San Marcos City Council
May 10, 2022

ATTACHMENT D

ENVIRONMENTAL IMPACT REPORT

Hallmark-Barham Specific Plan
Final Environmental Impact Report
State Cl earinghouse No. 2021040009
G
P20-0002, SP20-0002, R20-0001, MFSDP20-0001, TSM20-0001, CUP20-0007, GV20-0002, EIR21-001
City of Sa n M arcos
1 Civic Center Drive
San Marcos, CA 92069
Contact: Norm Pedersen
Prepared by:

S
ophia Mitchell & Associates
P.O. Box 1700
Gualala, CA 95445
March 2022
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0.1 INTRODUCTION AND SUMMARY
This Final Environmental Impact Report (EIR) has been prepared in accordance with the California Environmental Quality Act (CEQA) as amended (Public Resources Code Section 21000 et seq.), CEQA Guidelines (California Administrative Code Section 15000 et seq .), and the City of San Marcos CEQA procedures.

According to CEQA Guidelines Section 15132, the Final EIR shall consist of the following:
a) The Draft EIR or a revision of the Draft;
b) Comments and recommendations received on the Draft EIR either verbatim or in summary; c) A list of persons, organizations, and public agencies commenting on the Draft EIR; d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process; and
e) Any other information added by the Lead Agency.

In accordance with these requirements, the Hallmark -Barham Specific Plan EIR is comprised of the following:
• Draft Environmental Impact Report, Hallmark -Barham Specific Plan EIR ( December 2021)
(SCH No. 2021040009)
• This Final EIR document, March 2022, that incorporates the information required by Section 15132
Format of the Final EIR
This document is organized as follows:

Section 0.1 Introduction
This section describes CEQA requirements and content of this Final EIR.

Section 0.2 Corrections and Additions
This section provides a list of those revisions made to the Draft EIR text as a result of comments received and/or minor errors and omissions discovered subsequent to release of the Draft EIR for public review. None of these revisions would result in the need to recirculate the Draft EIR.

Section 0.3 Responses to Comment Letters Received on the Draft EIR This section provides copies of the comment letters received and individual responses to written comments. In accordance with P ublic Resources Code 21092.5, copies of the written proposed responses to public agencies will be forwarded to the agencies at least 10 days prior to certifying an EIR. The responses conform to the legal standards established for response to comments on Draft EIRs.

Section 0.4 Mitigation Monitoring and Reporting Program Hallmark-Barham Specific Plan March 2022
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This section includes the Mitigation Monitoring and Reporting Program (MMRP) which identified the mitigation measures, timing and responsibility for implementation of the measures.

Section 0.5 CEQANet Posting
This section contains the proof of posting of the Draft EIR for a 45-day public review on the State Clearinghouse CEQANet portal.

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0.2 CORRECTIONS AND ADDITIONS
The following Sections 0.2.1 and 0.2.2 contain a summary of revisions to information included in the Draft EIR (December 2021). These revisions were made based upon comment received on the Draft EIR.

Given the nature of the changes associated with the document, the information added to the EIR does not meet the requirements for recirculation pursuant to Section 15088.5 of the State CEQA Guidelines.

Pursuant to Section 15088.5(a), a lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review. The term “information” can include changes in the project or environmental setting as well as additional data or other information. New information added to the EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. “Significant new information” requiring recircula tion includes, for example, a disclosure showing that:
(1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
(2) A substantial increase in the severity of an environmental impa ct would result unless mitigation measures are adopted that reduce the impact to a level of insignificance. (3) A feasible project alternative or mitigation measure considerably different from others previously analyze would clearly lessen environmental impacts of the project, by the projects’ proponents decline to adopt it.
(4) The draft EIR was so fundamentally flawed and basically inadequate and conclusionary in nature that meaningful public review was precluded.

Changes to the Draft EIR include the following:
• Change to biological resources mitigation measure MM-BIO-2 to increase the mitigation ratio from 1:1 to 2:1 for impacts to Diegan coastal sage scrub a Diegan coastal sage scrub – Baccharis dominated, per the request of the California Department of Fish and Wildlife.

• Change to a cultural resources mitigation measures based upon a comment from the San Diego Archaeological Society.

In summary, the revisions made to the Draft EIR do not meet the requirements of Section 15088.5 of the CEQA Guidelines. The revisions do not result in a new significant impact being identified, nor do the revisions identify a substantial increase in the severity of an environmental impact. Further, a feasible project alternative or mitigation measure considerable different from others previously analyzed was not included in the revisions. Finally, the Draft EIR has adequately disclosed the potential impacts of the project and identified mitigation measures, where f easible to reduce the impacts to below a level of significance.

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0.2.1 DRAFT EIR CORRECTIONS AND ADDITIONS
Changes to the Draft EIR were made in response to comments received on the Final EIR. The new information clarifies information refines mitigation measures that were requested by commenters on the Draft EIR. Text that has been added to the document appears in an underline format. Text that has been deleted appears with strikeout.

The table below identifies the changed EIR sections and accompanying page numbers in the Final EIR.

The revised Draft EIR is included following this Final EIR Introduction.

Final EIR Section Page/Table/Figure Change

2.0 – Project Description Page 2-15 - CDFW noted as a Trustee and Responsible Agency for the project.

3.3 – Biological Resources Pages 3.3-22 and -23 – Revised mitigation measure MM-BIO- 2 to note change in mitigation ratio for upland habitats from 1:1 to 2:1.

Pages 3.3-22 and -23 – Revised mitigation measure MM-BIO- 2 to remove onsite preservation as a mitigation option. Due to proposed project footprint, it is not possible to mitigation onsite.

3.4 – Cultural Resources Table 3.10-5 – Revised mitigation measure CR-1a to require curation of non-tribal artifacts. This additional text was added based upon a comment from the San Diego Archaeological
Society.

3.10 – Land Use and Planning Table 3.10-5 – Revised mitigation measures MM-BIO-2 to note change in mitigation ratio for upland habitats from 1:1 to 2:1 and to remove onsite preservation as a mitigation option.

Table 3.10-11 – Revised to be consistent with Table 13-1 of the project’s traffic report.

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0.2.2 REVISED AND SUPPLEMENTAL MITIGATION

MEASURES
Based upon comment letters received on the Draft EIR, the following mitigation measure s were revised. The following represents the modified mitigation measure s, with changes shown in a strike out/underline format:

Revised Mitigation Measures
MM-BIO-2 Direct impact to 0.61 acre of Diegan coastal sage scrub and 0.03 acre of Diegan coastal sage scrub – Baccharis dominated shall be mitigated at a 1:1 2:1 ratio for a total of 1.28 0.64 acre. Direct Impact to 9.50 acres of non-native grassland shall be mitigated at a 0.5:1 ratio for a total of 4.75 acres. These mitigation ratios are consistent with Tables 4 -6 and 4 -7 of the MHCP (SANDAG 2003) and Table 4 in Section 5.2.1 of the City’s Draft Subarea Plan (City of San Marcos 2001).

This mitigation shal l be accomplished by the project applicant through on -site preservation, off-site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the Planning Manager. Proof of onsite preservation, off-site acquisition, payment of in lieu fees, purchase of credits from an approved mitigation bank or a combination thereof shall be provided to the Planning Manager prior to issuance of a grading permit.

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 project 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 Hallmark-Barham Specific Plan March 2022
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requirement and timing of such release of ownership, and the r ecipient 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. Additionally, all non-tribal artifacts collected by the archaeologist will also be subject to curation

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0.3 RESPONSE TO WRITTEN COMMENTS
Section 3.0 contains responses to all comment letters received on the December 2021 Draft Environmental Impact Report (Draft EIR). A total of five comment letters were received during the comment period, which closed January 21, 2022 . A response to each comment letter follows this introduction. A copy of each letter with bracketed comment numbers on the right margin is followed by the response for each comment as indexed in the letter.

Letter Number Commenter Date
Federal Agencies
1 United States Fish and Wildlife Service 1/19/22
State Agencies
2 California Department of Fish and Wildlife 1/19/22
3 California Department of Transportation (Caltrans) 1/20/22 Government Organizations
4 Rincon Band of Luiseño Indians 1/25/22
Other Organizations
5 San Diego County Archaeological Society 1/15/22
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1-1 1-1
LETTER 1
From: Curti s, Taylor L <taylor_curtis@fws. gov>
Sent: Wedne sday, January 19, 2022 10:41 AM
To: Pedersen, Norm an <NPedersen@san-mar cos.net>
Cc: Zoutendyk, David <[email protected] >
Subject: Hallm ark- Barham Specific Plan
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Hi Norm ,
We have reviewed the Hallmark-Barham Specific Plan Draft Environmental Impact Report (EIR). We request that applicant work with the U.S. Fish and Wildlife and City of Oceanside (City) to do their offsite mitigation by restoring coastal sage scrub in the City's Wildlife Corridor Planning Zone. Thank you for the opportunity to comment on the EIR.

Best,
Taylor Curti s
Fish and Wildlife Biologist
U.S. Fish and Wildlife Service
2177 Salk Avenue, Suite 250
Carlsbad, CA 92008
(she, her, hers)
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Letter 1
United States Fish and Wildlife Service
1-1 This comment requests that the mitigation for impacts to coastal sage scrub occur through restoration of coastal sage scrub habitat in the City of Oceanside Wildlife Corridor Planning Zone. Mitigation measure MM-BIO-2 notes that the mitigation shall be accomplished by the project applicant through off-site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the City of San Marcos Planning Manager. It is the City’s preference to mitigate within their own jurisdiction, where feasible, however, the proposed mitigation measure give the applicant flexibility on meeting the mitigation requirement. At the time of permitting, applicant will evaluate all options for mitigation, including mitigation in other jurisdictions.

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LETTER 2

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DocuSign Envelope ID: C1744B49-ED8B-4BF2-A95D-EAB28C04A588 t,
State of California - Natural Resources Agency

DEPARTMENT OF FISH AND WILDLIFE
South Coast Region
3883 Ruffin Road
San Diego, CA 921 23
(858) 467-4201
www . wildlife. ca. gov
January 19, 2022
Mr. Norm Pedersen
Associate Planner
City of San Marcos
1 Civic Center Drive
San Marcos , CA 92069
N Pedersen@san-marcos .net
GA VIN NEWSOM. Governor
CHARLTON H. BONHAM, Director
Subject: Hallmark-Barham Specific Plan (Project) , Draft Environmental Impact Report (DEIR), SCH #2021040009
Dear Mr. Pederson:
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The California Department of Fish and Wildlife (CDFW) has reviewed the City of San Marcos' DEIR for the Project pursuant the California Environmental Quality Act (CEQA) and CEQA Guidelines .1 Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife . Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW , by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code .

CDFWROLE
CDFW is California's Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the state . (Fish & G . Code,§§ 711 .7, subd. (a) & 1802 ; Pub.

Resources Code, § 21070; CEQA Guidelines § 15386, subd . (a).) CDFW, in its trustee capacity , has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants , and habitat necessary for biologically sustainable populations of those species . (Id., § 1802.) Similarly , for purposes of CEQA , CDFW is charged by law to provide , as available , biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect fish and wildlife resources.

CDFW is also submitting comments as a Responsible Agency under CEQA. (Pub. Resources Code, § 21069; CEQA Guidelines,§ 15381 .) CDFW may also need to exercise regulatory authority as provided by the Fish and Game Code . As proposed, for example , the Project may be subject to CDFW's lake and streambed alteration regulatory authority . (Fish & G. Code , § 1600 et seq.) Likewise, to the extent implementation of the Project as proposed may result in "take" as defined by State law of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.), the project proponent may seek related take authorization as provided by the Fish and Game Code .

CDFW also administers the Natural Community Conservation Planning (NCCP) program . The City of San Marcos (City) has participated in the NCCP program by preparing a draft Subarea Plan 1 CEQA is codified in the California Public Resources Code in section 21000 et seq. The "CEQA Guidelines" are found in Title 14 of the California Code of Regulations, commencing with section 15000.

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DocuSign Envelope ID: C17 44849-ED8B-4BF2- A95D-EAB28C04A588 Mr. Norm Pederson
City of San Marcos
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(SAP) under the subregional Multiple Habitat Conservation Plan (MHCP) , which addressed eight incorporated cities in northern San Diego County. Hovvever, the City's SAP has not been finalized and has not been adopted by the City or received permits from the Wildlife Agencies (collectively the CDFW and the U.S. Fish and Wildlife Service (USFWS)) .

PROJECT DESCRIPTION SUMMARY
Proponent: City of San Marcos (City)
Objective: The proposed Project would involve development of 151 multi-family residential units and approximately 5.35 acres of associated common and private open space on a 10.56-acre site, as contemplated in the Hallmark-Barham Specific Plan for the City. The project proposes a total of 349 parking spaces , including 264 garage spaces , and the proposed landscape plan emphasizes moderate water use species including a mix of trees , shrubs, grasses, and groundcover. A 150- foot fire fuel modification buffer is required in the southern end of the project and is included in the biological resources impact analysis. The Project Applicant is requesting the following discretionary approvals from the City to allow for development of the proposed project: General Plan Amendment, Specific Plan, Rezone, Multi-Family Site Development Plan, Tentative Subdivision Map, Conditional Use Permit, and Grading Variance .

Location: The 10.94-acre Project site (San Diego County Assessor 's Parcel Number (APN): 228- 310-01) is located at 943 E. Barham Drive, west of Le Moree Drive in the eastern portion of the City. The Project vicinity is developed primarily with residential uses. To the west of the Project is the Crescent Court residential development and to the southwest is the Williamsburg residential development. East of the Project site is Grace Church and the Barham Park & Ride. Southeast of the Project site is residential development associated with the Walnut Hills II Specific Plan. The northern boundary of the Project site is E. Barham Drive and immediately north of E. Barham Drive is landscaping , a sound wall, and State Route 78 (SR-78) . South of the project site is preserved open space, a private community park/viewpoint, and additional residences within the Williamsburg residential development.

Biological Setting: The following tasks vvere performed for the purpose of identifying potential biological impacts from construction of the Project: 1) biological and aquatic resource database review, 2) general biological survey and vegetation mapping , 3) habitat assessments for special status plant and wildlife species, 4) focused rare plant surveys, 5) protocol surveys for coastal California gnatcatcher (Polioptila ca!ifornica ca/ifornica, Endangered Species Act-listed threatened and California Species of Special Concern), and 6) a reconnaissance-level assessment for potentially jurisdictional aquatic resources .

The Project site has a north-aspect slope with elevations of approximately 650 to 755 feet above mean sea level. Most of the Project site supports non-native grassland (NNG; 9.50 acres consisting of non-native grasses such as ripgut grass (Bromus diandrus) , slender wild oat (Avena barbata), and glaucous barley (Hordeum murinum ssp. glaucum)). According to the environmental analysis, this suggests that the site, though undeveloped, may have been disturbed in the past as the vegetation differs from that of the adjacent open space. Located along the southern Project site boundary is 0.62 acre of Diegan coastal sage scrub (CSS) habitat dominated by coast monkey flovver (Mimu/us dentatus), black sage (Salvia mellifera ), coastal sagebrush (Artemisia californica) , and laurel sumac (Malosma /aurina). A smaller area of Baccharis-dominated Diegan CSS habitat (CSS dominated by coyote brush (Baccharis pi/ularis ssp. consanguinea) occurs along the eastern Project boundary . Along the northern boundary is 0.40 acre consisting of paved roads. Scattered J
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throughout the NNG across most of the site are ruderal vegetation (<0.01 acre consisting mostly of black mustard (Brassies nigra), tocalote (Centaurea melitensis) , and filaree/storksbill (Erodium spp.)) and ornamental vegetation (0.22 acre including pepper trees (Schinus spp.), Mexican fan palm (Washingtonia robusta) , and China berry (Melia azedarach)).

The proposed impacts to CSS and Baccharis-dominated CSS are considered potentially significant and require mitigation . Direct impact to 0.61 acre of CSS and 0.03 acre of Baccharis-dominated CSS are proposed to be mitigated at a 1 :1 ratio for a total of 0.64 acre. Direct impacts to 9.50 acres of NNG are proposed to be mitigated at a 0.5:1 ratio for a total of 4.75 acres. The DEIR specifies that this mitigation shall be accomplished by the Project Applicant through on-site preservation, off-site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the Planning Manager. Proof of on-site preservation, off-site acquisition, payment of in lieu fees, purchase of credits from an approved mitigation bank or a combination thereof shall be provided to the Planning Manager prior to issuance of a grading permit.

No defined bed, bank, or other regular flow indicators were observed during the initial aquatic resources assessment; thus, no potential non-wetland waters of the U.S./State or CDFW streambed were observed on site. Two plant species commonly associated with depressional areas confined by clay soils, coastal plantain (Plantago elongata) and slender woolly marbles (Psi/ocarphus tenellus), were observed in low-lying areas on site. Four wetland delineation samples were taken near these areas. None of the four sampling points met the required federal- or state-jurisdictional wetland parameters . As such, it was concluded that the on-site low­ lying areas are not expected to be jurisdictional under the Army Corps of Engineers , Regional Water Quality Control Board, nor CDFW.

No special status plant species were located on the Project site. One special status bird species, Cooper's Hawk (Accipiter cooperii ; CDFWWatch List species when nesting) was observed flying over the Project site during the 2020 general biological survey. Although Cooper's hawk may use the Project site as a hunting territory, suitable nesting habitat containing large trees is not present.

As such, Cooper's hawk is not anticipated to nest within the Project site.

Protocol 2020 breeding season gnatcatcher surveys for the Project were negative. However, California Natural Diversity Database (CNDDB) and U.S. Fish and Wildlife Service (USFWS) databases include reports of gnatcatcher within one mile of the Project site.

The Project area does not occur within a local movement corridor identified in the City's General Plan. As such, impacts on wildlife movement and corridors would be considered less than significant. However, the Project site does abut preserved open space on the southern boundary .

The Project site does not occur within lands designated as Focused Planning Areas in the City's Draft MHCP Subarea Plan (2001). The Project seeks to comply with habitat mitigation requirements outlined in the City's Draft MHCP Subarea Plan.

COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the City in adequately identifying and/or mitigating the Project's significant, or potentially significant, direct and indirect J
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January 19, 2022

impacts on fish and wildlife (biological) resources . Editorial comments or other suggestions may also be included to improve the document.

I. Mitigation Measure or Alternative and Related Impact Shortcoming COMMENT #1: Permanent impacts to CSS
Issue: Proposed mitigation for impacts to CSS are not adequate to fully mitigate for permanent loss of potential gnatcatcher habitat.

Specific impact: The proposed Project will permanently impact 0.61 acre of CSS and 0.03 acre of Baccharis -dominated CSS.

Why impact would occur: CSS habitat would be permanently lost due to Project construction and vegetation management to create a fuel buffer. The DEIR states that the Project will be required to mitigate impacts to CSS at a 1: 1 ratio based on the location of the Project site being outside of the FPA. The issue with the proposed mitigation ratio is that the ratio is based on a finalized NCCP MHCP plan. The City does not have a finalized plan; higher mitigation ratios are typically applied in jurisdictions that are undergoing regional planning or otherwise have not yet committed to a long­ term regional conservation effort.

Evidence impact would be significant: Based on the historic gnatcatcher observations in the vicinity of the Project area , the suitability of CSS habitat on site, and the adjacency to open space to the south of the Project site, there is potential for gnatcatchers to utilize this vegetation for foraging and/or nesting.

Recommended Potentially Feasible Mitigation Measure(s) (Regarding Mitigation Measure or Alternative and Related Impact Shortcoming)
Mitigation Measure #1: To reduce impacts to less than significant:

CDFW recommends that permanent impacts to CSS communities be mitigated at a minimum 2:1 ratio. Additionally, on-site mitigation is not recommended as such a small patch of habitat as which currently exists is not expected to maintain biological value in the absence of considerable management effort, which would require a substantial financial investment. Therefore for the subject project, CDFW recommends that mitigation for CSS be accomplished by purchas ing of CSS credits from a CDFW-approved conservation bank.

COMMENT #2: Permanent impacts to NNG and Agency Approval of Mitigation Lands Issue: Proposed mitigation for impacts to NNG are not adequate to fully mitigate for permanent loss of raptor foraging habitat.

Specific impact: The proposed Project will permanently impact 9.50 acres of NNG.

Why impact would occur: NNG habitat V1K>uld be permanently lost due to Project construction of housing units, parking facilities, and open space areas to be planted with ornamental vegetation.

Evidence impact would be significant: Non-native grasslands in San Diego County provide important foraging habitat for raptors. Although the Project site does not provide suitable raptor nesting habitat it does provide a significant area (9.50 acres) for foraging . The DEIR calls for ]
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January 19, 2022

mitigation by the project applicant through on-site preservation, off-site acquisition , in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the Planning Manager. The DEIR requires proof that this mitigation has been accomplished be provided to the Planning Manager prior to issuance of a grading permit but does not specify that the Wildlife Agencies be involved in the selection of mitigation lands.

Recommended Potentially Feasible Mitigation Measure(s) (Regarding Mitigation Measure or Alternative and Related Impact Shortcoming)
Mitigation Measure #2: To reduce impacts to less than significant:

CDFW recommends that the impacts to 9.50 acres of non-native grassland be mitigated by the purchase of non-native grassland credits at a CDFW-approved conservation bank. On-site conservation is not recommended as this property lies outside of the draft SAP's Focused Planning Area . Therefore , it is not expected to retain long-term conservation value as the City builds out its planned development as anticipated under the General Plan. Similar to the reasoning applied to the CSS discussion above, maintaining biological value of this small block of habitat would require considerable effort and financial commitment, and that is why use of a conservation bank credits is recommended . CDFW concurs with the use of a 0.5:1 mitigation ratio for a total of 4.75 acres of equivalent habitat within a CDFW-approved conservation bank.

COMMENT #3: Land Use Adjacency Protection Measures
Issue: The DEIR does not identify Project design measures and post construction operational procedures to reduce direct and indirect impacts to species utilizing the preserved open space to adjacent to the southern border of the Project site.

Specific Impact: Species utilizing the open space directly adjacent to the south side of the residential community could be affected after construction of the Project is complete by impacts associated with use and operation of the residential community, such as noise, human presence, nighttime lighting, increase in predators, and spread of non-native species into occupied habitat.

Why impact would occur: Direct and indirect impacts could occur if measures are not taken during Project design to reduce anthropogenic disturbances or hazards to native species from use and operation of the residential community once construction is complete .

Evidence impact would be significant: Anthropogenic impacts could result in mortality of native species or reduction in use of the habitat next to the residential community .

Recommended Potentially Feasible Mitigation Measure(s) (Regarding Mitigation Measure or Alternative and Related Impact Shortcoming)
Mitigation Measure #3: To reduce impacts to less than significant:

Building and parking lot features (especially on the south side of the Project site) shall include:
reduced, shielded, and/or lighting that is directed away from the preserved open space; bird safe glass or features which allow bird strikes to be eliminated or avoided; noise elements which do not exceed 60dBA (1 hour weighted) at the nearest edge of the open space; signage, barriers or similar features that shall notify and/or preclude human and domestic animal intrusion into the open space; and avoidance and/or proper use of and minimization of toxic chemicals and wildlife entrapping/endangering products including petroleum products, pesticides, herbicides, Hallmark-Barham Specific Plan March 2022
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DocuSign Envelope ID: C17 4484 9-ED8B-4BF2-A95D-EAB 28C04A588 Mr. Norm Pederson
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January 19, 2022

rodenticides, plastic netting/net covered fiber rolls, and similar. All Best Management Practices (BMPs) and landscaping elements shall also be removed after their useful life or function has ended.

