Ca#searchresultsanchor Viewed May 26, 2021
San Diego County Regional Airport Authority. 2011. McClellan-Palomar Airport Land Use Compatibility Plan. January 25. Amended March 4, 2010 and December 1, 2011. http://www.san.org/DesktopModules/Bring2mind/DMX/Download.aspx?Command=Core_Download &EntryId=2991&language=en-US&PortalId=0&TabId=225 Viewed March 31, 2021.

Vallecitos Water District. 2020. Hallmark-Barham Water and Sewer Study Final Technical Memorandum. October 23. Appendix N.1.

Other CEQA Considerations (Section 6.0)
City of San Marcos. 2021. Public Review Draft 2021-2029 Housing Element. https://sanmarcos.generalplan.org/s/Consolidated-Draft-2021-2029-San-Marcos-HE.pdf Viewed May 28, 2021

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 8-1

8.0 List of Preparers
City of San Marcos (Lead Agency)
Norm Pedersen, Associate Planner
Bradley Holder, EIT, Assistant Engineer
Environmental Impact Report
Sophia Mitchell & Associates, LLC
Sophia Habl Mitchell, LEED AP, Project Manager
Melyssa Sheeran, Senior Environmental Consultant
Air Quality, Greenhouse Gas, and Noise Reports
LDN Consulting
Jeremy Louden, Principal
Biological Resources Report and Focused Species Surveys Rocks Biological Consulting
Brenda Bennett, Associate Biologist and Arborist
Ian Hirschler, Senior Biologist
Chris Thompson, Associate Biologist
Cultural Resources Reports
ASM Affiliates
Stephen Harvey, M.A,. RPA
Holly Drake, M.A., RPA
Mark S. Becker, Ph,D., RPA
Shannon Davis, Senior Architectural Historian
Laura Taylor Kung, Architectural Historian
Geotechnical Investigation
Geocon Incorporated
Josephy P. Pagnillo, CEG
Trevor E. Myers, RCE
David B. Evans, CEG
Phase 1 Environmental Site Assessment
Geocon Incorporated
Mitchell H. Wagner, Staff Scientist
Troy K. Reist, CEG, Senior Geologist
Stormwater Quality Management Plan/Drainage Report
SB&O Inc.

Allen L. Butcher, PE
Traffic Analysis
Linscott, Law & Greenspan Engineers
Amelia Giacalone, Transportation Planner III
John Boarman, P.E., Principal

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