COMMENT #4 -Assurance That All Impacts Are Restricted to the Subject Property In addition to the above , CDFW recommends that the project be evaluated by the local fire authority to ensure that no fire-fuel clearing would be required on the adjacent off-site open space along the southern border of the site. Project development should ensure that sufficient distances are provided so that all impacts are contained within the project's boundaries .

ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a data base which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e).) Accordingly , please report any special status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB) . The CNN DB field survey form can be found at the following link:
http://www.dfg .ca.gov/biogeodata/cnddb/pdfs/CNDDB FieldSurveyForm .pdf. The completed form can be mailed electronically to CNDDB at the following email address : CNDDB@wildlife .ca.gov .

The types of information reported to CNDDB can be found at the following link:
http://www.dfg .ca.gov/biogeodata/cnddb/plants and animals .asp .

FILING FEES
The Project, as proposed , would have an impact on fish and/or wildlife , and assessment of filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the fee is required in order for the underlying project approval to be operative, vested, and final. (Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711 .4; Pub. Resources Code, § 21089.)

CONCLUSION
CDFW appreciates the opportunity to comment on the DEIR to assist the City in identifying and mitigating Project impacts on biological resources .

Questions regarding this letter or further coordination should be directed to Meredith Osborne , Environmental Scientist, at Meredith .Osborne@wildlife .ca.gov.

Sincerely ,
~ DocuSign ed by :

L2:t52~tY
David Mayer
Environmental Program Manager
South Coast Region
]
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DocuSign Envelope ID: C17 44849-ED8B-4BF2-A95D-EAB28C04A588 Mr. Norm Pederson
City of San Marcos
January 19, 2022

ec: CDFW
David Mayer, San Diego - [email protected] .gov
Jennifer Turner, San Diego - [email protected] Meredith Osborne, San Diego - Meredith .Osborne@wildlife .ca.gov Jennifer Ludovissy, San Diego - Jennifer [email protected] State Clearinghouse, Sacramento - [email protected] .gov Attachments
A. CDFW Comments and Recommendations
Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.3-11

2-11
DocuSign Envelope ID: C17 44849-ED8B-4BF2- A95 D-EAB28C0 4A588 Mr. Norm Pederson
City of San Marcos
January 19, 2022

Attachment A:

CDFW Comments and Recommendations
Recommendations/Mitigation
Measures
Mitigation Measure 1 Permanent impacts to CSS
communities be mitigated at a minimum
2:1 ratio by purchasing of CSS credits
from a CDFW-approved conservation
bank.

Mitigation Measure 2 Impacts to 9.50 acres of non-native grassland should be mitigated at a

0.5:1 ratio, requiring 4.75 acres of
credits, by the purchase of non-native
grassland credits at a CDFW-approved
conservation bank .

Mitigation Measure 3 Building and parking lot features
(especially on the south side of the
Project site) shall include : reduced,
shielded, and/or lighting that is directed
away from the preserved open space ;
bird safe glass or features which allow
bird strikes to be eliminated or avoided;
noise elements which do not exceed
60dBA (1 hour 'Neighted) at the nearest
edge of the open space ; signage,
barriers or similar features that shall
notify and/or preclude human and
domestic animal intrusion into the open
space; and avoidance and/or proper
use of and minimization of toxic
chemicals and wildlife
entrapping/endangering products
including petroleum products ,
pesticides , herbicides , rodenticides ,
plastic netting/net covered fiber rolls,
and similar. All Best Management
Practices (BMPs) and landscaping
elements shall also be removed after
their useful life or function has ended .

Timing Responsible
Party
Prior to Project
construction Applicant and
activities City of San
Marcos
Prior to Project
construction Applicant and
activities City of San
Marcos
Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.3-12
Letter 2
California Department of Fish and Wildlife

2-1 This comment provides opening remarks and does not raise any specific environmental issues.
2-2 This comment identifies CDFW’s role as both a Trustee Agency and a Responsible Agency for the project. Page 2-15 of the EIR notes CDFW’s role as both a Trustee Agency and a Responsible Agency.
2-3 This comment provides a summary of the project’s objective, location and biological setting.

It does not raise any specific environmental issues.
2-4 This comment provides an introduction to specific recommendation for the project. 2-5 This comment requests a 2:1 mitigation ratio for impacts to coastal sage scrub habitat. The Draft EIR included a 1:1 mitigation ratio. Based upon this comment, mitigation measures MM-BIO-2 has been revised. The revised mitigation measure is presented below in a strike- out/underline format:

MM-BIO-2 Direct impact to 0.61 acre of Diegan coastal sage scrub and 0.03 acre of Diegan coastal sage scrub – Baccharis dominated shall be mitigated at a 1:1 2:1 ratio for a total of 1.28 0.64 acre. Direct Impact to 9.50 acres of non-native grassland shall be mitigated at a 0.5:1 ratio for a total of 4.75 acres. These mitigation ratios are consistent with Tables 4 -6 and 4 -7 of the MHCP (SANDAG 2003) and Table 4 in Section 5.2.1 of the City’s Draft Subarea Plan (City of San Marcos 2001).

This mitigation shal l be accomplished by the project applicant through on -site preservation, off-site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the Planning Manager. Proof of onsite preservation, off-site acquisition, payment of in lieu fees, purchase of credits from an approved mitigation bank or a combination thereof shall be provided to the Planning Manager prior to issuance of a grading permit. 2-6 This comment addresses the mitigation for nonnative grassland. The comment does not raise concern with the proposed mitigation ratio (0.5:1). Rather the comment requests that the mitigation occur through the purchase of credits in a CDFW-approved conservation bank and not occur onsite. Due the site’s size and proposed footprint of development, conservation onsite would not be feasible for the project anyway. Mitigation measures MM- BIO-2, presented above, was revised to remove the option of on-site preservation since it would not be feasible anyway.
2-7 This comment addresses the potential for project operations to impact the preserved open space that is located adjacent to the southern boundary of the project site. The project design has taken into consideration the offsite preserve area and no direct or indirect impacts are anticipated.

The preserve area is grade separated from the project by a steep slope. There is a 150’ fire fuel modification buffer between the residential buildings and the property line which provides an additional buffer. The first 50 feet of this buffer from the residences will be landscaped and irrigated. The remaining 100 feet of fire buffer will be thinned to reduce fire Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.3-13
fuel loads. This buffer area will solely be for fuel modification and will not be for passive use by residents. There is no parking along the southern development boundary. Parking for residents is within ground floor garages and trees are planted at the end of the drive aisle facing southward to further shield vehicle lighting from going into the buffer area and offsite.

Guest parking areas, which would be expected to have more turnover, are located internal to the project and shielded from the offsite preserve area with intervening buildings. Similarly, the more active communal areas of the project are within the central portion of the project site community building. A small amenity area with a tot lot and seating is proposed in the southeastern portion of the site. Landscaping is proposed around this area to provide a buffer. Finally, all lighting will be required to conform with the City’s lighting ordinance and standards which requires shielding and no offsite spillage of lighting. In summary, the project design and grade separation will avoid any potential impacts to the offsite preserve area. No changes were made the EIR based upon this comment.
2-8 This comment requests that the project be reviewed by the local fire authority regarding fuel modification. The City of San Marco s Fire Department has reviewed the project. As noted on page 3.8-24 of the Draft EIR “ The project includes a 150 -foot onsite fuel modification buffer along the southern portion of the project site to further minimize fire risk to the proposed development. Per the Fire Marshal, offsite fuel modification is not required for the project.” No changes were made to the EIR based upon this comment.
2-9 This comment addresses contribution of environmental data to the California Natural Diversity Database (CNDDB). The project biologist will be responsible for submitting any required field survey results to the CNDDB.
2-10 This comment addresses the CDFW filing fees. The project applicant will pay the applicable filing fee at the time the Notice of Determination is filed with the County Clerk. 2-11 This comment provides a summary table of the proposed mitigation measures, as recommended by CDFW. Each of these items was addressed earlier in comments 2-5 through 2-7 above.

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3-1

CALI FORNIA STATE TRANSPORTATION AGENCY
California Department of Transportation
DISTRICT 11
4050 TAYLOR STREET, MS-240
SAN DIEGO, CA 92110
(619) 709-5152 I FAX (619) 688-4299 TTY 711
www.dol,ca,gov
January 20, 2022
Mr, Norm Pedersen
City of San Marcos
l Civic Center Drive
San Marcos, CA 92069
Dear Mr, Pedersen:

GAVIN NEWSOM, GOV ERNOR
l l-SD-78
PM VAR
Hallmark -Barham Specific Plan
DEIR/SCH#2021040009
Thank you for includ ing the California Department of Transportation (Ca ltra ns) in the env ironmenta l review process for the Draf t Environmental Impact Report (DEIR) for the Hallmar k-Barham Spec ific Plan located near State Route 78 (SR-78). The mission of Ca ltrans is to provide a safe and reliable transportation network that serves all people and respects the environment. The Loca l Development Review (LOR) Program reviews land use projects and plans to ensure consistency w ith our mission and state planning priorities.

Safety is one of Caltrans' strategic goa ls. Caltrans strives to make the year 2050 the first year without a single death or serious injury on California's roads . We are striving for more equitable outcomes for the transportation network's diverse users. To achieve these ambitious goa ls, we wil l pursue meaningfu l collaboration with our partners. We encourage the implementat ion of new technologies , innova tions, and best pract ices that wi ll enhance the safe ty on the tra nsportat ion network . These pursuits are both ambitious and urgent, and their accomplishmen t involves a focused departure from the status quo as w e cont inue to institutionalize safety in all our work.

Caltrans is committed to prioritizing projects that are equitab le and provide mean ingfu l benefits to historica lly underserved commun ities, to ultimately improve transportation access ibility and quality of life for people in the commun ities we serve.

We look forward to working with the City of San Marcos in areas where the City and Ca ltrans have joint jurisdiction to improve the transportation netw ork and connect ions between various modes of tra vel, with the goa l of improving the experience of those who use the transportation system.
"Provide a safe and reliable transportation network that serves all people and respects the environment " Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.3-15

3-2
Mr. Norm Pedersen
January 20, 2022

Caltrans has the following comments:

Transportation Analysis Study
Section 13 Page 45 of Appendi x K Transportation Analysis states:
" Based on the V MT analysis presented above in Section 6, a significant transportation impact is calculated. The results of the Project V MT comparison indicate that the Project would exceed the significance threshold by 21 .66%.

This would require mitigation of 21 .66% or more to reduce the VMT impact to less-than-significant . Since the maximum feasible total VMT reduction combining all measures is 15%, the Project 's impact is considered significant and unmitigated ."
Even with a presumed reduction per CAPCOA (LUT-1) of 6.2%, the project would still exceed the VMT significance threshold by 15.46%. Although the Transportation Analysis states that this VMT impact is significant and unmitigated, the project still needs to mitigate for it 's VMT impacts . This VMT impact is not in alignment with State VMT and emission s reduction goals . The project's VMT impacts need to be mitigated down to a level considered less than significant. Caltrans expect s conformance to state law (CEQA) with respect to mitigation of VMT impacts . Caltrans invites coordination with the City of San Marcos to determine appropriate mitigation measures including fair share contributions to Caltrans projects in the SR-78/B arha m area within the City of San Marcos.

Contributing funds towards the Barham Drive active transportation path is one way this project can help mitigate it's VMT impacts and align itself with the purposes of Senate Bill 743.

Per section 13.1 of the project 's Transportation Analysis, the V MT impact is stated to remain significant and unmitigated. The project needs to investigate additional methods to address this VMT impact . Some potential solutions to analyze are:
a. Reducing the project size.
b. Implementing other transportation improvements that would be comparable to fully mitigating the VMT impact.
c. Contribute funding equivalent to a calculated VMT reduction that the City of San Marcos will allow to the Caltrans SR-78 Woodland/Barham project that is in the area.
" Pro vid e a safe a nd re liab le tran sporta tion network that serves all peo p le and respec ts the e nvironment " Hallmark-Barham Specific Plan March 2022
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3-3

3-4

3-5

3-6
Mr. Norm Pedersen
January 20, 2022

Design
Caltrans and the City of San Marcos have a planned project to construct managed lanes on SR-78 and improve the Woodland Parkway interchange. This project is also proposed to construct a Class 1 active transportation path along a realigned Barham Drive , connecting the Inland Rail Trail to the Cal State San Marco s SPRINTER Station. This Caltrans/City of San Marcos project's work limits will encompass the section of SR-78 that is adjacent to the proposed Specific Plan Area. After reviewing the documents, specifically Appendi x K Transportation Analysis, we request that the City of San Marcos condition the project to provide fair share contribution to Caltrans SR-78 Woodland/Barham project as partial mitigation for the project' s VMT impacts.

Hydrology and Drainage Studies
Caltrans generally does not allow development projects to impact hydraulics within the State 's Right-of-Way. Any modification to the existing Caltran s drainage and/or increase in runoff to State facilities will not be allowed.

Complete Streets and Mobility Network
Caltrans views all transportation improvement s as opportunities to improve safety, access, and mobility for all traveler s in California and recognizes bicycle, pedestrian , and tran sit modes as integral elements of the transportation network . Caltrans support s improved tran sit accommodation through the provision of Park and Ride facilities, improved bicycle and pedestrian access and safety impro vements, signal prioritization for transit, bus on shoulders , ramp impro vements , or other enhancements that promotes a complete and integrated transportation network. Early coordination with Caltran s, in locations that may affect both Caltrans and the City of San Marcos is encouraged.

To reduce greenhou se gas emissions and achieve California's Climate Change target, Caltrans is implementing Complete Streets and Climate Change policies into State Highway Operations and Protection Program (SHOPP) projects to meet multi-modal mobility needs. Caltrans looks forward to working with the City to evaluate potential Complete Streets projects.

Land Use and Smart Growth
Caltrans recognizes there is a strong link between transportation and land use.

Development can have a significant impact on traffic and congestion on State transportation facilities . In particular, the pattern of land use can affect both local vehicle miles traveled and the number of trips. Caltrans supports collaboration with " Pro vid e a safe a nd re liab le tran sporta tion network that serves all peo p le and respec ts the e nvironment " l
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3-6
Cont.

3-7

3-8
Mr. Norm Pedersen
January 20, 2022

local agencies to work towards a safe, functional, interconnected, multi-modal transportation network integrated through applicable "smart growth " type land use planning and policies.

The City should continue to coordinate with Caltrans to implement necessary improvements at intersections and interchanges where the agencies have joint jurisdiction.

Noise
The applicant must be informed that in accordance with 23 Code of Federal Regulations (CFR) 772, the Department of Transportation (Caltrans) is not responsible for existing or future traffic noise impacts associated with the existing configuration of SR-78.

Environmental
Caltrans welcomes the opportunity to be a Responsible Agency under the California Environmental Quality A ct (CEQA), as we have some discretionary authority of a portion of the project that is in Caltrans' R/W through the form of an encroachment permit process. We look forward to the coordination of our efforts to ensure that Cal trans can adopt the alternative and/ or mitigation measure for our R/W.

An encroachment permit will be required for any work within the Caltrans' R/W prior to construction. As part of the encroachment permit process, the applicant must provide approved final environmental documents for this project, corresponding technical studies, and necessary regulatory and resource agency permits. Specifically, CEQA determination or exemption. The supporting documents must address all environmental impacts within the Caltrans' R/W and address any impacts from avoidance and/or mitigation measures.

We recommend that this project specifically identifies and assesses potential impacts caused by the project or impacts from mitigation efforts that occur within Caltrans' R/W that includes impacts to the natural environment , infrastructure including but not limited to highways , roadways, structures, intelligent transportation systems elements , on-ramps and off-ramps, and appurtenant features including but not limited to lighting, signage, drainage , guardrail , slopes, and landscaping. Caltrans is interested in any additional mitigation measures identified for the project's draft Environmental Document.
" Pro vid e a safe a nd re liable tran sportation network that serves all peo p le and respec ts the e nvironment " Hallmark-Barham Specific Plan March 2022
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3-10

3-9

3-11
Mr. Norm Pedersen
January 20, 2022

Broadband
Caltrans recognizes that teleworking and remote learning lessen the impacts of traffic on our roadways and surrounding communities. This reduces the amount of VMT and decreases the amount of greenhouse gas (GHG) emissions and other pollutants. The availability of affordable and reliable, high speed broadband is a key component in supporting travel demand management and reaching the state's transportation and climate action goals.

Mitigation
Caltrans endeavors that any direct and cumulative impacts to the State Highway network to be eliminated or reduced to a less than significant level pursuant to the California Environmental Quality Act (CEQA) and National Environmental Policy Act (NEPA) standards.

Caltrans recommends consideration of "fair share" funds towards future improvements associated with SR-78 corridor . Recommended feasible mitigation measures include "fair share" contribution towards Caltrans SR-78 Woodland/Barham project. Mitigation identified in the transportation analysis, subsequent environmental documents , and mitigation monitoring reports , should be coordinated with Caltrans to identify , and implement the appropriate mitigation . This includes the actual implementation and collection of any "fair share" monies, as well as the appropriate timing of the mitigation . Mitigation improvements on or adjacent to state facilities should be compatible with Caltrans concepts.

Mitigation measures for proposed intersection modifications are subject to the Caltrans Intersection Control Evaluation (ICE) policy (Traffic Operation Policy Directive 13-02). Alternative intersection design(s) will need to be considered in accordance with the ICE policy. Please refer to the policy for more information and requirements (http://www.dot .ca.gov/traffic ops/ice .html).

Mitigation conditioned as part of a local agency 's development approval for improvements to State facilities can be implemented either through a Cooperative Agreement between Caltrans and the lead agency, or by the project proponent entering into an agreement directly with Caltrans for the mitigation. When that occurs, Caltrans will negotiate and execute a Traffic Mitigation Agreement.

Right-of-Way
• Per Business and Profession Code 8771 , perpetuation of survey monuments by a licensed land surveyor is required, if they are being destroyed by any construction. " Pro vid e a safe a nd re liable tran sportation network that serves all peo p le and respec ts the e nvironment " Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.3-19

3-11
Cont.

Mr. Norm Pedersen
January 20, 2022

• Any work performed within Caltrans' R/W will require discretionary review and approval by Caltrans and an encroachment permit will be required for any work within the Caltrans ' R/W prior to construction.

Additional information regarding encroachment permits may be obtained by contacting the Caltrans Permits Office at (619) 688-6158 or emailing Dl 1.Permits@dot .ca .qov or by visiting the website at https :// dot .ca.gov /pro qr ams/ traffic -opera tions/ep . Early coordination with Caltrans is strongly advised for all encroachment permits.

If you have any que stions or concerns, please contact Kimberly Dodson, LDR Coordinator, at (619) 985-1587 or by e-mail sent to Kimber ly.Dod son@dot .ca .qov .

Sincerely ,

MAURICE EATON
Branch Chief
Local Development Review
" Pro vid e a safe a nd re liab le tran sporta tion network that serves all peo p le and respec ts the e nvironment " Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.3-20
Letter 3
California Department of Transportation (Caltrans)

3-1 This comment provides opening remarks and does not raise any specific environmental topics.
3-2 This comment indicates that the project must mitigate its VMT impacts to below a level of significance. As discussed in the Draft EIR (page 3.15-10) the results of the project VMT comparison indicate that the project would exceed the significance threshold by 21.66%.

The City coordinated with the project applicant to review the feasibility of mitigation options that are identified in the City’s Traffic Impact Assessment Guidelines (TIA Guidelines) specifically the Applicable VMT Reduction Strategies detailed Table 1 of Attachment C (VMT Mitigation). The following VMT reduction strategies were determined to be fully or partially applicable to the project: 1) Increase Site Density. 2) Major Transit Accessibility, 3) Voluntary Employer Commute Program, 4) School Pool Program, 5) Pedestrian and Bicycle Facility and Network Improvements, and 6) Community-Based Travel Planning.

The project applicant is also incorporating project features and design measures that can reduce VMT. These features and measures work towards enhancing and encouraging non- vehicular modes of transportation and reducing single-occupant trips. These include:
• Bicycle Network Improvements - The project applicant will provide bicycle network improvements in the project vicinity. These improvements are presented in figures at the end of the responses to the Caltrans letter. These include:
o Painting solid green bicycle lane improvements on Barham Drive at the intersection approach of Woodland Parkway
o Painting a dashed green bike lane on eastbound Barham Drive on the approach to La Moree Road.
• Provision of Bicycle Racks and Storage – The project design incorporates bicycle racks. Each residential unit includes a two car garage which can accommodate storage of bicycles.
• Dedicated Parking for Carpool/Vanpools – The project design includes a designated parking space for carpool, school carpool, vanpool, EV and/or park-and-ride spaces on site.
• Information Sharing from Homeowner’s Association (HOA) – The project is conditioned so that the HOA Manager will provide transit information to project residents and inform community members of public transit options and carpool options (including school carpool). The HOA will also make a good faith effort in offering transit fare subsidies.
• Workspace for Telecommuting – The community building has been designed to include a workspaces for telecommuting. Each home is also equipped with areas suitable for telecommuting.

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The project site is also located near transit options, which can reduce vehicular trips. The project site is within one mile of the Cal State San Marcos SPRINTER light rail station and within 0.9 mile of the Nordahl Road SPRINTER light rail station. Bus stops serving the North County Transit District (NCTD) Routes 305 and Route 347 are located approximately 0.4 and

0.7 mile from the project site. There is a pedestrian pathway from the project site to these SPRINTER stations and bus stops. Additionally, there is a bike lane on Barham Drive between the project site and nearby transit stations. Additionally, with the goal of reducing overall GHG emissions, the project will be required to comply with the City’s Climate Action Plan which includes GHG reduction measures. These measures include:
• Providing EV charging stations
• Using electric tank hot water heaters instead of natural gas • Complying with the City’s Water Efficient Landscape Ordinance • Planting 243 trees
It is important to note that the project reduces the overall amount of trip generation compared to what could be generated under the current General Plan designation. Under the current MU-3 (Mixed Use 3) designation, a mix of office and retails uses could be developed and generated up to 5,410 ADT, The project will generate 1,208 ADT, which is a 77% reduction. This reduction in ADT results in a corresponding reduction in air and greenhouse gas emissions which provides an overall benefit toward reducing VMT and GHG emissions on a region-wide basis.

Finally, from an historical perspective, the owner of the project site contributed to roadway infrastructure improvements through the dedication of right-of-way when the City widened E.

Barham Drive. These public road and utility easements (for public purposes) were signed over to the City in 2006 and 2008 and were recorded in 2012. East Barham Drive in front of the project site has been improved to its ultimate plan including tree wells, a bike lane and a 10-foot sidewalk. The bike lane and sidewalk along the project frontage provide for non- vehicular mobility options. In conclusion, the proposed project, while not able to mitigate the VMT impact to below a level of significance, incorporates several VMT and GHG emission reducing features and measures. The project also reduced potential ADT by 77% compared to what the ADT would be under buildout under the current General Plan designation of MU-

3. 3-3 This comment requests that the City condition the project to provide a fair share contribution to Caltrans SR-78 Woodland/Barham project as partial mitigation for the project’s VMT impacts. The only established fee program that the City has is the Public Facility Fees (PFF) development fees, a portion of which address the impact to the City of San Marcos’ SR-78 interchanges. Per mitigation measures 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. There are no other fee programs (i.e., in lieu VMT fee payment) that are available in the City.
3-4 This comment addresses drainage and runoff on Caltrans facilities. The project will not impact any Caltrans drainage facilities nor will it increase any runoff to Caltrans facilities. As Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.3-22
detailed in Section 3.9 (Hydrology/Water Quality) of the Draft EIR, the project site would be hydrologically engineered such that post-development runoff would be equal to the pre- development condition. Therefore, hydrologic impacts resulting from the proposed project would be less than significant.
3-5 This comment addresses Caltrans Complete Streets and Climate Change policies in State Highway Operations and Protection Program project. This requirement is not applicable to the proposed project.
3-6 This comment addresses land use planning and “smart growth” and coordination with the City. Comment noted however, this comment does not raise an environmental issue specific to the project.
3-7 This comment addresses noise from SR78 and potential impacts on the project. The noise analysis, which was summarized in Section 3.11 (Noise) of the Draft EIR considered the existing noise from SR-78 in the analysis. Mitigation measures (MM-N-3, MM-N-4 and MM-5) will be implemented by the project to reduce potential noise impacts to below a level of significance.
3-8 This comment addresses Caltrans responsibility as it relates to environmental review for encroachments into the Caltrans right-of-way. The project does not propose any improvements in the Caltrans right-of-way.
3-9 This comment addresses the availability of high speed broadband. High speed broadband is available in the project vicinity should future residents desire this service. Additionally, the common area building will include a space for telework. 3-10 This comment recommends consideration of “fair share” funds toward future improvements associated with the SR -78 corridor. As detailed in response 3 -3, above, p er mitigation measures 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. 3-11 This comment addresses survey monuments. The project will not impact any survey monuments. Nor will the project require any work within the Caltrans right-of-way.

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CONCEPTUAL USE ONLY NOT TO SCALE
New Green Bike Lane Improvements at
Barham Drive and Woodland Parkway
Hallmark-Barham Specific Plan March 2022
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CONCEPTUAL USE ONLY NOTTO SCALE
Bicycle Improvements at
Barham Drive and La Moree Road
Hallmark-Barham Specific Plan March 2022
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4-1
To:

Subject:

San Diego County Archaeological Society, Inc.

Environmental Review Committee
15 January 2022
Mr. Norm Pedersen, Associate Planner
Development Services Department
City of San Marcos
1 Civic Center Drive
San Marcos , California 92069
Draft Environmental Impact Report
Hallmark-Barham Specific Plan
SP20-0002, GPA20-0002, R20-0001, MFSDP20-000I , TSM20-0001, CUP20-0007 , GV20-0002, EIR2! -001
Dear Mr. Pedersen :

I have reviewed the cultural resources aspects of the subject DEIR on behalf of this committee of the San Diego County Archaeo logical Society .

Based on the information contained in the DEIR and its two cultural resources appendices , we agree with the impact analysis detailed in the cultural resources appendices.

Regarding the mitigation measures in the DEIR, specifically MM-CR-1 , the treatment , including curation, of non-tribal cultural resources needs to be explicitly addressed and defined .

Thank you for providing SDCAS with the opportunity to participate in the public review of this DEIR.
cc: ASM Affiliates
SDCAS President
File
,mosW . Royl,,~•
Environmental Review Committee
P.O. Box 81106 San Diego, CA 92138-1106 (858) 538-0935
Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.3-26
Letter 4
San Diego County Archaeological Society (SDCAS)

4-1 Based upon this comment, mitigation measures MM-CR1a has been revised to add a statement about what will happen should significant non-tribal resources be encountered during project grading. The revised mitigation measure, with the additional text underlined is presented below:

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, prep aration 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 project 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 recipient 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. Additionally, all non-tribal artifacts collected by the archaeologist will also be subject to curation

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5-1
Rincon Band of Luisefio Indians

CULTURAL RESOURCES DEPARTMENT
One Government Center Lane I Valley Center I CA 92082
(760) 749-1 092 I Fax: (760) 749-8901 I rincon-nsn.gov
January 25, 2022
Sent via email: [email protected]
Mr. Joseph Farace
City of San Marcos
1 Civic Center Drive
San Marcos, CA 92069
Re: SP20-0002 Hallmark-Barham Specific Plan
Dear Mr. Farace,
This letter is written on behalf of the Rincon Band of Luisefio Indians ("Rincon Band" or "Band" ), a federally recognized Indian Tribe and sovereign government. Thank you for providing us with the Notice of Intent to Adopt a Mitigated Negative Declaration (MND) for the above referenced project. The identified location is within the Territory of the Luisefio people, and is also within Rincon 's specific area of Historic interest.

We have reviewed the provided documents and agree with the measures, which include archaeological and tribal monitoring , a monitoring report, and protocols for discovery of cultural material and human remains . We understand that other Tribes potentially have knowledge particular to this project site and may request additional measures.

Please note that the Rincon Band supports all efforts to completely avoid cultural resources as prefened mitigation .

We do request that the Rincon Band be notified of any changes in project plans. In addition, we request a copy of the final monitoring report, when available and ask that Rincon be afforded the opportunity to monitor the ground disturbances associated with this project. If you have additional questions or concerns, please do not hesitate to contact our office at your convenience at (760) 749 1092 ext. 323 or via electronic mail at cmadrigal@rincon ­ nsn.gov.

Thank you for the opportunity to protect and preserve our cultural assets.

Sincerely,
Cheryl Madrigal
Tribal Historic Preservation Officer
Cultural Resources Manager
Bo Mazzetti
Chainnan
Tishma ll Turner
Vice Chair
Lauri e E. Gon zalez
Council Member
John Constantino
Council Member
Joseph Linton
Counc il Member
Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.3-28
Letter 5
Rincon Band of Luiseño Indians

5-1 This comment states that Rincon Band agrees with the proposed cultural resources mitigation measures. Should there be any changes in the project, the Rincon Band will be notified.

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City of San Marcos Page 0.4-1

0.4 MITIGATION MONITORING AND REPORTING

PROGRAM

INTRODUCTION AND SUMMARY
Pursuant to Section 21081.6 of the Public Resources Code and the California Environmental Quality Act (CEQA) Guidelines Section 15097, public agencies are required to adopt a monitoring or reporting program to assure that mitigation measures and revisions identified in Final Environmental Impact Report (FEIR) are implemented. As stated in Section 21081.6 of the Public Resources Code:
“… the public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment.”
Pursuant to Section 21081(a ) of the Public Resources Code, findings must be adopted by the decision makers coincidental to certification of the FEIR. The Mitigation Monitoring and Reporting Program (MMRP) must be adopted when making the findings (at the time of approval of the project).

As defined in the CEQA Guidelines, Section 15097, “reporting” is suited to projects that have readily measurable or quantitative measures or which already involve regular review. “Monitoring” is suited to projects with complex mitigation measures, such as wetland restoration or archaeological protection, which may exceed the expertise of the local agency to oversee, are expected to be implemented over a period of time or require careful implementation to assure compliance. Both reporting and monitoring would be applicable to the proposed project.

MITIGATION MATRIX
To sufficiently track and document the status of mitigation measures, a mitigation matrix has been prepared and includes the following components:
• Impact
• Mitigation Measure
• Action
• Timing
• Responsibility

The mitigation matrix is included in Table 0.4-1. Additionally, the project will be required to adhere to the design features presented in Table 0.4-2.

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Table 0.4-1. Mitigation Measures
Hallmark-Barham Specific Plan Mitigation Monitoring and Reporting Program Impact Mitigation Measure Action Timing Responsibility

BIOLOGICAL RESOURCES
Impact BIO-1
The Project has the
potential to directly
impact nesting birds
protected under the
MBTA through removal or
disturbance of habitat
that supports active
nests.

MM-BIO-1a To avoid direct impacts on raptors and/or
native/migratory birds, removal of habitat that supports active nests in the proposed area of disturbance should occur outside of the breeding season for these species
(February 1 to September 15). If removal of habitat in the proposed area of disturbance must occur during the
breeding season, a qualified biologist shall conduct a
preconstruction survey to determine the presence or
absence of nesting birds in the proposed area of
disturbance. The pre-construction (precon) survey shall be conducted within ten (10) calendar days prior to the start of construction activities (including removal of vegetation). If nesting birds are observed, a letter report or mitigation plan in conformance with applicable State and Federal Law (i.e., appropriate follow up surveys, monitoring schedules,
construction and noise barriers/buffers, etc.) shall be prepared and include proposed measures to be
implemented to ensure that take of birds or eggs or
disturbance of breeding activities is avoided. The report or mitigation plan shall be submitted to the CDFW and/or
USFWS as applicable for review and approval and
implemented to the satisfaction of those agencies. The
project biologist shall verify and approve that all measures identified in the report or mitigation plan are in place prior to and/or during construction. If nesting birds are not detected during the preconstruction survey, no further mitigation is required.

If construction is
proposed during the
breeding season,
conduct a pre-
construction survey.

If nesting birds are
present, implement
avoidance measures
outlined in approved
letter report/
mitigation plan.

If nesting birds are
not detected during
the preconstruction
survey, no further
mitigation is
required.

For construction
activities proposed
for the period of
February 1 through
September 15,
conduct survey
within ten days prior
to the start of
construction
activities.

Applicant/Land
Owner, Project
Biologist,
Contractor
Impact BIO-2
Direct impact to 0.61
acre of Diegan coastal
MM-BIO-2 Direct impact to 0.61 acre of Diegan coastal
sage scrub and 0.03 acre of Diegan coastal sage scrub – Baccharis dominated shall be mitigated at a 2:1 ratio for a total of 1.28 acres. Direct Impact to 9.50 acres of non- Proof of off-site
acquisition, in lieu
fees, purchase of
credits from
Prior to issuance of
grading permit.

Applicant/Land
Owner, Project
Biologist
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City of San Marcos Page 0.4-3
Impact Mitigation Measure Action Timing Responsibility
sage scrub, 0.03 acre of
Diegan coastal sage
scrub – Baccharis
dominated, and 9.50
acres of non-native
grassland.
native grassland shall be mitigated at a 0.5:1 ratio for a total of 4.75 acres. These mitigation ratios are consistent with Tables 4-6 and 4-7 of the MHCP (SANDAG 2003) and Table
4 in Section 5.2.1 of the City’s Draft Subarea Plan (City of San Marcos 2001).

This mitigation shall be accomplished by the project
applicant through off-site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the Planning Manager.

Proof of off-site acquisition, payment of in lieu fees, purchase of credits from an approved mitigation bank or a combination thereof shall be provided to the Planning
Manager prior to issuance of a grading permit.
mitigation bank, or
combination thereof
submitted to
Planning Manager.

Impact BIO-3
Potential for indirect
impacts to sensitive
habitats during Project
construction.

MM-BIO-3 A biologist shall be contracted to perform
regular random checks (at minimum once a month) to
ensure implementation of the following monitoring
requirements and BMPs. Monitoring reports and a post-
construction monitoring report will be prepared to document compliance with these requirements and shall be submitted to the Planning Manager.
• To prevent inadvertent disturbance to areas outside
the limits of work, the construction limits shall be
clearly demarcated (e.g., installation of flagging or
temporary visibility construction fence) prior to
ground disturbance activities and all construction
activities, including equipment staging and
maintenance shall be conducted within the marked
disturbance limits. The work limit delineation will be
maintained throughout project construction.
• Spoils, trash, and any excavation-generated debris
will be removed to an approved offsite disposal
facility. Trash and food items will be contained in
closed containers and removed daily to reduce the
attraction of opportunistic predators to the site,
Biological monitoring
and implementation
of BMPs during
construction.

Prior to and during
construction
Applicant/Land
Owner, Project
Biologist,
Contractor
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Impact Mitigation Measure Action Timing Responsibility
such as common ravens, coyotes, and feral cats
and dogs that may prey on listed species.
• Raw cement/concrete or washings thereof, asphalt,
paint or other coating material, oil, or other
petroleum products, or any other substances that
could be hazardous to vegetation or wildlife
resources, resulting from project-related activities,
will be prevented from contaminating the soil.
• Construction activities will be limited to daylight
hours to the extent feasible. If nighttime work is
necessary, lighting will be shielded away from
surrounding natural areas. Fixtures will be shielded
to downcast below the horizontal plane of the fixture
height and mounted as low as possible.

Impact BIO-4
Potential for indirect
impacts to sensitive
habitats during Project
operation.

MM-BIO-4 To avoid indirect impacts on adjacent sensitive habitats, final landscape plans will be reviewed and
approved by a qualified biologist to ensure that no invasive plant materials are included in planting plans.

Review/approve
landscape plans
Prior to construction Applicant/Land
Owner, Project
Biologist

CULTURAL RESOURCES/TRIBAL CULTURAL RESOURCES
Impact CR-1a
Due to grading and
ground disturbing
activities, the Project has
the potential to impact
unidentified historical
resources underneath
the Project site.

Impact CR-1b
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 Enter into Tribal
Cultural Resources
Treatment and
Repatriation
Agreement.

Prior to issuance of
Grading Permit
and/or during all
earth moving and
ground disturbing
activity.

Applicant/
Landowner, TCA
Tribe
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City of San Marcos Page 0.4-5
Impact Mitigation Measure Action Timing Responsibility
Due to grading and
ground disturbing
activities, the Project has
the potential to impact
unidentified historical
resources underneath
the Project site.

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 project 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 recipient 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.

Additionally, all non-tribal artifacts collected by the archaeologist will also be subject to curation.

MM-CR-1b Construction Monitoring. Prior to the issuance of a Grading 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 Traditionally 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.

Monitoring of earth
moving and ground
disturbing activities.

Prior to issuance of
Grading Permit
and/or during all
earth moving and
ground disturbing
activity.

Archaeologist,
Tribal Monitor
Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.4-6
Impact Mitigation Measure Action Timing Responsibility
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 Archaeologist 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 resources. 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 construction 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.

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Impact Mitigation Measure Action Timing Responsibility
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 report 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 consultation 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.

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City of San Marcos Page 0.4-8
Impact Mitigation Measure Action Timing Responsibility
MM-CR-1c Unanticipated Discovery Procedures. Both the
Qualified Archaeologist 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 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 archaeological 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
If potential
archaeological
resources are found,
halt ground
disturbance and
follow procedures
listed for discovery.

During all earth
moving and ground
disturbing activity.

Archaeologist,
Tribal Monitor
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Impact Mitigation Measure Action Timing Responsibility
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 will 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 California 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 require 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

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Impact Mitigation Measure Action Timing Responsibility
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 sites 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 resources for later reburial or storage at a local curation 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 project 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 curation facility, whichever is most applicable, that the repatriation and/or curation have been completed.

Impact CR-2
There is a potential for
Project construction
MM-CR-2 Human Remains. As specified by California Health and Safety Code Section 7050.5, if human remains, or
remains that are potentially human, are found on the project site during ground disturbing activities or during
If human remains
are found, halt
ground disturbance
and follow
During all earth
moving and ground
disturbing activity.

Archaeologist
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Impact Mitigation Measure Action Timing Responsibility
activities to disturb
previously unidentified
human remains on the
Project site.
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 Commission 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 culturally 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 identified, 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 procedures listed for
discovery.

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Impact Mitigation Measure Action Timing Responsibility
Code, six or more human burials at one location constitute a cemetery (Section 8100), and 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 location free from future disturbance (see Public Resources Code Section 5097.98(e) and 5097.94(k)).

GEOLOGY AND SOILS
Impact GEO-1
The Project has the
potential to disturb
previously unknown
paleontological resources
during Project grading.

MM-GEO-1 Prior to project grading the project applicant shall retain a qualified paleontologist to review the proposed project area to determine the potential for paleontological resources to be encountered. If there is a potential for paleontological resources to occur, the paleontologist shall identify the area(s) where these resources are expected to be present, and a qualified paleontological monitor shall be retained to monitor the initial cut in any areas that have the potential to contain paleontological resources.

Site review and if
potential for
paleontological
resources is
identified,
monitoring of initial
cut in any areas that
have the potential
for resources.
construction
activities and filing
of mitigation report.

Prior to grading and if
applicable during
initial cut.

Paleontologist

LAND USE AND PLANNING
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
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.

Payment of Public
Facility Fees
Prior to issuance of
first building permit.

Applicant
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City of San Marcos Page 0.4-13
Impact Mitigation Measure Action Timing Responsibility
under Near Term 2025
With Project condition.

Impact LU-2a
Northbound left-turn
movement out of the E.

Barham Drive/ Project
Driveway (West), the
Project’s western
driveway, is calculated to
operate at LOS E during
the PM peak hour under
Near Term 2025 With
Project condition.

Impact LU-2b
Northbound left-turn
movement out of the E.

Barham Drive/ Project
Driveway (West) (the
Project’s western
driveway) is calculated to
operate at LOS E during
the PM peak hour under
Horizon Year 2050 with
Project condition. The
significant effect is only
for the outbound left-
turns during PM peak
hour.

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.

Note signage
restricting left-turns
on final Project plans
and install sign.

Prior to Project
occupancy.

Applicant
Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.4-14
Impact Mitigation Measure Action Timing Responsibility
Impact LU-3a
Northbound left-turn
movement out of the E.

Barham Drive/ Project
Driveway (East), the
Project’s eastern
driveway, is calculated to
operate at LOS E during
the PM peak hour under
Near Term 2025 With
Project condition.

Impact 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
Horizon Year 2050 with
Project condition. The
significant effect is only
for the outbound left-
turns during PM peak
hour.

MM LU-3 The project shall restrict left-turns out of the eastern project driveway between the hours of 4 PM and 6 PM. Signage shall be placed at the eastern project driveway identifying the turning movement timing restriction. The signage requirement shall be noted on the final project plans and shall be put in place prior to project operation.

Note signage
restricting left-turns
on final Project plans
and install sign.

Prior to Project
occupancy.

Applicant
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City of San Marcos Page 0.4-15
Impact Mitigation Measure Action Timing Responsibility
NOISE
Impact N-1
Depending on the staging
location of a rock drill,
noise levels may exceed
the 75 dBA exterior noise
threshold.

MM-N-1 If a rock drill is proposed within 160 feet of any occupied noise sensitive land use, a noise mitigation plan based upon the location of the construction equipment,
topography and construction schedule shall be prepared by an acoustical engineer. If noise levels are determined to exceed City’s noise threshold of 60 dBA at any existing sensitive receptor, a mitigation plan shall be developed that may include a temporary noise barrier along any property line where the impacts could occur. A barrier ranging from 8 to 12 feet in height may be needed. The proposed noise
barrier shall be of solid non-gapping material to adequately reduce construction noise levels below the noise threshold.

The mitigation plan may also incorporate the usage of the equipment (amount of time used and/or the location in
respect to the property line). The mitigation plan shall determine the final height and location of a temporary
barrier if one is necessary. The final mitigation design shall be reviewed and approved by the Planning Division Manager.

Preparation of noise
mitigation plan and
implementation of
identified measures
including
construction of
temporary noise
barriers.

Prior to
commencement of
rock drilling
activities.

Applicant/
Landowner,
Acoustical
Engineer, City
(Planning Division
Manager)
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.

MM-N-2 To minimize exterior noise levels related to rock crusher operation during construction and to comply with the City of San Marcos noise standards limiting noise levels to 60 dBA Leq at residences and 65 dBA Leq at the nearby
church and preschool, barriers shall be constructed to break the line of sight from the rock crusher to a receptor.

Assuming the rock crusher is 10 feet in height, the barrier must be at least 11-12 feet in height to shield the crusher both visually and acoustically. The barrier may consist of an earthen berm, 5/8” plywood, 1-inch acoustical blankets or any combination of these materials. The barriers shall be in place prior to the commencement of rock crushing activities.

The locations of crusher and placement of the required
barriers are presented in Figure 3.11-3. The design of the barriers, including materials and color for any sound walls shall be subject to review and approval by the Planning Construct noise
barriers; Take noise
measurements
during first week of
rock crusher
operation to
determine hourly
noise levels.

If noise levels
exceed thresholds,
implement further
noise reduction
measures to meet
noise standards.

Prior to
commencement of
rock crushing
activities and during
first week of rock
crusher operations.

Applicant/
Landowner,
Acoustical
Engineer, City
(Planning Division
Manager)
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Impact Mitigation Measure Action Timing Responsibility
Division Manager. To ensure compliance with the City’s
thresholds, noise measurements of the rock crusher should be conducted to determine the hourly noise level within the first week of operation once the final crusher type and location are determined. If noise levels are found to be above the established thresholds of 60 dBA Leq at any
existing single family residential use, 65 dBA Leq for any multifamily use or 65 dBA Leq at a commercial use then
additional mitigation in the form of higher barriers, sound absorbing materials or operational limits on the crusher usage shall be incorporated.

Impact N-3
Noise levels at 11
receptors at the top of
slopes along E. Barham
Drive facing SR-78 are
modeled to exceed the
City’s General Plan Noise
Element 65 dBA exterior
noise threshold.

MM-N-3 To minimize on-site exterior ground floor noise levels and to comply with the City of San Marcos noise
standards, 6-8-foot barriers shall be constructed along the units adjacent to E. Barham Drive. The barriers shall be in place prior to project occupancy and must be constructed of a non-gapping material consisting of masonry, ½ inch thick glass, earthen berm or any combination of these materials.

The locations of barriers are presented in
Figure 3.11-4. The
design of the barriers, including materials and color for any sound walls shall be subject to review and approval by the Planning Division Manager.

Construct noise
barriers. Submit
location and design
of barriers to City
Planning Division
Manager for
approval.

Prior to Project
occupancy of
affected units
adjacent to E.

Barham Drive (Figure

3.11-4 in EIR).

Applicant/
Landowner,
Acoustical
Engineer, City
(Planning Division
Manager)
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.

MM-N-4 To minimize on-site exterior second and third floor balcony noise levels and to comply with the City of San Marcos noise standards, 5-7-foot barriers shall be
constructed along the units adjacent to E. Barham Drive and farther back (see Figure 3.11-5). The barriers shall be in place prior to project occupancy and must be constructed of a non-gapping material consisting of masonry, ½ inch thick glass, earthen berm or any combination of these materials.

The locations of barriers, presented in Figure 3.11-5, and design of the barriers, including materials and color for any sound walls shall be subject to review and approval by the Planning Division Manager.

Construct noise
barriers. Submit
location and design
of barriers to City
Planning Division
Manager for
approval.

Prior to Project
occupancy of
affected units
adjacent to E.

Barham Drive and
farther back (Figure

3.11-5 in EIR).

Applicant/
Landowner,
Acoustical
Engineer, City
(Planning Division
Manager).

Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.4-17
Impact Mitigation Measure Action Timing Responsibility
MM-N-5 To ensure compliance with the CCR Title 24 interior noise threshold of 45 dBA CNEL, a final noise assessment shall be performed prior to the issuance of building permits.

This final report shall identify the interior noise requirements based on architectural and building plans to meet the City’s established interior noise limit. The identified interior noise requirements, which may include conventional building
construction methods and providing a closed window
condition requiring a means of mechanical ventilation (e.g., air condition) for each building and upgraded windows for all sensitive rooms (e.g., bedrooms and living spaces), shall also be in place prior to occupancy of the residences
adjacent to E. Barham Drive.

Preparation of Final
Noise Assessment
and implement
identified interior
noise requirements
to meet City’s
interior noise limit.

Submit final noise
assessment prior to
issuance of building
permits for
residences adjacent
to E. Barham Drive.

Noise reduction
measures in place
prior to occupancy.

Applicant/
Landowner,
Acoustical
Engineer, City
(Planning Division
Manager).

TRANSPORTATION
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.

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.

Payment of Public
Facility Fees
Prior to issuance of
first building permit.

Applicant
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.

Note signage
restricting left-turns
on final Project plans
and install sign.

Prior to Project
occupancy.

Applicant
MM-LU-3
The project shall restrict left-turns out of the eastern project driveway between the hours of 4 PM and 6 PM. Signage
shall be placed at the eastern project driveway identifying the turning movement timing restriction. The signage
Note signage
restricting left-turns
on final Project plans
and install sign.

Prior to Project
occupancy.

Applicant
Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.4-18
Impact Mitigation Measure Action Timing Responsibility
requirement shall be noted on the final project plans and shall be put in place prior to project operation.

Impact TR-2
The project’s per capita
VMT is 17.07, which
exceeds the threshold of

14.96 VMT per capita.

There are no applicable or feasible mitigation measures to reduce the project’s VMT impact. The impact remains
significant and unavoidable.

n/a n/a n/a

Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.4-19
Table 0.4-2. Design Considerations for the Project
Aesthetics
• Implementation of the Landscape Plan to provide a cohesive and visually -appealing planting scheme.
• Compliance with the City of San Marcos Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080, Light and Glare Standards.

Air Quality
• Compliance with the San Diego Air Pollution Control District’s (SDAPCD’s) fugitive dust rules and fugitive dust control measures outlined in Section 87.426 of the City’s Grading Ordinance.
• In accordance with SDAPCD Rule 67.0 (Architectural Coatings), the project would utilize low-volatile organic compound (VOC) paint that does not exceed 100 grams of VOC per liter for interior surfaces and 150 grams of VOC per liter for exterior surfaces. • Heavy diesel construction equipment shall be rated Tier IV or better.

Geology and Soils
• Implementation of all remedial grading and drainage recommendations contained within Chapters 7 and 9 of the geotechnical report prepared for the project (GEOCON 2020).

Greenhouse Gas Emissions
• Each garage will be wired for EV charging stations.
• Provision of three Level 2 EV charging station in the community parking area. • Installation of rooftop solar consistent with Title 24. • The project design includes bicycle racks.
• The HOA manager will provide transit information to the owners and make a good faith effort in offering transit fare subsidies.
• The CC&Rs will have a requirement that the HOA will also inform community members about public transit and carpool options.
• The project will include parking for carpool vehicles. • Provision of a workspace in the community building for telecommute employees. • The project’s landscaping plan incorporates shade trees. • Compliance with the City’s Model Water Efficient Landscape Ordinance (WELO) and Municipal Code, Title 20.
• None of the units will have fireplaces.

Hazards and Hazardous Materials
• Future residents shall be notified of potential annoyances commonly associated with proximity to airports (e.g., noise, vibrations, and overflights) through the recording of overflight notification documents as outlined in the McClellan -Palomar Airport Land Use Compatibility Plan and Chapter 20.265 of the City’s Municipal Code.

Hydrology and Water Quality
• Source control BMPs include, but are not limited to:
• Preventing illicit discharges into the MS4
• Stenciling the future on-site public road storm drain inlets • Protecting trash storage areas from rainfall, run-on, runoff, and wind dispersal. • Site design BMPs include:

Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.4-20
• Conserving natural areas, soils, and vegetation
• Minimizing impervious areas
• Runoff collection through multiple private inlets
• Landscaping with native or drought tolerant species.

Noise
• Grading, excavation and other earth moving activities would occur between 7:00 AM and 4:30 PM, Monday through Friday. No grading, excavation and other earth moving activities would occur on the weekends or holidays in accor dance with the City’s Municipal Code, Section 17.32.180.
• Blasting activities shall comply with the City’s Municipal Code, Section 17.60.070 (Blasting Operations Procedures).

Public Services – Fire Protection, Police Protection and Schools • The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 2001-01 (Fire and Paramedic). • The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD98 -01 (Police). The applicant shall pay the San Marcos Unified School District developer fees that are in effect at the time of building permit issuance. The current residential fee is $4.38 per square foot.

Transportation (Vehicle Miles Traveled)
• The project design results in a greater average residential density on the project site (14.3 dwelling units/acre) compared to the residential density for the Traffic Analysis Zone (TAZ) in which is located (TAZ 1026), which has a residential density of 7.03 dwelling units per acre. This allows for a reduction in vehicle miles traveled. • The project design includes bicycle racks.
• The HOA manager will provide transit information to the owners and make a good faith effort in offering transit fare subsidies.
• The CC&Rs will have a requirement that the HOA will also inform community members about public transit and carpool options.
• The project will include parking for carpool vehicles. • Provision of a workspace in the community building for telecommute employees. • The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD2011-01 (Congestion Management).

Utilities and Service Systems
• The applicant shall pay Water Capital Facility (Capacity) Fees that are in effect at the time of building permit issuance to Rincon del Diablo Municipal Water District per Ordinance No. 21-98.21.
• The applicant shall pay Wastewater Capital Facility Fees per Vallecitos Water District per Ordinance No. 176.

Wildfire
• 150-foot onsite fire fuel modification buffer is incorporated into the project design. • Designed per code for fire resistive building materials

Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.4-21

0.5 CEQANET POSTING

1125122,5·2JP M Hallmarlc-Barham Speci fic Plan
Hallmark-Barham Specific Plan
Summary
SCH Number
Lead Agency
Document Title
Document Type
Received
Present Land Use
Document Description
Contact Information
Name
Agency Name
Job Title
Contact Types
Address
Phone
Email
Name
Agency Name
Job Title
Contact Types
Address
Phone
https://ce qan et.opr. ca.g0¥/2021 040009/2
2021040009
City of San Marcos
Hallma rk-Barham Specific Plan
EIR- Draft EIR
12/6/202 1
Undeveloped
Draft Enviro nmental Impac t Report for approval of a General Plan Amendment, Specific Plan, Rezone , Multi-Family Site Developme nt Plan, Tentative Subdivision Map, Conditional Use Perm it, and Grading Variance to allow for the development of 151 con­ domi niums on the project site .

Norm Pedersen

CITY OF SAN MARCOS
Associate Planner
Lead/Publ ic Agency
1 CIVIC CENTER DRIVE
SAN MARCOS, CA 92069
(760) 744-1050 ext. 3236
nped ersen@sa n-m a recs.net
Soph ia Habl Mitchell
Soph ia Mitchell & Associates
Environmental Project Manager
Consulting Firm
PO BOX 1700
GUALALA, CA 95445
Hallmark-Barham Specific Plan March 2022
City of San Marcos Page 0.4-22

1/25122,5 :23PM
Email
Location
Coordinates
Cities
Counties
Regions
Cross Streets
Zip
Total Acres
Parcel#
State Highways
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Schools
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Start
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Comments
httpsJ/c~ q11n et.opr- c11.govno21 04000912:

Hallmark-Barham Specific Plan
(858) 243-0843
[email protected]
I 33°8'6"N 117°8'14"W
San Marcos
San Diego
Citywide
943 E. Barham Drive
92069

10.56 228-310-01-00
SR-78
NCTD Sprinter
Mission Hills High Schoo l
San Marcos Cree
125
3W
29 San Bern
12/ 6/2021
1/20/2022
California Air Resources Board (ARB), Califo rnia Department of Conservatio n (DOC), California Departmen t of Forestry and Fire Prot ection (CAL FIRE), California Departmen t of Parks and Recreation, California Department of Water Resources (DWR), California Highway Patrol (CHP), Californ ia Native American Heritage Comm ission (NAHC), Californi a Natural Resources Agency, California Public Utilit ies Commission (CPUC), California Regional Water Quality Contro l Board, San Diego Region 9 (RWQCB), Departmen t of Toxic Substances Control, Office of Historic Preservation, St at e Water Resources Control Board, Division of Drinking Water, California Departme nt of Fish and Wildlife, South Coast Region 5 (CDFW), Californ ia Department of Transportation, District 11 (DOT)
California Department of Fish and Wild life, South Coast Region 5 (CDFW), California Departmen t ofTransporta tion , District 11 (DOT)
2/4
Hallmark-Barham Specific Plan November 2021
City of San Marcos Page i
Table of Contents
Table of Contents ................................ ................................ ................................ ............................... i Figures ................................ ................................ ................................ ................................ ........... v Tables ................................ ................................ ................................ ................................ .......... vi Technical Appendices (Included on CD in back pocket) ................................ ................................ ... viii Acronyms ................................ ................................ ................................ ................................ .......... ix

1.0 Summary ................................ ................................ ................................ ........................... 1-1

1.1 Project Summary ................................ ................................ ................................ ..................... 1-1

1.2 Summary of Significant Effects/Mitigation ................................ ................................ ............ 1-1

1.3 Areas of Controversy ................................ ................................ ................................ ............... 1-3

1.4 Issues to be Resolved ................................ ................................ ................................ ............. 1-4

1.5 Project Alternatives ................................ ................................ ................................ ................. 1-4

1.5.1 No Project/No Development Alternative .................................................................................. 1-4

1.5.2 No Project/Existing Land Use Alternative ................................................................................ 1-5

1.5.3 Reduced Density Alternative .................................................................................................... 1-5

1.5.4 Reduced Footprint Alternative .................................................................................................. 1-6

1.5.5 Environmentally Superior Alternative ....................................................................................... 1-6

2.0 Project Description, Location and Environmental Setting ................................ ................... 2-1

2.1 Project Objectives ................................ ................................ ................................ .................... 2-1

2.2 Project Description ................................ ................................ ................................ .................. 2-2

2.2.1 Discretionary Actions ................................................................................................................ 2-2

2.2.2 Project Characteristics.............................................................................................................. 2-3

2.2.2.1 Land Use ................................................................................................................................... 2-3

2.3 Environmental Setting ................................ ................................ ................................ .......... 2-12

2.3.1 Existing Land Use and Setting ................................................................................................2 -12

2.3.2 Existing General Plan and Zoning ..........................................................................................2 -13

2.3.3 Regional Setting .....................................................................................................................2 -13

2.4 Intended Uses of EIR ................................ ................................ ................................ ............ 2-15

2.4.1 Scope of the EIR .....................................................................................................................2 -16

2.4.2 Notice of Preparation and Scoping ........................................................................................2 -16

2.4.3 Draft EIR and Public Review ...................................................................................................2 -17

2.4.4 Final EIR Publication and Certification ...................................................................................2 -18

2.5 Matrix of Project Approvals ................................ ................................ ................................ .. 2-18

2.6 Project Inconsistencies with Applicable Regional and General Plans................................ 2-19

2.7 List of Past, Present and Reasonably Anticipated Future Projects in the Project Area ..... 2-19

3.0 Environmental ................................ ................................ ................................ .............. 32.7-1

3.1 Aesthetics ................................ ................................ ................................ .............................3.1 -1

3.1.1 Existing Conditions ................................................................................................................3.1- 2

3.1.2 Regulatory Setting .................................................................................................................3.1- 3

3.1.3 Thresholds of Significance ....................................................................................................3.1- 5

3.1.4 Project Impact Analysis .........................................................................................................3.1- 5

3.1.5 Cumulative Impact Analysis ..................................................................................................3.1- 9 Table of Contents
Hallmark-Barham Specific Plan November 2021
City of San Marcos Page ii

3.1.6 Mitigation Measures ........................................................................................................... 3.1-10

3.1.7 Conclusion .......................................................................................................................... 3.1-10

3.2 Air Quality ................................ ................................ ................................ .............................. 3.2-1

3.2.1 Existing Conditions ................................................................................................................3.2- 1

3.2.2 Regulatory Setting .................................................................................................................3.2- 6

3.2.3 Thresholds of Significance ................................................................................................. 3.2-12

3.2.4 Project Impact Analysis ...................................................................................................... 3.2-14

3.2.5 Cumulative Impact Analysis ............................................................................................... 3.2-18

3.2.6 Mitigation Measures ........................................................................................................... 3.2-19

3.2.7 Conclusion .......................................................................................................................... 3.2-19

3.3 Biological Resources ................................ ................................ ................................ ............3.3-1

3.3.1 Existing Conditions ................................................................................................................3.3- 2

3.3.2 Regulatory Setting .............................................................................................................. 3.3-13

3.3.3 Thresholds of Significance ................................................................................................. 3.3-16

3.3.4 Project Impact Analysis ...................................................................................................... 3.3-16

3.3.5 Cumulative Impact Analysis ............................................................................................... 3.3-21

3.3.6 Mitigation Measures ........................................................................................................... 3.3-22

3.3.7 Conclusion .......................................................................................................................... 3.3-23

3.4 Cultural Resources ................................ ................................ ................................ ...............3.4-1

3.4.1 Existing Conditions ................................................................................................................3.4- 2

3.4.2 Regulatory Setting .................................................................................................................3.4- 7

3.4.3 Thresholds of Significance ....................................................................................................3.4- 9

3.4.4 Project Impact Analysis ...................................................................................................... 3.4-10

3.4.5 Cumulative Impact Analysis ............................................................................................... 3.4-12

3.4.6 Mitigation Measures ........................................................................................................... 3.4-13

3.4.7 Conclusion .......................................................................................................................... 3.4-17

3.5 Energy ................................ ................................ ................................ ................................ ...3.5-1

3.5.1 Existing Conditions ................................................................................................................3.5- 1

3.5.2 Regulatory Setting .................................................................................................................3.5- 4

3.5.3 Thresholds of Significance ................................................................................................. 3.5-11

3.5.4 Project Impact Analysis ...................................................................................................... 3.5-11

3.5.5 Cumulative Impact Analysis ............................................................................................... 3.5-17

3.5.6 Mitigation Measures ........................................................................................................... 3.5-18

3.5.7 Conclusion .......................................................................................................................... 3.5-18

3.6 Geology and Soils ................................ ................................ ................................ .................3.6-1

3.6.1 Existing Conditions ................................................................................................................3.6- 2

3.6.2 Regulatory Setting .................................................................................................................3.6- 5

3.6.3 Thresholds of Significance ....................................................................................................3.6- 8

3.6.4 Project Impact Analysis .........................................................................................................3.6- 8

3.6.5 Cumulative Impact Analysis ............................................................................................... 3.6-13

3.6.6 Mitigation Measures ........................................................................................................... 3.6-13

3.6.7 Conclusion .......................................................................................................................... 3.6-14

3.7 Greenhouse Gas ................................ ................................ ................................ ...................3.7-1

3.7.1 Existing Conditions ................................................................................................................3.7- 1

3.7.2 Regulatory Setting .................................................................................................................3.7- 2

3.7.3 Thresholds of Significance ................................................................................................. 3.7-12 Table of Contents
Hallmark-Barham Specific Plan November 2021
City of San Marcos Page iii

3.7.4 Project Impact Analysis ...................................................................................................... 3.7-13

3.7.5 Cumulative Impact Analysis ............................................................................................... 3.7-20

3.7.6 Mitigation Measures ........................................................................................................... 3.7-20

3.7.7 Conclusion .......................................................................................................................... 3.7-20

3.8 Hazards and Hazardous Materials ................................ ................................ ......................3.8-1

3.8.1 Existing Conditions ................................................................................................................3.8- 2

3.8.2 Regulatory Setting .................................................................................................................3.8- 4

3.8.3 Thresholds of Significance ................................................................................................. 3.8-10

3.8.4 Project Impact Analysis ...................................................................................................... 3.8-11

3.8.5 Cumulative Impact Analysis ............................................................................................... 3.8-15

3.8.6 Mitigation Measures ........................................................................................................... 3.8-15

3.8.7 Conclusion .......................................................................................................................... 3.8-16

3.9 Hydrology and Water Quality ................................ ................................ ................................ 3.9-1

3.9.1 Existing Conditions ................................................................................................................3.9- 3

3.9.2 Regulatory Setting .................................................................................................................3.9- 4

3.9.3 Thresholds of Significance ................................................................................................. 3.9-10

3.9.4 Project Impact Analysis ...................................................................................................... 3.9-11

3.9.5 Cumulative Impact Analysis ............................................................................................... 3.9-19

3.9.6 Mitigation Measures ........................................................................................................... 3.9-20

3.9.7 Conclusion .......................................................................................................................... 3.9-20

3.10 `Land Use and Planning ................................ ................................ ................................ ... 3.10-1

3.10.1 Existing Conditions ............................................................................................................. 3.10-1

3.10.2 Regulatory Setting .............................................................................................................. 3.10-6

3.10.3 Thresholds of Significance ............................................................................................... 3.10-13

3.10.4 Project Impact Analysis .................................................................................................... 3.10-13

3.10.5 Cumulative Impact Analysis ............................................................................................. 3.10-24

3.10.6 Mitigation Measures ......................................................................................................... 3.10-25

3.10.7 Conclusion ........................................................................................................................ 3.10-25

3.11 Noise ................................ ................................ ................................ ................................ . 3.11-1

3.11.1 Existing Conditions ............................................................................................................. 3.11-1

3.11.2 Regulatory Setting .............................................................................................................. 3.11-4

3.11.3 Thresholds of Significance ................................................................................................. 3.11-9

3.11.4 Project Impact Analysis .................................................................................................... 3.11-12

3.11.5 Cumulative Impact Analysis ............................................................................................. 3.11-20

3.11.6 Mitigation Measures ......................................................................................................... 3.11-20

3.11.7 Conclusion ........................................................................................................................ 3.11-22

3.12 Population and Housing ................................ ................................ ................................ .... 3.12-1

3.12.1 Existing Conditions ............................................................................................................. 3.12-1

3.12.2 Regulatory Setting .............................................................................................................. 3.12-2

3.12.3 Thresholds of Significance ................................................................................................. 3.12-5

3.12.4 Project Impact Analysis ...................................................................................................... 3.12-6

3.12.5 Cumulative Impact Analysis ............................................................................................... 3.12-7

3.12.6 Mitigation Measures ........................................................................................................... 3.12-7

3.12.7 Conclusion .......................................................................................................................... 3.12-7

3.13 Public Services ................................ ................................ ................................ .................. 3.13-1

3.13.1 Existing Conditions ............................................................................................................. 3.13-1 Table of Contents
Hallmark-Barham Specific Plan November 2021
City of San Marcos Page iv

3.13.2 Regulatory Setting .............................................................................................................. 3.13-3

3.13.3 Thresholds of Significance ................................................................................................. 3.13-6

3.13.4 Project Impact Analysis ...................................................................................................... 3.13-6

3.13.5 Cumulative Impact Analysis ............................................................................................. 3.13-10

3.13.6 Mitigation Measures ......................................................................................................... 3.13-12

3.13.7 Conclusion ........................................................................................................................ 3.13-12

3.14 Recreation ................................ ................................ ................................ ......................... 3.14-1

3.14.1 Existing Conditions ............................................................................................................. 3.14-1

3.14.2 Regulatory Setting .............................................................................................................. 3.14-2

3.14.3 Thresholds of Significance ................................................................................................. 3.14-4

3.14.4 Project Impact Analysis ...................................................................................................... 3.14-4

3.14.5 Cumulative Impact Analysis ............................................................................................... 3.14-7

3.14.6 Mitigation Measures ........................................................................................................... 3.14-8

3.14.7 Conclusion .......................................................................................................................... 3.14-8

3.15 Transportation ................................ ................................ ................................ ................... 3.15-1

3.15.1 Existing Conditions ............................................................................................................. 3.15-1

3.15.2 Regulatory Setting .............................................................................................................. 3.15-3

3.15.3 Thresholds of Significance ................................................................................................. 3.15-7

3.15.4 Project Impact Analysis ...................................................................................................... 3.15-8

3.15.5 Cumulative Impact Analysis ............................................................................................. 3.15-13

3.15.6 Mitigation Measures ......................................................................................................... 3.15-14

3.15.7 Conclusion ........................................................................................................................ 3.15-15

3.16 Tribal Cultural Resources ................................ ................................ ................................ .. 3.16-1

3.16.1 Existing Conditions ............................................................................................................. 3.16-2

3.16.2 Regulatory Setting .............................................................................................................. 3.16-4

3.16.3 Thresholds of Significance ................................................................................................. 3.16-5

3.16.4 Project Impact Analysis ...................................................................................................... 3.16-6

3.16.5 Cumulative Impact Analysis ............................................................................................... 3.16-7

3.16.6 Mitigation Measures ........................................................................................................... 3.16-8

3.16.7 Conclusion ........................................................................................................................ 3.16-12

3.17 Utilities and Service Systems ................................ ................................ ............................ 3.17-1

3.17.1 Existing Conditions ............................................................................................................. 3.17-2

3.17.2 Regulatory Setting ............................................................................................................ 3.17-16

3.17.3 Thresholds of Significance ............................................................................................... 3.17-21

3.17.4 Project Impact Analysis .................................................................................................... 3.17-22

3.17.5 Cumulative Impact Analysis ............................................................................................. 3.17-29

3.17.6 Mitigation Measures ......................................................................................................... 3.17-31

3.17.7 Conclusion ........................................................................................................................ 3.17-31

4.0 Alternatives ................................ ................................ ................................ ....................... 4-1

4.1 Introduction to Alternatives ................................ ................................ ................................ ..... 4-1

4.2 Project Objectives ................................ ................................ ................................ .................... 4-1

4.3 Project Alternatives Considered in This EIR ................................ ................................ ........... 4-2

4.3.1 Description of Alternative ......................................................................................................... 4-2

4.3.2 Summary of Impacts................................................................................................................. 4-2

4.3.3 No Project/No Development Alternative .................................................................................. 4-3 Table of Contents
Hallmark-Barham Specific Plan November 2021
City of San Marcos Page v

4.3.4 No Project/Existing Land Use Designation Alternative ............................................................ 4-8

4.3.5 Reduced Density Alternative ..................................................................................................4 -14

4.3.6 Reduced Footprint Alternative ................................................................................................4 -19

4.4 Alternatives Considered But Rejected ................................ ................................ ................. 4-24

4.4.1 Alternative Location ................................................................................................................4 -24

4.5 Environmentally Superior Alternative ................................ ................................ .................. 4-25

5.0 Environmental Effects Found not to be Significant ................................ ............................. 5-1

5.1 Agriculture and Forestry Resources ................................ ................................ ........................ 5-1

5.2 Geology and Soils ................................ ................................ ................................ .................... 5-2

5.3 Hydrology and Water Quality ................................ ................................ ................................ ... 5-3

5.4 Land Use and Planning ................................ ................................ ................................ ........... 5-3

5.5 Mineral Resources ................................ ................................ ................................ .................. 5-3

5.6 Noise ................................ ................................ ................................ ................................ ....... 5-4

5.7 Population and Housing ................................ ................................ ................................ .......... 5-4

5.8 Wildfire ................................ ................................ ................................ ................................ ..... 5-4

6.0 Other CEQA Considerations................................ ................................ ................................ 6-1

6.1 Significant and Unavoidable Impacts ................................ ................................ ..................... 6-1

6.2 Growth Inducement ................................ ................................ ................................ ................. 6-1

6.3 Significant Irreversible Environmental Changes ................................ ................................ .... 6-2

7.0 References ................................ ................................ ................................ ........................ 7-1

8.0 List of Preparers ................................ ................................ ................................ ................ 8-1

Figures
Figure 2-1. Project Location ................................ ................................ ................................ ................ 2-23 Figure 2-2. Conceptual Site Plan ................................ ................................ ................................ ......... 2-24 Figure 2-3. Open Space ................................ ................................ ................................ ....................... 2-25 Figure 2-4a. Landscape Concept ................................ ................................ ................................ ........ 2-26 Figure 2-4b. Plant Materials ................................ ................................ ................................ ................ 2-27 Figure 2-5a. Architectural Concept (3-Plex) ................................ ................................ ........................ 2-28 Figure 2.5b. Architectural Concept (7-Plex, Option 1) ................................ ................................ ........ 2-29 Figure 2.5c. Architectural Concept (7-Plex, Option 2) ................................ ................................ ........ 2-30 Figure 2-6. Conceptual Fence and Wall Plan................................ ................................ ...................... 2-31 Figure 2-7. Lighting Plan ................................ ................................ ................................ ...................... 2-32 Figure 2-8. Conceptual Circulation Plan ................................ ................................ ............................. 2-33 Figure 2-9a. Private Alley and Driveway Cross Sections (1 of 2) ................................ ....................... 2-34 Figure 2-9b. Private Alley and Driveway Cross Section (2 of 2) ................................ ......................... 2-35 Figure 2-10. Grading Plan ................................ ................................ ................................ ................... 2-36 Figure 2-11. Grading Variance Exhibit ................................ ................................ ................................ 2-37 Figure 2-12. Proposed Water Exhibit ................................ ................................ ................................ .. 2-38 Figure 2-13. Proposed Wastewater Exhibit ................................ ................................ ........................ 2-39 Figure 2-14. Conceptual Drainage Plan ................................ ................................ .............................. 2-40 Table of Contents
Hallmark-Barham Specific Plan November 2021
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Figure 2-15. Cumulative Projects ................................ ................................ ................................ ........ 2-41 Figure 3.1-1 Site Photos 1 and 2 ................................ ................................ ................................ 3.1-11 Figure 3.1-2 Site Photos 3 and 4 ................................ ................................ ................................ 3.1-12 Figure 3.1-3 Site Photos 5 and 6 ................................ ................................ ................................ 3.1-13 Figure 3.1-4 Site Photos 7 and 8 ................................ ................................ ................................ 3.1-14 Figure 3.1-5 Site Photos 9 and 10 ................................ ................................ .............................. 3.1-15 Figure 3.1-6 Site Photos 11 and 12 ................................ ................................ ............................ 3.1-16 Figure 3.1-7. Architectural Rendering ................................ ................................ .............................. 3.1-17 Figure 3.3-1. Existing Biological Resources ................................ ................................ ..................... 3.3-25 Figure 3.3-2. Impacts to Biological Resources ................................ ................................ ................ 3.3-26 Figure 3.10-1. Existing Circulation Network ................................ ................................ .................. 3.10-27 Figure 3.11-1. Ambient Monitoring Locations ................................ ................................ ............... 3.11-23 Figure 3.11-2. Modeled Receptor Locations ................................ ................................ ................. 3.11-24 Figure 3.11-3. Preliminary Rock Crusher Location and Mitigation ................................ ............... 3.11-25 Figure 3.11-4. Ground Level Mitigation Measures ................................ ................................ ........ 3.11-26 Figure 3.11-5. Upper Level Mitigation Measures ................................ ................................ .......... 3.11-27 Figure 3.13-1 Public Services in Project Vicinity ................................ ................................ ........... 3.13-13 Figure 4.3-1. No Project/Existing Land Use Designation Alternative ................................ ................ 4-30

Tables
Table 1-1. Summary of Significant Environmental Impacts ................................ ................................ .. 1-2 Table 1-2. Comparison of Impacts of Proposed Project and Alternatives ................................ ............ 1-8 Table 2-1. Proposed Open Space Summary ................................ ................................ .......................... 2-4 Table 2-2. Project Design Features ................................ ................................ ................................ ..... 2-10 Table 2-3. Required Actions and Approvals ................................ ................................ ........................ 2-19 Table 2-4. Cumulative Projects ................................ ................................ ................................ ........... 2-20 Table 3.1-1. Aesthetics Summary of Impacts ................................ ................................ .................... 3.1-1 Table 3.2-1. Air Quality Summary of Impacts ................................ ................................ .................... 3.2-1 Table 3.2-2. San Diego County Air Basin Attainment Status by Pollutant ................................ ........ 3.2-3 Table 3.2-3. Two Year Ambient Air Quality Summary Near the Project Site (Camp Pendleton or Carmel Mountain Ranch Stations) ................................ ................................ ................................ .......... 3.2-4 Table 3.2-4. Ambient Air Quality Standards ................................ ................................ ....................... 3.2-7 Table 3.2-5. Screening-Level Criteria for Air Quality Impacts................................ .......................... 3.2-13 Table 3.2-6. Construction Emissions (lbs/day) ................................ ................................ ............... 3.2-15 Table 3.2-7. Operational Emissions (lbs/day) ................................ ................................ ................. 3.2-17 Table 3.3-1. Biological Resources Summary of Impacts ................................ ................................ .. 3.3-1 Table 3.3-2. Wildlife Species Potential for Occurrence ................................ ................................ ..... 3.3-5 Table 3.3-3. Plant Species Potential for Occurrence ................................ ................................ ........ 3.3-7 Table 3.3-4. Project Vegetation Community/Land Use Impacts ................................ ..................... 3.3-18 Table 3.4-1. Cultural Resources Summary of Impacts ................................ ................................ ..... 3.4-1 Table 3.5-1. Energy Summary of Impacts ................................ ................................ .......................... 3.5-1 Table 3.5-2 Hours of Operation for Construction Equipment ................................ ......................... 3.5-13 Table 3.5-3 Construction Equipment Diesel Demand ................................ ................................ ..... 3.5-14 Table 3.5-4 Construction Worker Vehicle Gasoline Demand ................................ .......................... 3.5-14 Table 3.5-5 Construction Vendor Truck Diesel Demand ................................ ................................ . 3.5-15 Table 3.5-6 Construction Haul Truck Diesel Demand ................................ ................................ ..... 3.5-15 Table of Contents
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Table 3.5-7 Mobile Source Fuel Consumption - Operation ................................ ............................. 3.5-16 Table 3.6-1. Geology and Soils Summary of Impacts................................ ................................ ........ 3.6-1 Table 3.7-1. Greenhouse Gas Emissions Summary of Impacts ................................ ....................... 3.7-1 Table 3.7-2. Expected Annual Construction CO2e Emissions Summary (Proposed Project) ......... 3.7-14 Table 3.7-3. SDG&E Energy Intensity Factors ................................ ................................ ................. 3.7-15 Table 3.7-4. Project Consistency with Applicable CAP Checklist Measures ................................ ... 3.7-16 Table 3.7-5. Proposed Project Operational Emissions Summary (MT/Year) ................................ . 3.7-17 Table 3.7-6. MU3 General Plan Buildout Scenario - Annual Construction CO2e Emissions Summary ................................ ................................ ................................ ................................ ................... 3.7-18 Table 3.7-7. MU3 General Plan Buildout Scenario Operational Emissions Summary (MT/Year) ........... ................................ ................................ ................................ ................................ ................... 3.7-18 Table 3.8-1. Hazards and Hazardous Materials Summary of Impacts ................................ ............. 3.8-1 Table 3.9-1. Hydrology/Water Quality Summary of Impacts ................................ ............................. 3.9-1 Table 3.10-1. Land Use Summary of Impacts ................................ ................................ ................. 3.10-1 Table 3.10-2. Levels of Service Criteria for Intersections ................................ ............................... 3.10-4 Table 3.10-3. Peak Hour Intersection LOS – Existing Conditions ................................ ................... 3.10-5 Table 3.10-4. Roadway Segment LOS – Existing Conditions ................................ .......................... 3.10-6 Table 3.10-6. Project Trip Generation................................ ................................ ............................ 3.10-16 Table 3.10-7. Near-Term Year (2025) Intersection Operations Without and With Project.......... 3.10-17 Table 3.10-8. Near Term (Year 2025) Roadway Segment Operations................................ ......... 3.10-19 Table 3.10-9. Horizon Year (2050) Intersection Operations Without and With Project .............. 3.10-21 Table 3.10-10. Horizon Year (2050) Roadway Segment Operations ................................ ........... 3.10-23 Table 3.10-11. Proposed Project and Existing Zoning Comparison ................................ ............. 3.10-26 Table 3.10-12. Project Consistency with Applicable San Marcos General Plan Goals and Policies ........ ................................ ................................ ................................ ................................ ................. 3.10-28 Table 3.11-1. Noise Summary of Impacts ................................ ................................ ....................... 3.11-1 Table 3.11-2. Measured Ambient Noise Levels ................................ ................................ .............. 3.11-3 Table 3.11-3. Exterior Noise Standards by Zone ................................ ................................ ............. 3.11-8 Table 3.11-4. Permitted Increase in Noise Levels ................................ ................................ .......... 3.11-9 Table 3.11-5. Permitted Increase in Interior Noise Levels................................ .............................. 3.11-9 Table 3.11-6. Groundborne Vibration and Noise Impact Criteria (Human Annoyance)............... 3.11-11 Table 3.11-7. Groundborne Vibration Impact Criteria (Structural Damage) ................................ 3.11-12 Table 3.11-8. Construction Noise Levels ................................ ................................ ....................... 3.11-13 Table 3.11-9. Construction Noise Levels ................................ ................................ ....................... 3.11-14 Table 3.11-10. Rock Crushing Noise Levels ................................ ................................ .................. 3.11-15 Table 3.11-11. Future Traffic Parameters ................................ ................................ ..................... 3.11-16 Table 3.11-12. Future Exterior Noise Levels (Ground Level) ................................ ........................ 3.11-16 Table 3.11-13. Future Exterior Noise Levels (Second Level) ................................ ........................ 3.11-17 Table 3.11-14. Future Exterior Noise Levels (Third Level) ................................ ............................ 3.11-18 Table 3.11-15. Vibration Levels from Construction Activities (Residential Receptors) ............... 3.11-20 Table 3.12-1. Population/Housing Summary of Impacts ................................ ............................... 3.12-1 Table 3.12-2. Forecasted Growth for the San Diego Region and the City of San Marcos ............. 3.12-4 Table 3.13-1 Public Services Summary of Impacts................................ ................................ ......... 3.13-1 Table 3.13-2. San Marcos Fire Station Staffing ................................ ................................ .............. 3.13-2 Table 3.13-3. Enrollment and Capacity by School ................................ ................................ .......... 3.13-8 Table 3.14-1. Recreation Summary of Impacts................................ ................................ ............... 3.14-1 Table 3.14-2. Proposed Open Space Summary ................................ ................................ .............. 3.14-5 Table 3.15-1. Transportation/Traffic Summary of Impacts ................................ ............................ 3.15-1 Table 3.15-2. Bicycle Mobility ................................ ................................ ................................ .......... 3.15-3 Table of Contents
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Table 3.15-2. VMT Impact Threshold by Land Use................................ ................................ .......... 3.15-9 Table 3.15-3. Project VMT Findings ................................ ................................ ............................... 3.15-10 Table 3.15-4. Vehicle Queue Summary ................................ ................................ ......................... 3.15-12 Table 3.16-1. Tribal Cultural Resources Summary of Impacts ................................ ....................... 3.16-1 Table 3.17-1. Utilities and Service Systems Summary of Impacts ................................ ................. 3.17-1 Table 3.17-2. RDDMWD Projected Water Demands in Acre Feet Per year ................................ .... 3.17-4 Table 3.17-3. RDDMWD Water Shortage Contingency Plan ................................ ........................... 3.17-7 Table 3.17-4. Existing (2010-2014) Wastewater Flow Summary ................................ ................ 3.17-14 Table 3.17-5. Projected Wastewater Flows within VWD Service Area ................................ .......... 3.17-15 Table 4-1. Summary of Alternatives and Project Objectives ................................ .............................. 4-26 Table 4-2. Comparison of Impacts of Proposed Project and Alternatives ................................ ......... 4-28

Technical Appendices (Included on CD in back pocket)
Appendix A.1 Specific Plan
Appendix A.2 Conceptual Landscape Plan
Appendix A.3 Tentative Map
Appendix B.1 Initial Study Checklist
Appendix B.2 Notice of Preparation
Appendix B.3 NOP Comment Letters
Appendix C Lighting Photometric Plot Exhibits
Appendix D Air Quality Assessment
Appendix E.1 Biological Technical Report
Appendix E.2 45 Day California Gnatcatcher Survey Report Appendix E.3 Special-Status Plant Survey Results
Appendix E.4 Jurisdictional Findings
Appendix F.1 Cultural Resources Inventory Study
Appendix F.2 Archaeological Significance Evaluation
Appendix G Geotechnical Investigation
Appendix H.1 Greenhouse Gas Assessment
Appendix H.2 CAP Consistency Checklist
Appendix I Phase 1 and Phase II Environmental Site Assessment Appendix J.1 Preliminary Drainage Report
Appendix J.2 PDP Stormwater Quality Management Plan (SWQMP) Appendix K Transportation Impact Analysis & Local Transportation Analysis Appendix L Noise Assessment
Appendix M Service Provider Letters
Appendix N.1 VWD Sewer Study
Appendix N.2 RDDMWD Water Service Letter

Table of Contents
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Acronyms
AB Assembly Bill
ADA Americans with Disabilities Act
ADT Average Daily Trips
AF Acre Feet
AFY Acre Feet Per Year
AIA Airport Influence Area
ALUC Airport Land Use Commission
ALUCP Airport Land Use Compatibility Plan
AMSL Above Mean Sea Level
ANFO Ammonium Nitrate/Fuel Oil
ANSI American National Standards Institute
APN Assessor’s Parcel Number
AQIA Air Quality Impact Assessment
AQMD Air Quality Management District
ASTM American Society for Testing and Materials
AWSC All Way Stop Control
BAU Business-As-Usual
BMP Best Management Practices
BEV Battery Electric Vehicles
BSD Buena Sanitation District
BTA Bicycle Transportation Account
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
CAFE Corporate Average Fuel Economy
CalARP California Accidental Release Program
CalEEMod California Emissions Estimator Model
Cal/EPA California Environmental Protection Agency
CALGreen California Green Building Standards Code
Cal/OSHA State of California Occupational Safety and Health Administration
CalRecycle Department of Resources Recycling and Recovery Caltrans California Department of Transportation
CAP Climate Action Plan
CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CBC California Building Code
CC&R Covenants, Conditions, and Restrictions
CCA Community Choice Aggregation
CCAA California Clean Air Act
CCR California Code of Regulations
CCSYA Critical Coarse Sediment Yield Areas
CDFW California Department of Fish and Wildlife
CEC California Energy Commission
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CEQA California Environmental Quality Act
CESA California Endangered Species Act
CFD Community Facilities District
CFR Code of Federal Regulations
CFS Cubic Feet Per Second
CGS California Geological Survey
CH4 Methane
CHP California Highway Patrol
CHRIS California Historical Resources Information System CIP Capital Improvement Program
CIWBM California Integrated Waste Management Board
CMP Congestion Management Plan
CMWD Carlsbad Municipal Water District
CNEL Community Noise Equivalent Level
CO Carbon Monoxide
CO2 Carbon Dioxide
CO2e CO2 Equivalent
COPPS Community Oriented Police and Problem Solving
CPTED Crime Prevention Through Environmental Design
CPUC California Public Utilities Commission
CRPR California Rare Plant Rank
CRHR California Register of Historic Resources
CSS Coastal Sage Scrub
CSUSM California State University San Marcos
CUP Conditional Use Permit
CUWCC California Urban Water Conservation Council
CWA Clean Water Act
CWC California Water Code
CWPP Community Wildfire Protection Plan
CY Cubic Yard
dB Decibel
dBA A-weighted Decibel
DDE Dichlorodiphenyldichloroethylene
DEH Department of Environmental Health
DEIR Draft Environmental Impact Report
DMV Department of Motor Vehicle
DOF Department of Finance
DOT Department of Transportation
DPR Department of Parks and Recreation
DTSC Department of Toxic Substances Control
DU Dwelling Unit
DU/Acre Dwelling Unit/Acre
DWR Department of Water Resources
E East
EDCO EDCO Waste and Recycling
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EIR Environmental Impact Report
EISA Energy Independence and Security Act
EO Executive Order
ESA Endangered Species Act
ESA Environmental Site Assessment
EV Electric Vehicle
EWA Encina Wastewater Authority
EWPCF Encina Water Pollution Control Facilities
FAA Federal Aviation Administration
FAC Facultative
FAR Federal Aviation Regulations
FAR Floor Area Ratio
FEIR Final Environmental Impact Report
FEMA Federal Emergency Management Agency
FERC Federal Energy Regulatory Commission
FHWA Federal Highway Administration
FPA Focused Planning Area
FPP Fire Protection Plan
FRA Federal Rail Administration
FT Feet
FTA Federal Transit Administration
FCEV Fuel Cell Electric Vehicles
GHG Greenhouse gas
GPA General Plan Amendment
GPD Gallons Per Day
GPM Gallons Per Minute
GV Grading Variance
GWP Global Warming Potential
HA Hydrologic Area
HAPs Hazardous Air Pollutants
HARRF Hale Avenue Resource Recovery Facility
HCFC Hydrochlorofluorocarbons
HCM Highway Capacity Manual
HFC Hydrofluorocarbons
HFRA Health Forests Restoration Act
HMBP Hazardous Material Business Plan
HMP Hydromodification Plan
HOV High-Occupancy Vehicle
HRA Hazards Risk Assessment
HREC Historical Recognized Environmental Condition
H&SC Health and Safety Code
I-5 Interstate
IBC International Building Code
ICC International Code Council
ID Improvement District
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IDA International Dark Sky Association
IEPR Integrated Energy Policy Report
IFC International Fire Code
in/sec inch per second
IPCC Intergovernmental Panel on Climate Change
ISO Insurance Service Office
IWMA Integrated Waste Management Act
IWMP Integrated Waste Management Plan
JRMP Jurisdictional Runoff Management Program
Kg Kilogram
kV Kilovolt
kWh Kilowatt-hour
LBP Lead-based Paint
Lbs/Day Pounds per Day
LCFS Low Carbon Fuel Standards
LED Light Emitting Diode
Leq Equivalent Sound Level
LI Light Industrial
LID Low Impact Development
LNG Liquefied Natural Gas
LOS Level of Service
LCFS Low Carbon Fuel Standard
LTF Local Task Force
LTS Less than Significant
LTSM Less than Significant with Mitigation
LUST Leaking Underground Storage Tank
MBTA Migratory Bird Treaty Act
MEP Maximum Extent Possible
MFSDP Multi-Family Site Development Plan
MG Million Gallon
MG/M3 Milligrams per Cubic Meter
MGD Million Gallons Per Day
MGY Million Gallons Per Year
MHCP Multiple Habitat Conservation Plan
MLLW Mean Lower Low Water
MM Mitigation Measure
MMCFD Million Cubic Feet Per Day
MMT Million Metric Tons
MMTCO2e Million Metric Tons of CO2 Equivalent
MOU Memorandum of Understanding
MPH Miles Per Hour
MRF Meadowlark Reclamation Facility
MRZ Mineral Resource Zone
MSCP Multiple Species Conservation Program
MS4s Separate Storm Sewer Systems
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MSSC Minor Street Stop Controlled Intersection
MT Metric Ton
MU3 Mixed Use 3
MWD Metropolitan Water District
N2 Nitrogen
N2O Nitrous Oxide
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NBL Northbound Lane
NCCP Natural Community Conservation Planning
NCTD North County Transit District
NEVs Neighborhood Electric Vehicles
NHPA National Historic Preservation Act
NHTSA National Highway Traffic Safety Administration
NO2 Nitrogen Dioxide
NOP Notice of Preparation
NPDES National Pollutant Discharge Elimination System
NRHP National Register of Historic Places
NSLU Noise Sensitive Land Use
NTA Northern Tributary Area
O2 Oxygen
O3 Ozone
OCPs Organochlorine pesticides
OEHHA Office of Environmental Health Hazards Assessment OS Open Space
OPR Office of Planning and Research
Pb Lead
PC Per Capita
PDP Priority Development Project
PFCs Perfluorocarbons
PFF Public Facility Fee
PG&E Pacific Gas & Electric
PHEV Plug-In Hybrid Electric Vehicles
PM2.5 Fine Particulate Matter
PM10 Respirable Particulate Matter
PPB Parts Per Billion
PPHM Parts Per Hundred Million
PPIC Public Policy Institute of California
PPM Parts Per Million
PPV Peak Particle Velocity
PRC Public Resources Code
PRD Planned Residential Development
PVC Polyvinyl Chloride
RAQS Regional Air Quality Strategies
RBC Rocks Biological Consulting
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RCP Regional Comprehensive Plan
RCP Reinforced Concrete Pipeline
RCRA Resource Conservation and Recovery Act
RDDMWD Rincon del Diablo Municipal Water District
REC Recognized Environmental Conditions
RES Residential
Renewable Fuel Standard RFS
RHNA Regional Housing Needs Assessment
RMP Risk Management Plan
RMS Root Mean Square
ROZ Ridgeline Overlay Zone
RPS Renewable Portfolio Standard
RTP Regional Transportation Plan
RWQCB Regional Water Quality Control Board
RZ Rezone
SAFE Safer Affordable Fuel-Efficient
S.F. Square Feet
SF6 Sulfur Hexafluoride
SANDAG San Diego Association of Governments
SB Senate Bill
SCAQMD South Coast Air Quality Management District
SCIC South Coastal Information Center
SCS Sustainable Communities Strategy
SDAB San Diego Air Basin
SDAPCD San Diego Air Pollution Control District
SDCWA San Diego County Water Authority
SDG&E San Diego Gas & Electric
SDNR San Diego Northern Railroad
SDP Site Development Permit
SF6 Sulfur Hexafluoride
SFNA School Facilities Needs Assessment
SHMA Seismic Hazards Mapping Act
SIP State Implementation Plans
SLF Sacred Lands File
SMFD San Marcos Fire Department
SMFPD San Marcos Fire Protection District
SMUSD San Marcos Unified School District
SO2 Sulfur Dioxide
SOV Single Occupancy Vehicle
SP Service Population
SPA Specific Plan Area
SRA State Responsibility Areas
SR-76 State Route 76
SR-78 State Route 78
SU Significant and Unavoidable
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SUSMP Standard Urban Stormwater Mitigation Plan
SWDA Solid Waste Disposal Act
SWRCB State Water Resources Control Board
SWP State Water Project
SWPPP Stormwater Pollution Prevention Plan
SWQMP Stormwater Quality Management Plan
TACs Toxic Air Contaminants
TAZ Traffic Analysis Zone
T-BACT Toxics Best Available Control Technology
TCA Traditionally and Culturally Affiliated
TDM Transportation Demand Management
TIAG Transportation Impact Analysis Guidelines
TOVWTP Twin Oaks Valley Water Treatment Plan
TMDL Total Maximum Daily Load
TSM Tentative Subdivision Map
UBC Uniform Building Code
USACE U.S. Army Corps of Engineers
USBR U.S. Bureau of Reclamation
USDOT U.S. Department of Transportation
USEPA U.S. Environmental Protection Agency
USFWS U.S. Fish and Wildlife Service
USGS U.S. Geological Survey
UST Underground Storage Tank
UWMP Urban Water Management Plan
V/C Volume-To-Capacity
VCMWD Valley Center Municipal Water District
Vdb Vibration Velocity
VHFHSZ Very High Fire Hazard Severity Zone
VID Vista Irrigation District
VMT Vehicle Miles Traveled
VOCs Volatile Organic Compounds
VWD Vallecitos Water District
WB Westbound
WELO Water Efficiency Landscape Ordinance
WMA Watershed Management Area
WQIP Water Quality Improvement Plan
WUI Wildland Urban Interface
ZEV Zero Emission Vehicle
μg/m3 Micrograms Per Cubic Meter

Hallmark-Barham Specific Plan November 2021
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1.0 Summary

1.1 Project Summary
The applicant is proposing to develop 151 multi-family residential units and associated common and private open space as contemplated in the Hallmark-Barham Specific Plan (proposed project) on a

10.56-acre site located at 943 E. Barham Drive, west of La Moree Road in the City of San Marcos.

The project applicant is reques ting the following discretionary approvals from the City to allow for development of the proposed project:
• General Plan Amendment (GP20 -0002) – A General Plan Amendment would be required to change the existing Mixed Use 3 (MU3) designation to Specific Plan Area (SPA). • Specific Plan (SP20 -0002) - The Specific Plan establishes the development rules and regulations of all land uses within the project site. Upon adoption of the Specific Plan by the City, all development within the project site must conform to t he regulations of the Specific Plan.
• Rezone (R20-0001) - A rezone would be required to change the existing Mixed -Use-3 (MU-3) zoning to Specific Plan Area (SPA).
• Multi-Family Site Development Plan (MFSDP20 -0001) - The Site Development Plan approval would be required to construct 151 multi -family residential units and address the details of the architectural style, building elevation, fencing, landscaping, among other criteria, within the development.
• Tentative Subdivision Map (TSM20 -0001) – A Tentative Subd ivision Map would be required for formation of residential condominium units, private driveways, and open space areas. • Conditional Use Permit (CUP20 -0007) - A Conditional Use Permit would be required for potential use of a temporary rock crusher.
• Grading V ariance (GV20 -0002) - A Grading Variance would be required to allow manufactured slopes and/or retaining walls in excess of 20 feet in height without benching within the project area.

1.2 Summary of Significant Effects/Mitigation
Table 1 -1, Summary of Significant Environmental Impacts, provides a summary of significant environmental impacts resulting from the project, mitigation measures identified to reduce and/or avoid the environmental effects, and a determination of the level of significance of each impact following implementation of the identified mitigation measures. The analysis shows that , with implementation of mitigation measures, all project impacts with the exception of land use and transportation impacts will be mitigated to below a level of significance. Detailed analyses of significant environmental effects and mitigation are provided in Chapter 3 of this Environmental Impact Report (EIR).

In addition to mitigation measures, regulatory standards for grading, construction, and environmental protection have been incorporated into the project design to reduce adverse

1.0 Summary
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environmental effects. These include, but are not limited to, grading design and earthwork specifications, erosion control measures, Best Management Practices (BMPs) for pollutant control during construction, and a biofiltration basins to handle and treat runoff.

The mitigation measures listed in Table 1 -1 will reduce impacts related to biological resources, cultural resources, geology and soils, land use, noise, and transportation. As shown in Table 1 -1, the remaining impacts to land use and transportation would remain significant and unavoidable.

Table 1-1. Summary of Significant Environmental Impacts Impact Mitigation Measures Level of Significance After
Mitigation
Biological Resources
BIO-1: Direct and indirect
impacts to nesting birds
Implementation of MM-BIO-1,
refer to Section 3.3.6 Less than significant
BIO-2: Direct impacts to
sensitive habitats
Implementation of MM-BIO-2,
refer to Section 3.3.6 Less than significant
BIO-3 and BIO-4: Indirect
impacts to sensitive habitats
during project construction and
operation
Implementation of MM-BIO-3
and MM-BIO-4, refer to Section

3.3.6 Less than significant
Cultural Resources and Tribal Cultural Resources
CR-1a and CR-1b: Potential for
impacts to archaeological and
historical resources
Implementation of MM-CR-1a,
MM-CR-1b and MM-CR-1c, refer
to Section 3.4.6
Less than significant
CR:2 Potential for impacts to
human remains
Implementation of MM-CR-2,
refer to Section 3.4.6 Less than significant
Geology and Soils
GEO-1: Potential for impact to
paleontological resources
Implementation of MM-GEO-1,
refer to Section 3.6.6 Less than significant
Land Use
LU-1: Year 2025 impact at
Rancheros Drive/SR-78 WB
resulting in an inconsistency
with Mobility Element policies
Implementation of MM-LU-1,
refer to Section 3.10.6 Significant and unavoidable
LU-2a and LU-2b: Year 2025
and Year 2050 impact at E.

Barham Drive/western project
driveway in the PM Peak hour
Implementation of MM-LU-2,
refer to Section 3.10.6 Less than significant
LU-3a and LU-3b: Year 2025
and Year 2050 impact at E.

Barham Drive/eastern project
driveway in the PM Peak hour
Implementation of MM-LU-3,
refer to Section 3.10.6 Less than significant

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Impact Mitigation Measures Level of Significance After
Mitigation
Noise
N-1: Noise impact related to
rock drilling
Implementation of MM-N-1,
refer to Section 3.11.6 Less than significant
N-2: Noise impact related to
rock crusher
Implementation of MM-N-2,
refer to Section 3.11.6 Less than significant
N-3 and N-4: Noise impact
related to future onsite roadway
noise
Implementation of MM-N-3,
MM-N-4, and MM-N-5, refer to
Section 3.11.6
Less than significant
Transportation
TR-1: Conflict with Mobility
Element policies addressing
roadways
Implementation of MM-LU-1,
MM-LU-2, and MM-LU-3, refer
to section 3.10.6
Significant and unavoidable
TR-2: Project and cumulative
impact related to vehicle miles
traveled
None Significant and unavoidable

1.3 Areas of Controversy
A Notice of Preparation (NOP) was distributed on March 31, 2021, for a 30 -day public review and comment period. Additionally, an online public scoping meeting was held on April 15, 2021.

Public comments were received on the NOP for this EIR and reflect concern over a number of environmental issues (refer to Appendices B.2 and B.3 ). A total of five letters were received and included:
• California Department of Fish and Wildlife
• Caltrans
• Native American Heritage Commission
• San Diego County Archaeological Society
• Sylvia J. Williams
Issues and concerns raised in the NOP comment letters include:
• Biological Resources: sensitive species, scope of biological analysis, analysis of direct and indirect impact to biological resources, and recommended mitigation measures. • Transportation: scope of the study area, existing roadway congestion, appropriate and adequate mitigation, safety.
• Cultural and Tribal Cultural Resources: compliance with Assembly Bill 52 and Senate Bill 18.

1.0 Summary
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These concerns are addressed in Chapters 3 and 4 of this EIR.

1.4 Issues to be Resolved
An EIR is an informational document intended to inform the public agency decision makers and the public of the significant effects of a project, identify possible ways to minimize the significant effects, and describe reasonable alternatives to the project.

The lead agency must respond to each significant effect identified in the EIR by making “Findings” for each significant effect. The is sues to be resolved by the decision makers for the project include whether or how to mitigate the associated significant effects, including whether to implement a project alternative.

Issues to be resolved that are directly related to the proposed project include the choice among the alternatives and whether or how to mitigate the significant effects. In particular, the decision makers must decide if the significant impacts associated with biological resources, cultural resources /tribal cultural resources , geology and soils, and noise have been mitigated to less than significant and whether or not the proposed project’s significant and unavoidable impacts related to land use and transportation would be offset by the benefits of the project. Lastly, the decis ion makers must determine whether any of the project alternatives would substantially reduce significant effects while still meeting key objectives of the project.

1.5 Project Alternatives
Four alternatives are proposed to provide an understanding of how envir onmental effects could be reduced by varying the design and scope of the project. Table 1 -2 provides a comparison of the impacts of project alternatives to the impacts of the proposed project.

1.5.1 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 construction would occur on the project site under this alternative. The project site is curren tly 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, ornamental and ruderal vegetation. H abitat on the project site would not be impacted under this alternative.

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 th is 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 Fees ( PFF), which goes toward supporting variety of services and improvements in the City , including but not limited to Circulation Streets, SR -78 Interchanges, NPDES, Tech Improvements, Parks, and Habitat Conservation . Similarly, this alternative would n ot 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

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Hallmark-Barham Specific Plan November 2021
City of San Marcos Page 1-5
water source for the Mira Lago community, located immediately east of the project site. F inally, this alternative would not meet any of the project objectives.

1.5.2 No Project/Existing Land Use Alternative
Under the No Proj ect/Existing Land Use Alternative, the project site would be developed consistent with the site’s existing land use. Per the City’s General 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 with a maximum floor area ratio (FAR) of 1.50. According to Table 2-3 of the Land Use Element of the City’s General Plan, this designation “Provides for a variety of commercial and office uses integrated as a cohesive development. These uses may be mixed ‘vertically’ (on separate floors of a building) or ‘horizontally’ (on a single site or adjacent parcels). Structured parking, while not required to achieve the maximum FAR, may be allowed. Shared parking arrange ments may also be allowed consistent with the nature of mixed uses. Typical uses include retail, commercial services, administrative and office uses, institutional and government uses, business support and financial uses, restaurants, and health care facilities. To maintain a pedestrian scale and orientation, retail and other active services are encouraged at street level. This designation does not allow residential uses. A Specific Plan is required for development” (City of San Marcos 2012).

A development scenario that wou ld be consistent with the MU3 zoning could include three 3 -story buildings on the project site for a total of 275,067 square feet ( s.f.) of office use and 18,344 s.f. of retail use and 879 parking spaces. The southern portion of the project site would be r eserved 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 Alter native would be approximately four times higher than the proposed project. This alternative would generate approximately 5,410 ADT compared to the 1,208 ADT anticipated for the project.

The No Project/Existing Land Use Alternative would result in a more intensive use on the project site, including four times the trip generation compared to the proposed project (5,410 ADT compared to 1,208 ADT). This results in a corresponding increase in air and greenhouse gas emissions and noise from offsite 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 area would be disturbed . Th is alternative would not generate any students for SMUSD. Depending on the mix of Vehicle Miles Traveled ( VMT) reduction strategies an employer implements and the number of employees who participate, it could be possible to reduce the VMT impacts to below a level of significance. This alternative could meet some of the project objectives.

1.5.3 Reduced Density Alternative
Under the Reduced Density Alternative, the project 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 fuel modification buffer. Overall, the development footprint and area of disturbance would be similar to that of the proposed project, but with fewer residential units.

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

Depending on the type and number of units development under this alternative (single family and multi-family), this alternative would generate between 592 and 740 ADT. Compared to the proposed

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Hallmark-Barham Specific Plan November 2021
City of San Marcos Page 1-6
project, which generates 1,208 ADT, this alternative would reduce ADT by at least 38% and up to 50%.

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% -50% and a corresponding decrease in air and greenhouse gas emissions and noise from offsite traffic compared to the proposed project. Public services and utilities, service systems and energy demands would also proportionally decreas e. 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.

1.5.4 Reduced Footprint Alternative
A Reduced Footprint Alter native 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%.

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 offs ite traffic 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 res ources, and geology and soils would be less than the proposed project since less ground disturbing activities would be required . 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. This alternative would meet the majority of the project objectives.

1.5.5 Environmentally Superior Alternative
Table 1 -2 provides a qualitative comparison of the impacts for each alternative compared to the proposed project. As shown in Table 1-2, 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 meet 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 Pro ject 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 Footpr int Alternative is the environmentally superior alternative because it would provide a reduced level of impact in some environmental analysis areas including air quality, greenhouse gas, noise, public services,

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Hallmark-Barham Specific Plan November 2021
City of San Marcos Page 1-7
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 biological resources, cultural resources, geology and soils, noise, tribal cultural resource, and land use (partially mitigated).

Due to project site being in a suburban setting and the limited options there are to mitigate Vehicle Miles Traveled ( 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 ex isting degraded LOS at the intersection 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 District ( CFD) and Public Facilities Fee s (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 rem ain and the significant and unavoidable land use and transportation impacts would still occur under the Reduced Footprint Alternative.

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Table 1-2. 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)

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Hallmark-Barham Specific Plan November 2021
City of San Marcos Page 1-9
Environmental Topic Proposed
Project
No Project/No
Development
Alternative
No Project/Existing Land
Use Designation Alternative
Reduced Density
Alternative
Reduced
Footprint
Alternative

Public Services LTS No Impact
(Reduced)
LTS
(Same)
LTS
(Reduced)
LTS
(Reduced)
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

2.0 Project Description
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-1

2.0 Project Description, Location and Environmental Setting This Draft Environmental Impact Report (EIR) has been prepared by the City of San Marcos to evaluate the potential effects associated with the construction and implementation of the proposed Hallmark-Barham Specific Plan Project (proposed project) as described in Section 2.2 of this EIR. The EIR is intended to provide information to the San Marcos City Council, public agencies, stakeholders and organizations, and the general public regarding the potential environmental impacts, mitigation measures, and alternatives to the proposed project.

2.1 Project Objectives
The following objectives of the Hallmark-Barham Specific Plan describe the underlying purpose of the proposed project and provide a basis for identification of a range of reasonable alternatives evaluated in this EIR. The complete Specific Plan is included as Appendix A.1. • 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 Cit y 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 nature and appearance of all construction within the Hallmark -Barham Specific Plan Area through integration of landform use, architectural design, unified landscape theme, and recreation areas; • Design a safe and 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 righ ts-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 w hich 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.

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-2

2.2 Project Description
The approximate 10.56 -acre site is located at 943 E. Barham Drive, west of La Moree Road in the Barham/Discovery Community. The assessor parcel number (APN) is 228-310-01-00 (Figure 2-1).

The project applicant is requesting approval of a General Plan Amendment, Specific Plan, Rezone, Multi-Family Site Development Plan, Tentative Subdivision Map, Conditional Use Permit, and Grading Variance. If approved, these entitlements would allow for the development of a multi- family residential project on the project site.

The Specific Plan is a compreh ensive planning document that establishes development guidelines for the project site. The Specific Plan will serve as the primary land use, policy, and regulatory document for the project by providing a development planning review process, as authorized b y California Government Code Section 65450, in conjunction with the City of San Marcos Zoning Ordinance, Chapter 20.535. Under the Specific Plan, the only permitted land use would be residential.

The proposed project would allow for the development of 151 multi-family residential units and associated common and private open spaces. The proposed project includes infrastructure improvements as described in greater detail below. The conceptual site plan is included in Figure 2-

2. 2.2.1 Discretionary Actions
As mentioned above, the requested project entitlements/discretionary actions, and permits by the City include a General Plan Amendment, Specific Plan, Rezone, Multi- Family Site Development Plan, Tentative Subdivision Map, a Conditional Use Permit, and a Grading Variance. Each of these actions is described in more detail below. The Specific Plan is included as Appendix A.1 and the project plans are included as Appendix A.2.
• General Plan Amendment (GP20 -0002) – A General Plan Amendment would be required to change the existing Mixed Use 3 (MU3) designation to Specific Plan Area (SPA). • Specific Plan (SP20 -0002) - The Specific Plan establishes the development rules and regulations of all land uses within the project site. Upon adoption of the Specific Plan by the City, all development within the project site must conform to the regulations of the Specific Plan. The Specific Plan would be required to be reviewed and approved concurrently with the Multi-Family Site Development Plan application.
• Rezone (R20-0001) - A rezone would be required to change the existing Mixed -Use-3 (MU-3) zoning to Specific Plan Area (SPA).
• Multi-Family Site Development Plan (MFSDP20 -0001) - The Site Development Plan approval would be required to construct 151 multi -family residential units and address the details of the architectural style, building elevation, fencing, landscaping, among other criteria, within the development.
• Tentative Subdivision Map (TSM20 -0001) – A Tentative Subdivision Map would be required for formation of residential condominium units, private driveways, and open space areas. • Conditional Use Permit (CUP20 -0007) - A Conditional Use Permit would be required for potential use of a temporary rock crusher.

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-3
• Grading Variance (GV20-0002) - A Grading Variance would be required to allow manufactured slopes and/or retaining walls in excess of 20 feet in height without benching within the project area.

2.2.2 Project Characteristics
This section details the characteristics of the proposed project.

2.2.2.1 Land Use
The Specific Plan will be comprised of a residential land use component containing open space, as detailed below.

Residential Land Use
The proposed project proposes 151 multi -family residential units situated on approximately 10.6 gross acres. The site plan is included as Figure 2 -2. Residential buildings compose approximately

2.8-acres of the project site. Multi- family residential dwelling units are comprised of one, two, and three-story condominiums with ten dwelling unit types intersp ersed throughout the project site.

Overall building heights will not exceed 40 feet.

Open Space
There are two main categories of open space proposed for the project – common open space and private open space . Common open space will total approximately 5.35 acres and includes open space with grades 10 percent and greater, common open space with grades less than ten percent, the water quality basin/bioretention area and recreational areas.

Private open space is associated with private patio and deck areas on the residential units. The open space concept plan is included as Figure 2-3 and Table 2-1 summarizes the proposed open space areas.

Common Open Space
Common open space is divided into: 1) common open space area with grades 10 percent or greater; 2) common open space area with grades less than 10 percent; 3) the water quality basin/bioretention area; and 4) recreational areas.

Common Open Space – Grades 10 Percent or Greater
The first category is common open space with grades of 10 percent or greater. Accor ding to the City of San Marcos Zoning Ordinance, open space of 10 percent grade or greater cannot be counted as usable open space. This category includes open space features such as landscaping and slopes and encompasses 134,776 square feet (s.f.).

Common Open Space – Grades Less than 10 Percent
Common open space areas with grades less than 10 percent are considered to be usable open space. These are landscaped areas and other areas which encourage relaxation activities such as observing nature, bird watchi ng, painting, photography, and picnicking as well as recreational open space areas such as open turf areas. This encompasses 64,913 s.f.

2.0 Project Description
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-4
Table 2-1. Proposed Open Space Summary
Open Space Description Square Feet Provided
Common Open Space
Common Open Space
(Grades 10 percent or greater) 134,776(1)
Common Open Space
(Grades less than 10 percent) 64,913(2)
Water Quality Basin/Bio-retention
Area 6,764(1)
Recreational Areas 10,742(2)
Private Open Space
Private Open Space
(Patios/Decks) 26,390
Notes: (1) Per the Zoning Ordinance, open space areas with grades of 10 percent or greater and the water quality basin/bioretention areas do not count as usable open space (2) Open space with grades of less than 10 percent and recreational areas count towards the project’s usable open space calculation.

Common Open Space – Water Quality Basin/Bioretention Area The project includes a 6,764 -s.f. water quality basin area. This is a non -usable open space area located in the northwest corner of the project site which is used to direct water during rain events to control for flooding and to treat water before it is discharged from the site. The water quality basin/bioretention area does not count towards usable common open space.

Common Open Space – Recreational Areas
The proposed project includes five recreational open space areas totaling 10,742 s.f., inclusive of multi-age play areas, tot lots, seating, barbeque stations, open turf areas, and patio areas. These areas will be maintained by the Homeowners Association and include:
• A 3,564 s.f. primary recreation area will provide residents with amenities such as a barbeque counter and patio space, a bocce ball court, and a tot lot with seating and open turf area.

Excluding the tot lot, other recreationa l amenities within the primary recreation area may be substituted to make room for a pool.
• A 2,345 s.f. multi -age recreation area has been established adjacent to Building 12 and includes a multi-age play structure, open turf area, and bench seating. • A 1,805 s.f. amenity space adjacent to Building 1 will include an enhanced paved patio area, tables with seating, open turf areas and a dog wash station. • A 1,552 s.f. overlook tot lot area provided adjacent to Building 17 includes features such bench seating, a fire pit with seating, walkways, and a tot lot. • A 1,476 s.f. amenity space adjacent to Building 25 includes a dog wash and open turf area.

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-5
Private Open Space
Private open space within the proposed project consists of private patio space and private balcony/deck space. The City requires that each unit with ground floor living must provide 250 s.f. of private open space. Units with living space on the second floor and above must provide 50 s.f. of private open space in the form of decks or balconies . There is a total of 88 units within the proposed project that include ground floor living space and 63 units with living area on the second floor or above. Therefore, according to the City of San Marcos Zoning Ordinance, the units with ground floor living would be required to provide 22,000 s.f. of private patio space and the units with living space on the second floor and above would be required to provide approximately 3,150 s.f. of balcony/deck space. Combined, the minimum private open space required for the pr oposed project equates to 25,150 s.f. The proposed project provides a total of 26,390 s.f. of outdoor private space and will exceed the City’s requirement.

Landscape Plan
The proposed landscape plan includes a mix of trees, shrubs, grasses and groundcover and the plant selection emphasizes moderate water use species. The landscape concept plan is included as Figure 2-4a and the plant material guide is included as Figure 2-4b.

Proposed tree species include desert willow, majestic beauty Indian hawthorn, California laurel, columnar Italian cypress, fern pine, western redbud, European olive, Mexican palo verde, African suman, strawberry tree, flaxleaf paperbark, and date palms. See Figure 2-4b for a comprehensive list of proposed plant materials. The project will also comply with the City’s Model Water Efficient Landscape Ordinance (WELO) and Municipal Code, Title 20.

2.2.2.2 Architectural Design
The project will have a Contemporary Spanish architectural style. Proposed materials include wood, stucco, brick with decorative metal accents and trims . The project includes a variety of floor plans to allow for the articulation of the building elevations. One -story, two-story, and three -story product types are included with the project. The project proposes 19 7 -Plex Buildings (133 units) and six 3 - plex buildings (18 units) for a total of 151 units. A 1,160 s.f. central recreation building is also proposed that would have a kitchen, living room, dining room, California room, patio, restroom, and storage area.

Figure 2-5a presents the architectural concept for the 3 -plex buildings and Figures 2- 5b and 2-5c presents the architectural concepts for the 7-plex buildings.

2.2.2.3 Walls, Fencing, Entry Monuments and Lighting
Walls, fences, and monuments within the proposed project are f unctional boundaries framing outdoor spaces and complementary pieces of the landscape design. Walls, fences, and monuments create partitions between private open space, screen the development from roadways, reduce noise from roadways, and enhance the overall site design.

Fencing and Walls
Fence and wall types allowed under the Specific Plan include tubular steel, split face block/earth - tone color, living hedge with tubular steel gate, wood, or vinyl privacy fencing. Walls and fences would be designed in such a way as to become a visual amenity, compatible with the surrounding natural landscape’s colors and materials.

Figure 2-6 presents the conceptual fence and wall plan.

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-6
Standard masonry walls and masonry retaining walls would be used where engineering requ ires more stability and strength. Masonry retaining walls would be split face block and may incorporate fencing along the top of the wall.

Private open space fencing would utilize wood, vinyl, block, or tubular steel and be fire resistant as needed. Living walls (hedges) are encouraged as a private open space fencing option. Fencing around recreational areas would be tubular steel or other similar material and design.

Lighting
Lighting for the proposed project will be used to accent landscaping and provide safety and accent lighting for multi -family building clusters. All lighting fixtures for the proposed project will be energy efficient architecturally appropriate, and designed to minimize glare, conflict, and light pollution, while providing illumination levels that create a safe environment for both vehicles and pedestrians.

Street area lights will be full cut-off fixtures and will utilize house-side shields to reduce light trespass and prevent light pollution . Common area lighting will be used to enhance and complement the character of the development. Conceptual lighting fixtures and locations are illustrated on Figure 2-7.

Lighting will be required to conform with the City’s lighting ordinance and standards.

2.2.2.4 Access, Circulation and Parking
Access
Access to the project site will be via two unsignalized driveways on E. Barham Drive. The western driveway will be 40 -feet wide and serve as the primary entry to the project site and provide full access. The eastern driveway will be 26 -feet wide and will a lso provide full access . Based upon mitigation measures identified in Section 3.10, Land Use (MM-LU-2 and MM-LU-3), the project will be required to limit left turns out of both driveways between the PM Peak Hour (4:00 PM to 6:00 PM).

A secondary emergency -only access is provided through the western boundary of the project site at the western terminus of Street “C”. This access will connect to an existing emergency access driveway on the adjacent property which connects to Saddleback Way and then to E. Barha m Drive.

This access point is for emergency vehicles only and bollards would be put in place.

Circulation
Internal roadways are designed to provide safe movement of bicycle, pedestrian, and vehicle traffic through the project site and to provide attractive frontages to residential lots. Figure 2-8 presents the conceptual circulation plan. Typical cross sections for the proposed private driveways and alleys are shown on
Figure 2-9a and Figure 2-9b.

Vehicular circulation through the project will be via three private 26 -foot-wide internal streets, Driveways “A”, “B” and “C”. These streets provide access to private alleys (Alleys A through K) . In addition, the proposed project provides an accessible path of travel through the site and to each residence via pedes trian pathways that also connect to the sidewalk on E. Barham Drive which is identified as an Urban Trail per the City’s Master Trails Plan.

Parking
The project proposes a total of 349 parking spaces. This includes 283 garage spaces associated with the uni ts, which will be pre -wired for electric vehicle charging stations. One -bedroom units will

2.0 Project Description
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-7
have a one -car garage and all other units will have a two -car garage . An additional 66 outdoor parking spaces would be provided with 10 of these spaces assigned to u nits and 56 spaces for guests. Of those outdoor spaces, three will be ADA spaces. The project will provide three EV charging stations in the guest parking area.

2.2.2.5 Grading and Construction Phase
The project is expected to start construction in late 2022 with an occupancy of 2025. The project would be constructed in one phase and all construction materials would be stored onsite.

Grading
Grading will consist of approximately 39,711 cubic yards (CY) of cut material and 86,052 CY of fill material requiring an imp ort of approximately 46,341 CY of material. The grading concept plan is presented in Figure 2-10. Material import is expected to take 103 days. Assuming the use of a 15 CY haul truck, approximately 3.090 trips will be required, which is approximately 30 tr uck trips per day.

The import and export of earth material is guided by Section 17.32.080 of the City’s Municipal Code and prior to any import of soils, a haul route will be submitted for review and approval by the City Engineer. Additionally, grading and other earth moving activities are restricted to the hours of 7:00 AM and 4:30 PM, Monday through Friday, per Section 17.32.180 of the City’s Municipal Code.

The project would implement fugitive dust control measures outlined in Section 87.426 of the City’s Grading Ordinance, which would include watering the site a minimum of twice daily to control dust, as well as reducing speeds on unpaved surfaces to 15 mph or less, replacing ground cover in disturbed areas quickly, and reducing dust during loading/unloading of dirt and other materials.

Grading Variance
A grading variance is required for projects including slopes and/or retaining walls that exceed 20 feet in height without benching. Areas where slopes are proposed to be greater than 20 feet include the southern extent of development (31.6 -foot maximum slope height), a small area on the western edge of the project site (25.8 -foot maximum slope height) and a portion of the project frontage with E. Barham Drive (22.8-foot maximum slope height with 6-foot retaining wall).

Figure 2-11 depicts the
areas that are proposed to have manufactured slopes without benching in excess of 20 feet in height. Approval of a grading variance allows for reduced grading and lower overall slope heights due to the removal of benching.

Blasting and Rock Crushing
Due to granitic bedrock conditions, blasting and rock crushing may be required during the project grading and site preparation activities. If required, blasting would be needed in the northeast portion of the project site. The project would comply with all provisions identified in the City’s Municipal Code Section 17.60.06 as it relates to blasting and blasting shall only be permitted between the hours of 9:00 AM and 4:00 PM during any weekday. Blasting also required iss uance of a Blasting Permit from the San Marcos Fire Department. The project’s requested approvals include a Conditional Use Permit, which would allow for the use of the temporary rock crusher.

2.0 Project Description
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-8

2.2.2.6 Public Utilities and Services
Water Facilities
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 has confirmed their ability to serve the project (RDDMWD 2021).

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 Vallecitos Water District (VWD) line in E. Barham Drive. 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 were to be 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 driveways “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 -inch domestic water lines will connect to the existing 10 -inch and 8- inch public water mains underneath E. Barham Drive.

Wastewater Facilities
The project site is within the service area of VWD for wastewater service, specifically within VWD’s Sewer Improvements District “A”. The project will connect to existing VWD sewer infrastructure and VWD has indicated they can serve the project (VWD 2020).

Preliminary sewer design for the project determined 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 private 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 proposed wastewater concept.

Site Drainage and Stormwater Management
Storm drain systems and connections would be designed to accommodate the proposed future development. One biofiltration basin is proposed at the northwest corner of the project site. The biofiltration basin would be approximately 6,764 s.f. Stormwater flow s will be conveyed to the filtration system via storm drains, where water will be cleaned prior to being discharged. The conceptual drainage plan is presented in
Figure 2-14. Hydromodification will be required with final engineering submittals in conforman ce with the 2016 City of San Marcos Best Management Practices Design Manual.

Electricity and Gas
Electricity and natural gas would be provided by San Diego Gas & Electric (SDG&E). The proposed project would connect to the existing underground 69KV 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.

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Solid Waste Disposal
Solid waste collection and recycling services to the proposed project would be provided by EDCO Waste & Recycling . Non-recyclable waste, including general trash and green materials, is collected and transported to the Sycamore Sanitary Landfill in Santee . Recyclable materials are transferred to the Escondido Resources Recovery Transfer Station for further processing.

Fire Protection
The project is located within the San Marcos Fire Protection District b oundary. The San Marcos Fire Department (SMFD) would provide fire protection for urban and wildland fires and emergency services to the project site. SMFD services San Marcos with four stations, the closest of which is Fire Station No. 3 located at 404 Woodland Parkway approximately 0.50 miles north of the project site.

Police Protection
Police protection for the proposed project would be provided by the County of San Diego Sheriff’s Department. The County Sheriff provides contract law enforcement services to the City of San Marcos through the station located at 182 Santar Place located within City limits. The station’s location is approximately 0.60 miles northwest of the project site. The Sheriff’s Department provides services to San Marcos and the surrounding unincorporated areas.

Schools
The project site is within the San Marcos Unified School District (SMUSD) boundary. SMUSD is 49 square miles in size and encompasses most of the City of San Marcos and portions of the Cities of Vista, Escondido, and Carlsbad, as well as unincorporated areas of the County of San Diego between these cities. Students generated by the project would attend Knob Hill Elementary School, Woodland Park Middle School, and Mission Hills High School.

Parks
There are 16 major community parks and 18 mini parks located throughout the City. The City residents in the project area are currently served by several nearby parks. The closest parks to the project site are the Alder Glen tot lot and Jack’s Pond Park. The Alder Glen tot lot include s a kiosk, permanent restrooms, play equipment and trail connections . Jack’s Pond Park consists of picnic areas, trails, tot play lot, restrooms, Native Center, and turf area.

Libraries
The City is served by the San Diego County Library. The San Marcos Bra nch is located at 2 Civic Center Drive, approximately 1.25 miles northwest of the project site.

2.2.2.7 Offsite Improvements
As part of the project, RDDMWD will extend an existing 8 -inch waterline from the Mira Lago community through the project site to loop and connect with an existing VWD waterline in E. Barham Drive. This will include approximately 50 feet of water line that would be offsite within E. Barham Drive. The water line extension is presented in Figure 2-12.

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To connect the project’s proposed sewer lines to the existing VWD sewer line within E. Barham Drive, approximately 75-feet of off -site connection will be required. The sewer connection is presented in Figure 2-13.

Both of the extensions described would take place within E. Barham Drive and would not impact any vegetation.

2.2.2.8 Economic Characteristics
As discussed in Chapter 6 of the Hallmark-Barham Specific Plan (Appendix A.1), the proposed project would include a Public Facilities and Financing Plan to ensure improvements are implemented in a timely and successful manner. The financing mechanisms for each improvement will be timed with any development of the project site, the City’s conditions of approval, and site plan/design review approval. Refer to Chapter 6 of Appendix A.1 for additional details reg arding the methods of financing of construction and operation of public improvements and services.

Project Design Features
The project incorporates the following design features and will adhere to specific regulatory requirements that will minimize potential environmental effects. These are summarized, in Table 2-2.

Table 2-2. Project Design Features
Aesthetics
• Implementation of the Landscape Plan to provide a cohesive and visually -appealing planting scheme.
• Compliance with the City of San Marcos Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080, Light and Glare Standards.

Air Quality
• Compliance with the San Diego Air Pollution Control District’s (SDAPCD’s) fugitive dust rules and fugitive dust control measures outlined in Section 87.426 of the City’s Grading Ordinance.
• In accordance with SDAPCD Rule 67.0 (Architectural Coatings), the project would utilize low-volatile organic compound (VOC) paint that does not exceed 100 grams of VOC per liter for interior surfaces and 150 grams of VOC per liter for exterior surfaces.
• Heavy diesel construction equipment shall be rated Tier IV or better.

Geology and Soils
• Implementation of all remedial grading and drainage recommendations contained within Chapte rs 7 and 9 of the geotechnical report prepared for the project (GEOCON 2020).

Greenhouse Gas Emissions
• Each garage will be wired for EV charging stations.
• Provision of three Level 2 EV charging station in the community parking area. • Installation of rooftop solar consistent with Title 24. • The project design includes bicycle racks.
• The HOA manager will provide transit information to the owners and make a good

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faith effort in offering transit fare subsidies.
• The CC&Rs will have a requirement that the HOA will also inform community members about public transit and carpool options.
• The project will include a parking for carpool vehicles. • Provision of a workspace in the community building for telecommute employees. • The project’s landscaping plan incorporates shade trees. • Compliance with the City’s Model Water Efficient Landscape Ordinance (WELO) and Municipal Code, Title 20.
• None of the units will have fireplaces.

Hazards
• Future residents shall be notified of potential annoyances commonly associated with proximity to airports (e.g., noise, vibrations, and overflights) through the recording of overflight notification documents as outlined in the McClellan -Palomar Airport Land Use Compatibility Plan and Chapter 20.265 of the City’s Municipal Code.

Hydrology/Water Quality
• Source control BMPs include, but are not limited to:
• Preventing illicit discharges into the MS4
• Stenciling the future on-site public road storm drain inlets • Protecting trash storage areas from rainfall, run-on, runoff, and wind dispersal. • Site design BMPs include:
• Conserving natural areas, soils, and vegetation
• Minimizing impervious areas
• Runoff collection through multiple private inlets
• Landscaping with native or drought tolerant species.

Noise
• Grading, excavation, and oth er earth moving activities would occur between 7:00 AM and 4:30 PM, Monday through Friday. No grading, excavation and other earth moving activities would occur on the weekends or holidays in accordance with the City’s Municipal Code, Section 17.32.180.
• Blasting activities shall comply with the City’s Municipal Code, Section 17.60.070 (Blasting Operations Procedures).

Public Services – Fire Protection, Police Protection and Schools • The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD 2001 -01 (Fire and Paramedic).
• The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD98 -01 (Police). The applicant shall pay the San Marcos Unified School District developer fees that are in effect at the time of building permit issuance. The current residential fee is $4.38 per square foot.

Transportation (Vehicle Miles Traveled)
• The project design results in a greater average residential density on the project site (14.3 dwelling units/acre) compared to the residential density for the Traffic Analysis

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Zone (TAZ) in which is located (TAZ 1026), which has a residential density of 7.03 dwelling units per acre. This allows for a reduction in vehicle miles traveled. • The project design includes bicycle racks.
• The HOA manager will provide transit information to the owners and make a good faith effort in offering transit fare subsidies.
• The CC&Rs will have a requirement that the HOA will also inform community members about public transit and carpool options.
• The project will include parking for carpool vehicles. • Provision of a workspace in the community building for telecommute employees. • The applicant/developer/property owner shall submit an executed version of petition to annex into and establish, with respect to the property, the special taxes levied by the following Community Facility District: CFD2011 -01 (Congestion Management).

Utilities
• The applicant shall pay Water Capital Facility (Capacity) Fees that are in effect at the time of building permit issuance to Rincon del Diablo Municipal Water District per Ordinance No. 21-98.21.
• The applicant shall pay Wastewater Capital Facility Fees per Vallecitos Water District per Ordinance No. 176.

Wildfire
• 150-foot onsite fire fuel modification buffer is incorporated into the project design. • Designed per code for fire resistive building materials

2.3 Environmental Setting

2.3.1 Existing Land Use and Setting
On-Site
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. Based upon historical aerial photography reviews, a residential structure and associated outbuilding were constructed on the project site sometime between 1949 and 1968.

All structures and outbuilding were removed sometime between 1983 and 1996.

Elevations range from 710 feet above mean sea level (amsl) in the southeast portion of the site to 650 feet amsl in t he northwest portion of the site . 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 land and ornamental vegetation occur scattered throughout the non -native grassland across the majority of the site. Developed, ruderal, and ornamental land border the north, east, and west project boundaries.

Surroundings
The project vicinity is developed primarily with residential uses. To the east of the project is the Mira Lago residential development and to the southeast is the Williamsburg residential development.

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West of the project site is Grace Church and the Barham Park & Ride. Southwest of the project site is residential development associated with the Walnut Hills II Specific Plan. The northern boundary of the project site is E. Barham Drive and immediately north of E. Barham Drive is landscaping, a sound wall, and State Route 78 (SR ‐78). South of the project site is preserved open space, a private community park/viewpoint and additional residences within the Williamsburg residential development.

2.3.2 Existing General Plan and Zoning
Existing General Plan Land Use Designation
The project site has an existing General Plan Land Use designation of Mixed Use 3 (MU3), which is a mixed-use non-residential designation with a maximum floor area ratio (FAR) of 1.50 . According to Table 2-3 of the Land Use Element of the City’s General Plan, this designation “Provides for a variety of commercial and office uses integrated as a cohesive development. These uses may be mixed ‘vertically’ (on separate floors of a building) or ‘horizontally’ (on a single sit e or adjacent parcels).

Structured parking, while not required to achieve the maximum FAR, may be allowed. Shared parking arrangements may also be allowed consistent with the nature of mixed uses. Typical uses include retail, commercial services, administ rative and office uses, institutional and government uses, business support and financial uses, restaurants, and health care facilities. To maintain a pedestrian scale and orientation, retail and other active services are encouraged at street level. This designation does not allow residential uses. A Specific Plan is required for development” (City of San Marcos 2012).

Existing Zoning Designation
The project site has a zoning designation of MU -3. According to Section 20.225.060 of the City’s Zoning Ordinance, this zone is intended to “support a job -based mixed-use area combining a variety of commercial and office uses integrated as a cohesive development. This business -oriented area shall be complementary to the MU-1 and MU-2 Zones; residential uses are not permitted in the MU-3 (SP) Zone. Typical uses include commercial retail, business services, administrative and office uses, institutional and government uses, business support and financial uses, restaurants, and health care facilities. Horizontal and vertical mixed use is permitted” (City of San Marco 2021).

2.3.3 Regional Setting
The following provides a general description of various aspects of the project’s environmental setting. Additional descriptions of the project’s environmental setting as it relates to environmental issue areas can be found in Chapter 3.

2.3.3.1 Climate
The weather of the San Diego region, as in most of Southern California, is influenced by the Pacific Ocean and its semi -permanent high -pressure systems that result in dry, warm summers and mild, occasionally wet winters. The average summertime high temperature in the region is approximately 74°F, with highs approaching 76°F in August on average. The average wintertime low temperature is approximately 49°F. Precipitation in the local area is approx imately 10 inches per year, with the bulk of precipitation falling between December and March.

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2.3.3.2 Air Basin
The City and project site is within the San Diego Air Basin (SDAB) and is under the jurisdiction of the San Diego Air Pollution Control District (SDAPC D). The SDAB is one of 15 air basins that geographically divide the State of California. The SDAB lies in the southwest corner of California and comprises the entire San Diego region, covering 4,260 square miles, and it is an area of high air pollution pot ential. The SDAB experiences warm summers, mild winters, infrequent rainfalls, light winds, and moderate humidity. This usually mild climatological pattern is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds.

The SDAB is currently classified as a federal nonattainment area for ozone (O 3) and a state
nonattainment area for particulate matter less than or equal to 10 microns (coarse particulate matter (PM10)), particulate matter less than or equal to 2.5 microns (fine particulate matter (PM 2.5)), and O3.

2.3.3.3 Soils
Four surficial soil types and one geologic formation was encountered during the field investigation for the geotechnical study. The surficial soil types consist of undocumented fill, topsoil, alluvium, and colluvium. The formational unit is Cretaceous-age granitic rock.

Undocumented fill was observed in one exploratory trench, and is estimated to be approximately one-foot thick and consists of loose, moist, silty sand, with some minor trash debris. Tops oil is estimated to blanket the property beyond the main northwest -trending drainage and varies in thickness from approximately one to five feet. This surficial soil is characterized as loose, damp to moist, silty fine - to medium-grained sand. Alluvial and colluvial soils deposits are present along the entire length of the northwest -trending drainage and adjacent hillsides, and vary in thickness from approximately 3 to 11 -feet-thick. These deposits generally consisted of loose to dense, damp to moist, silty to clayey, and fine - to coarse -grained sand. Cretaceous -age granitic rock underlies the surficial deposits throughout the property. The soils derived from excavations within the decomposed portion of this unit typically consist of low -expansive, silty, fine- to coarse-grained sands and provide suitable foundation support in either a natural or properly compacted condition.

2.3.3.4 Terrain and Topography
The project site is located within the 7.5 -minute San Marcos Quadrangle map. The site consists of a northwest-trending drainage with moderate to steep slopes along the flanks. Elevations range from 710 feet amsl in the southeast portion of the site to 650 feet amsl in the northwest portion of the site.

2.3.3.5 Watersheds and Hydrology
The project site is located within the Carlsbad Watershed Hydrologic Unit. The Carlsbad Watershed Hydrologic Unit (904.00) is a triangular area covering approximately 210 square miles. This hydrologic unit is bordered by San Luis Rey Hydrologic Unit to the north and San Dieguito Hydrologic Unit to the east and south. The Carlsbad Hydrologic Unit includes one small coastal lagoon (Loma Alta Slough) and four major coastal lagoons, including Buena Vista, Agua Hedionda, Batiquitos, and San Elijo. The project site is located within the San Marcos Hydrologic Subarea (904.5).

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2.3.3.6 Regional Biology
The City of San Marcos Subarea Habitat Conservation Plan/Natural Community Conservation Plan (NCCP) has not been finalized or implemented, and the City is no longer an active participant in the NCCP program and the subregional Multiple Habitat Conservation Program (MHCP) conservation planning effort. However, it is the City’s General Plan policy to comply with the conservation policies identified in the MHCP through use of the Draft San Marcos Subarea Plan as an implementation tool.

The project site is not located within a Focused Planning Area (FPA) in the City’s Draft Subarea Plan.

Based upon the biological resources study prepared for the project (Rocks 2020a), the site is primarily non-native grassland with smaller areas of Diegan coastal sage scrub, Diegan coastal sage scrub – Baccharis dominated, developed, disturbed, ornamental and ruderal vegetation. No special status plant species were observed on the project site. Focused breeding season surveys for the coastal California gnatcatcher were negative.

2.4 Intended Uses of EIR
This EIR was prepared in accordance with CEQA (California Public Resources Code, Section 21000 et seq.), CEQA Guidelines (14 CCR 15000 et seq.).

The EIR is an informational document that will provide the City’s decision makers, public agencies, responsible and trustee agencies, and members of the public with information about (1) the potential for significant adverse environmental impacts that would result from the development of the proposed project, (2) possible ways to minimize any significant environmental impacts, and (3) feasible alternatives to the proposed project that would reduce or avoid significant impacts associated with the proposed project (California Public Resources Code, Section 21002.1[a]; 14 CCR 15121[a]). Responsible and trustee agencies may use this EIR to fulfill their legal authority to issue permits for the proposed project. The analysis and findings in this EIR reflect the independent judgment of the City.

Lead Agency
As defined by CEQA Guidelines Section 15367, a “Lead Agency” means the public agency which has the principal responsibility for carrying out or approving a project. The City is the lead agency for the proposed project because it will perform the entitle ment processing of the proposed project. As the designated lead agency, the City has assumed responsibility for preparing this EIR, and the analysis and findings in this EIR reflect the City’s independent judgment. When deciding whether to approve the proposed project, the City will use the information in this EIR to consider potential impacts to the physical environment associated with the proposed project.

Trustee Agencies
As defined by CEQA Guidelines Section 15381, a “Trustee Agency” means a state agency having jurisdiction by law over natural resources affected by a project which are held in trust for the people of the State of California. The California Department of Fish and Wildlife (CDFW) is a Trustee Agency with regard to the fish and wildlife of t he state, to designate rare and endangered native plant, and to game refuges, ecological reserves, and other areas administered by the department. CDFW is a Trustee Agency for the project.

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Responsible Agencies
As defined by CEQA Guidelines Section 15381, a “Responsible Agency” includes all public agencies other than the lead agency which have discretionary approval power over the project. Subsequent to certification of the Final EIR, agencies with permitting authority over all or portions of the proposed project will use the Final EIR as the basis for their evaluation of environmental effects related to the proposed project that will culminate with the approval or denial of applicable permits. The California Department of Fish and Wildlife (CDFW) is a Responsible Agency for the project.

2.4.1 Scope of the EIR
For the proposed project, the City determined that a Project EIR, as defined by CEQA Guidelines, Section 15161, was required. The City made this determination based on the scope and the location of the propo sed project, as well as preparation of an Initial Study in accordance with CEQA Guidelines, Section 15063 (included as Appendix B.1 to this EIR).

This EIR evaluates all subject areas listed in Appendix G to the CEQA Guidelines, with the exception of those subject areas determined not to have a potentially significant impact on the environment, as determined during preparation of the Initial Study (refer to Chapter 5 of this EIR). Chapter 3 of this EIR evaluates in detail, the following subject areas: aesthe tics, air quality, biological resources, cultural resources, energy, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, population and housing, public services, recreation, transportation, tribal cultural resources, utilities and service systems, wildfire, cumulative impacts, and growth-inducing impacts.

As a “Project EIR,” this EIR is “focused primarily on the changes in the environment that would result from the developm ent project” (CEQA Guidelines Section 15161). In addition, as a Project EIR, this EIR examines all phases of the proposed project including planning, construction, and operation (CEQA Guidelines Section 15161). Where environmental impacts have been determined to be significant, this EIR recommends mitigation measures directed at reducing or avoiding those significant environmental impacts. The project will have a significant and unmitigated impact related to transportation (inconsistency with the Mobility Element of the General Plan due to level of services and vehicle miles traveled) and land use (inconsistency with the Mobility Element of the General Plan due to level of service). Alternatives to the proposed project are identified to evaluate whether ther e are ways to minimize or avoid significant impacts associated with the proposed project.

2.4.2 Notice of Preparation and Scoping
CEQA establishes mechanisms to inform the public and decision makers about the nature of the proposed project and the extent a nd types of impacts that the proposed project and alternatives to the proposed project would have on the environment should the proposed project or alternatives be implemented. Pursuant to Section 15082 of the CEQA Guidelines, the City circulated a Notice of Preparation (NOP) dated March 31, 2021, to interested agencies, organizations, and parties. The NOP was also sent to the State Clearinghouse at the California Office of Planning and Research. The State Clearinghouse assigned a state identification number (SCH No 2021040009) to this EIR.

The NOP is intended to encourage interagency and public communication regarding the proposed action so that agencies, organizations, and individuals are afforded an opportunity to respond with specific comments and/or que stions regarding the scope and content of the EIR. An online public

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scoping meeting was held on April 15, 2021. The 30 -day public scoping period ended on April 30, 2021. A total of five NOP comment letters were received:
• California Department of Fish and Wildlife
• Caltrans
• Native American Heritage Commission
• San Diego Archaeological Society
• Sylvia J. Williams
Comments received during the NOP public scoping period were considered part of the preparation of this EIR. The NOP and written comments are included in Appendices B.2 and B.3 to this EIR. Topics raised include:
• Biological Resources: sensitive species, scope of biological analysis, analysis of direct and indirect impact to biological resources, and recommended mitigation measures. • Cultural and Tribal Cultural Resources: compliance with Assembly Bill 52 and Senate Bill 18. • Transportation: scope of the study area, existing roadway congestion, appropriate and adequate mitigation, safety.

Public scoping comments regarding the proposed project’s pote ntial impact on the environment have been incorporated in the analysis in this EIR in Sections 3.3 (biological resources), 3.4 (cultural resources), 3.16 (tribal cultural resources), 3.10 (land use – level of service analysis for traffic) and

3.15 (transportation).

2.4.3 Draft EIR and Public Review
This Draft EIR was prepared under the direction and supervision of the City. The Draft EIR will be made available to members of the public, responsible agencies, and interested parties for a 45 -day public review period in accordance with CEQA Guidelines, Section 15105.

Public review of the Draft EIR is intended to focus “on the sufficiency of the document in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated” (14 CCR 15204). The Notice of Completion of the Draft EIR will be filed with the State Clearinghouse as required by CEQA Guidelines, Section 15085. In addition, the Notice of Availability of the Draft EIR will be distributed pursuant to CEQA Guidelines, Section 15087.

Interested parties may provide comments on the Draft EIR in written form. This EIR and related technical appendices are available for review during the 45-day public review period at:

City of San Marcos
Development Services Department Counter
1 Civic Center Drive
San Marcos, CA 92069
The document is also available online at: https://www.san -marcos.net/departments/development- services/planning/environmental-review-sustainability/environmental-documents.

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Interested agencies and members of the public may submit written comments on the adequacy of the Draft EIR to the City’s Development Services Department at the address above, addressed to Norm Pedersen, Associate Planner, or emailed at: [email protected] Comments on the Draft EIR must be received by the close of business on the last day of the 45 - day review period.

2.4.4 Final EIR Publication and Certification
Once the 45-day public review period has concluded, the City will review all public comments on the Draft EIR and provide a written response to all written comments pertaining to environmental issues as part of the Final EIR. The Final EIR will include all written comments received during the public review period; responses to comments; a nd, if applicable, edits and errata made to the Draft EIR.

The City will then consider certification of the Final EIR (14 CCR 15090). If the EIR is certified, the City may consider project approval (14 CCR 15092).

When deciding whether to approve the proposed project, the City will use the information provided in the Final EIR to consider potential impacts to the physical environment. The City will also consider all written comments received on the Draft EIR during the 45 -day public review period in making its decision to certify the Final EIR as complete and compliant with CEQA and in making its determination whether to approve or deny the proposed project. Environmental considerations, as well as economic and social factors, will be weighed by the City to determine the most appropriate course of action.

Prior to approving the proposed project, the City must make written findings and adopt a Statement of Overriding Considerations with respect to any significant and unavoidable environmental effect identified in the Draft EIR (14 CCR 15091, 15093). If the proposed project is approved, the City will file a Notice of Determination with the State Clearinghouse and San Diego County Clerk within five working days after project approval (14 CCR 15094.)
Subsequent to certification of the Final EIR, agencies with permitting authority over all or portions of the proposed project will use the Final EIR’s evaluation of the proposed project’s environmental effects in considering whether to approve or deny applicable permits.

2.5 Matrix of Project Approvals
Consistent with the City’s General Plan and San Marcos Municipal Code Zoning Ordinance Title 20, the proposed project requires certain entitlements be submitted, reviewed, and approved by the City.

The requested entitlements include a General Plan Amendment, Specific Plan, Rezone, Multi- Family Site Development Plan, Tentative Subdivision Map, Conditional Use Permit, and a Grading Variance.

These entitlements, listed and described in Table 2-3, would govern the development of t he project site.

The City will use this EIR and associated documentation in its decision to approve or deny the required discretionary permits. Other responsible and/or trustee agencies can use this EIR and supporting documentation in their decision -making process to issue additional approvals. These additional approvals may include but are not limited to approval of a site -specific Stormwater Pollution Prevention Plan. Additional permits and approvals from responsible and other agencies are also listed in Table 2-3.

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2.6 Project Inconsistencies with Applicable Regional and General Plans Throughout Chapter 3 of this EIR, the project has been evaluated in relation to the applicable goals, policies, and objectives of: the City’s General Plan and San Marcos Municipal Code Zoning Ordinance Title 20 (Section 3.10, Land Use); Regional Air Quality Strategy (Section 3.2, Air Quality); San Diego Air Pollution Control District policies (Section 3.2, Air Quality); City’s Climate Action Plan (Section 3.7, Greenhouse Gas Emissions); Regional Water Quality Control Board permits (Section 3.9, Hydrology and Water Quality); the Multiple Habitat Conservation Program (Section 3.3, Biological Resources); Airport Land Use Compatibility Plans (Sections 3.8, Hazards and Hazardous Materials, 3.10, Land Use, and 3.11, Noise); and various other applicable regional and local plans and policies.

Table 2-3. Required Actions and Approvals
Agency Required Action/Approval
City of San Marcos – Lead Agency • General Plan Amendment • Specific Plan
• Rezone
• Conditional Use Permit
• Multi-Family Site Development Plan
• Tentative Subdivision Map
• Grading Variance
• Grading Plan/Permit
• Public Improvement Plan/Permit
• Landscape Plan/Permit
• Building Permits
National Pollutant Discharge Elimination System
Construction General Permit (State Water Resources
Control Board Order 2009-09-DWQ)
Vallecitos Water District Approval for sewer service
Rincon del Diablo Municipal Water
District
Approval for water service

2.7 List of Past, Present and Reasonably Anticipated Future Projects in the Project Area
CEQA requires an EIR to analyze cumulative impacts. Section 15355 of CEQA Guidelines defines cumulative impacts as “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts.” Section 15130 of the CEQA Guidelines provides guidance for analyzing significant cumulative impacts in an EIR. The discussion of cumulative impacts “need not provide as great detail as is provided for the effects attributable to the project alone,” but instead is to be “be guided by standards of practicality and reasonableness” (CEQA Guidelines §15130(b)). The discussion should also focus only on significant effects resulting from the project’s incremental effects and the effects of other projects. According to

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Section 15130(a)(1), “an EIR should not discuss impacts which do not result in part from the project evaluated in the EIR.”
Cumulative impacts can result from the combined effect of past, present, and future projects located in proximity to the project under review. Therefore, it is important for a cumulative impacts analysis to be viewed over time and in conjunction with other related past, present, and reasonably foreseeable future developme nts whose impacts might compound or interrelate with those of the project under review.

According to Section 15130(b)(1) of the CEQA Guidelines, a cumulative impact analysis may be conducted and presented by either of two methods:
• A list of past, present, and probable activities producing related or cumulative impacts; or • A summary of projections contained in an adopted general plan or related planning document, or in a prior environmental document that has been adopted or certified, which described or eval uated regional or area -wide conditions contributing to the cumulative impact.

With the exception of the impact analyses of air quality and greenhouse gas emissions, the cumulative list approach has been used in this cumulative analysis, as discussed below. The cumulative impacts of air quality and greenhouse gas emissions have been evaluated using the summary of projections method because the geographic scope of such impacts tends to be broad and area-wide.

An inventory of past, present, and reasonably fore seeable future projects within the vicinity of the project site is presented in Table 2-4 and shown on Figure 2-15.

Table 2-4. Cumulative Projects
No.(1) Project Location Description
City of San Marcos
1 Block 3 Student
Housing
Northwest corner of Campus Way
and Barham Drive 342 beds
2 Carmel Street
Apartments
Southwest corner of Industrial and
Carmel Street 170 MFR dwelling units
3 Kaiser Permanente
Master Plan 400 Craven Road Approximately 70,700 s.f. of medical/hospital use (206 beds)
4 Main Square Southeast corner of San Marcos
Boulevard and McMahr Road
486 apartments and approximately
44,000 s.f. of commercial
5 San Elijo Hills San Elijo Road 11,700 s.f. of commercial 6 Pacific Commercial Northeast corner of Grand Avenue
and Pacific Street 122 hotel rooms
7 Brookfield
Residential S. Twin Oaks Valley Road 220 MFR dwelling units 8 San Marcos
Highlands North end of N. Las Posas Road 187 SFR dwelling units

2.0 Project Description
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-21
No.(1) Project Location Description
9 El Dorado II
Specific Plan
Southwest corner of Richmar
Avenue and Pleasant Way
72 MFR dwelling units and 2,000
s.f. of commercial
10 Villa Serena Richmar Avenue & Marcos Street 12 MFR units 11 Montiel Partners Montiel Road 8 SFR dwelling units
12 Sandy Lane Estates Sandy Lane 9 SFR dwelling units
13 Creekside Assisted
Living
Southeast corner of Twin Oaks
Valley Road and Richmar Avenue 174 bed assisted living facility 14 Carkel SM –
Starbucks
Southeast corner of San Marcos
Boulevard and Bent Avenue 1,797 s.f drive-thru restaurant 15 South Lake Park
Phase 1
Twin Oaks Valley Road, South of
Village Drive Parking lot and fishing dock
16 McDonald Group San Marcos Boulevard (Former
Sears site)
5,000 s.f. commercial and 82 MFR
dwelling units
17 JR Legacy II Montiel Road 128 room hotel
18 Meadowlark
Canyon San Marcos Boulevard 33 SFR dwelling units
19 Mariposa II –
Phase 1
Richmar Avenue and Los Olivos
Drive 60 MFR dwelling units
20 Mariposa II –
Phase 2
Richmar Avenue and Los Olivos
Drive 66 MFR dwelling units
21 Murai N. Las Posas Road 89 SFR dwelling units
22 Pacifica San
Marcos
S. Rancho Santa Fe Road and
Creek Street
31 MFR dwelling units and 4,375
s.f. of commercial
23 Discovery Village
South Future Discovery Street 220 SFR dwelling units
24 Discovery Village
North Craven Road 41 acres
office/commercial/residential
25 Jump Ball LLC San Marcos Boulevard and Bent 3,200 s.f. drive through restaurant 26 Fitzpatrick
Viewpoint
Fitzpatrick Road and Richmar
Avenue 78 MFR and 2 SFR dwelling units
27 Mission 24 Mission Road at Avenida Chapala 24 MFR dwelling units 28 Mission 316 West Northeast corner of Mission Road
and Woodward Street 67 MFR dwelling units
29 Lanikai Northwest corner of Mission Road
and Woodward Street 115 senior dwelling units
30 Mesa Rim Climbing
Center 285 Industrial Street 28,000 s.f. of commercial
31 Artis Senior Living San Elijo Road at Paseo Plomo 64 bed senior living complex

2.0 Project Description
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-22
No.(1) Project Location Description
32 Kiddie Academy Twin Oaks Valley Road northeast
of Windy Way 11,430 s.f. preschool
33 Edenpark 1601 San Elijo Boulevard Approximately 180,500 s.f. of commercial
34 Montiel
Commercial 2355 and 2357 Montiel Road Approximately 33,000 s.f. of office use
35 California Allstars East side of Twin Oaks Valley Road Approximately 28,000 square foot industrial use
36 Bodhi Hill Buddhist
Center
Poinsettia Avenue near Linda Vista
Drive
Approximately 44,000 s.f. of
institutional uses
37 Mercy Hill and
Marian Center Borden Road Approximately 22,800 s.f. of
institutional uses
County of San Diego
38 Sunrise Barham Drive, west of Myers
Avenue
193 MFRs with passive and
recreational open space on 14.4
acres.
39 Harmony Grove
Village
North and south of Harmony Grove
Road, and east and west of
Country Club Drive
Up to 742 dwelling units,
commercial services, park and
community gathering locales, and
equestrian facilities on a 468-acre
site.
40 Harmony Grove
Village South
Country Club Drive/Harmony
Grove Road
453 dwelling units and 5,000-s.f. of
commercial/civic uses, open space,
and parks on a 111-acre site.
41 Valiano
Development
South of Hill Valley Drive and west
of Country Club Drive
334 SFRs, parks and open space on
a 210-acre lot.

City of Escondido
42 Escondido
Innovation Center
1925 and 2005 Harmony Grove
Road
Industrial development project
consisting of 212,088-s.f. on an

11.04- acre site.
43 Escondido
Research and
Technology Center
Citracado Parkway 74,400 s.f. medical office building
44 Stone Brewery
Hotel
Citracado Parkway, opposite of
existing Stone Brewing 44-room boutique hotel
Notes: (1) See Figure 2-15 for location of cumulative projects. (2) SFR = Single-Family Residential, MFR= Multi-Family Residential

2.0 Project Description
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-23
Figure 2-1. Project Location

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-24
Figure 2-2. Conceptual Site Plan

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-25
Figure 2-3. Open Space

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Figure 2-4a. Landscape Concept

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-27
Figure 2-4b. Plant Materials

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-28
Figure 2-5a. Architectural Concept (3-Plex)

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-29
Figure 2.5b. Architectural Concept (7-Plex, Option 1)

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-30
Figure 2.5c. Architectural Concept (7-Plex, Option 2)

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-31
Figure 2-6. Conceptual Fence and Wall Plan

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-32
Figure 2-7. Lighting Plan

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-33
Figure 2-8. Conceptual Circulation Plan

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-34
Figure 2-9a. Private Alley and Driveway Cross Sections (1 of 2)

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-35
Figure 2-9b. Private Alley and Driveway Cross Section (2 of 2)

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-36
Figure 2-10. Grading Plan

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-37
Figure 2-11. Grading Variance Exhibit

2.0 Project Description
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-38
Figure 2-12. Proposed Water Exhibit

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-39
Figure 2-13. Proposed Wastewater Exhibit

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-40
Figure 2-14. Conceptual Drainage Plan

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 2-41
Figure 2-15. Cumulative Projects

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 3.1-1

3.0 Environmental

3.1 Aesthetics
Introduction
This section addresses the aesthetic resources of the proposed project area and the potential effects that implementation of the proposed project may have related to aesthetics, including impacts to scenic vistas, scenic resources, degradation of visual character and lighting/glare. The analysis also considers the California Environmental Quality Act (CEQA) Guidelines Appendix G, and applicable State and Local regulations, including the City of San Marcos General Plan. The General Plan is available on the City’s website.1
Table 3.1 -1 summarizes the project - and cumulative -level impact analysis by threshold for the proposed project.

Table 3.1-1. Aesthetics Summary of Impacts
Threshold of Significance Project Direct
Impact
Project
Cumulative
Impact
Impact After
Mitigation
#1 - Have a substantial adverse impact on a
scenic vista.

Less Than
Significant
Less Than
Significant
Less Than
Significant
#2 - Substantially damage scenic resources,
including but not limited to trees, rock
outcroppings, and historic buildings within a
state scenic highway.

Less Than
Significant
Less Than
Significant
Less Than
Significant
#3 - In non-urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those that
are experienced from publicly accessible
vantage point). If the project is in an
urbanized area, would the project conflict
with applicable zoning and other regulations
governing scenic quality?
Less Than
Significant
Less Than
Significant
Less Than
Significant
#4 - Create a new source of substantial light
or glare which would adversely affect day or
nighttime views in the area.

Less Than
Significant
Less Than
Significant
Less Than
Significant

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

3.1 Aesthetics
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 3.1-2

3.1.1 Existing Conditions
Scenic Highways
According to Caltra ns’ California Scenic Highway Mapping System, the project site is not located adjacent to, or in the vicinity of, a designated state scenic highway (Caltrans 2011). State Route 78 (SR-78) is a designated state scenic highway from the west boundary of the A nza-Borrego Desert State Park to the east boundary of the State Park. SR -78 is located approximately 200 feet north of the project site, however the portion designated as a state scenic highway begins approximately 37 miles east of the project site. Additionally, the portion of SR -78 from the west boundary of the Anza - Borrego Desert State Park to the junction of SR -78 and SR -79 in Santa Ysabel is eligible for state scenic highway designation (Caltrans 2011). The project site is located approximately 25 mile s east of the closest point of this eligible state scenic highway. Interstate 5 (I-5) and State Route 76 (SR-76) are also eligible state scenic highways, though not officially designated. I -5 is located approximately 11 miles west and SR-76 approximately 11 miles northwest of the project site.

At a local level, the City has designated SR -78 as a view corridor for its unobstructed visual passageway. The highway corridor provides views of the Merriam Mountains, Mount Whitney, Double Peak, CSUSM, and Palomar Community College. The project site is visible from both eastbound and westbound SR-78.

Scenic Vistas
A scenic vista is typically defined as a panoramic view or vista from an identified view/vista point, public road, public trails, public recreational areas, or scenic highways.

The City’s General Plan does
not identify any designated scenic vistas; however, the General Plan more generally aims to protect the City’s scenic resources such as the San Marcos, Merriam, and Double Peak Mountains, creek corridors, mature trees, rock outcroppings, and ocean views (City of San Marcos 2012).

Visual Character
The following is a description of the existing visual characteristics and quality of the project site and surroundings.

The City of San Marcos is in the n orthern portion of San Diego County. The majority of the City is located on the valley floor, with SR -78 running through the center of the City. Landforms such as the mountain ranges to the north and south of San Marcos contribute to its scenic corridors.

The project site is located at 943 E. Barham Road, on the south side of Barham Road, approximately 475 feet east of Woodland Parkway. 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. Based upon historical aerial photography reviews, a residential structure and associated outbuilding were constructed on the project site sometime betwe en 1949 and 1968. All structures and outbuilding were removed sometime between 1983 and 1996.

On-site elevations range from 710 feet above mean sea level (amsl) in the southeast portion of the site to 650 feet amsl in the northwest portion of the site . Visually, the project site is heavily influenced by the existing vegetation that covers the project site. As detailed in the Biological Technical Report prepared for the project, the site is primarily non -native grassland with smaller areas of Diegan coastal sage scrub, Diegan coastal sage scrub – Baccharis dominated, developed,

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 3.1-3
disturbed, ornamental and ruderal vegetation (RBC 2020a). Figures 3.1 -1 through 3.1 -6 present photos of the project site.

The project vicinity is developed primarily with residential u ses. To the east of the project is the Mira Lago residential development and to the southeast is the Williamsburg residential development.

West of the project site is Grace Church and the Barham Park & Ride. Southwest of the project site is residential development associated with the Walnut Hills II Specific Plan. The northern boundary of the project site is E. Barham Drive and immediately north of E. Barham Drive is landscaping, a sound wall, and SR ‐78. South of the project site is preserved open space, a private community park/view point and additional residences within the Williamsburg residential development.

Existing Light and Glare Conditions
The project site is currently undeveloped and thus does not contain any existing sources of light or glare. Additionally, the project site does not contain any reflective surfaces that would act as sources for glare. The project vicinity contains sources of nighttime lighting typical of residential, commercial, and industrial development. Residential devel opments existing to the east and southwest of the project site contain typical sources of residential lighting, including outdoor lighting fixtures on structures and on residential streets. No sources of substantial glare are present in this area.

Commercial and light industrial developments north of the project site on the opposite side of SR-78.

Sources of nighttime lighting in this area could occur from exterior building lighting, street lighting, and lighting in parking lots. No sources of substantial glare are present in this area.

3.1.2 Regulatory Setting
This section describes the state and local regulations related to aesthetics that are applicable to the proposed project.

State
California Scenic Highway Program
The California Department of Transportation manages the California Scenic Highway Program. The goal of the program is to preserve and protect scenic highway corridors from changes that would affect the aesthetic value of the land adjacent to highways. No state -designated scenic highways are in the p lanning area. SR -78 is a designated state scenic highway from the west boundary of the Anza-Borrego Desert State Park to the east boundary of the State Park. SR -78 is located approximately 200 feet north of the project site, however the portion designated as a state scenic highway begins approximately 37 miles east of the project site. Additionally, the portion of SR -78 from the west boundary of the Anza -Borrego Desert State Park to the junction of SR -78 and SR-79 in Santa Ysabel is eligible for state scenic highway designation (Caltrans 2011). The project site is located approximately 25 miles east of the closest point of this eligible state scenic highway.

Local
San Marcos General Plan – Conservation and Open Space Element The following goal and policies f rom the City of San Marcos General Plan, Conservation and Open Space Element pertain to aesthetics and visual quality:

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 3.1-4
• Goal COS-3: Protect natural topography to preserve and enhance the natural beauty of San Marcos.
o Policy COS -3.1: Preserve scenic resource s, including prominent landforms such as Double Peak, Owens Peak, San Marcos Mountains, Merriam Mountains, Cerro de Las Posas, Franks Peak, and canyon areas through conservation and management policies. o Policy COS -3.2: Encourage and maintain high -quality a rchitectural and landscaping designs that enhance or complement the hillsides, ridgelines, canyons, and view corridors that comprise the visual character in San Marcos. o Policy COS -3.3: Continue to work with new development and redevelopment project applicants in designing land use plans that respect the topography, landforms, view corridors, wildlife corridors, and open space that exists. o Policy COS -3.4: Evaluate potential impacts to visual and aesthetic resources, including the potential to create new light sources, while still maintaining and being sensitive to rural lighting standards.

The project’s consistency with applicable General Plan goals and policies is discussed in Section

3.10, Land Use and Planning. As detailed in Table 3.10 -5 in Section 3. 10, the project is consistent with all the applicable goals and policies.

San Marcos Municipal Code and Zoning Ordinance. Title 20 The provisions of Title 20 of the San Marcos Municipal Code are referred to as the Zoning Ordinance.

The San Marcos Municipal Code Zoning Ordinance Title 20 is the primary implementation tool for the policies of the General Plan. The Zoning Ordinance provides more detailed direction related to design and development standards; permitted, conditionally permitted, and prohibited u ses; and other regulations such as lighting and sign regulations. The land uses specified in the Zoning Ordinance are based upon and consistent with the land use policies set forth in the General Plan. Specifically, building design, setbacks, lighting, and signage standards as well as open space requirements for development to protect open space and ambient light levels in the City. Lighting standards of the Ordinance require energy -efficient lighting that limits light and glare for private projects, with exceptions for specialized streetscape lighting. Private developments are required to submit lighting plans to ensure consistency with dark sky needs of the region (City of San Marcos 2021a).

Title 20, Section 20.300.080, Site Planning and General Development Standards The City of San Marcos Street Lighting Standards and Specifications describes the lighting and glare standards for the City. These standards require lighting to be directed downward, and limit the type and spacing of lighting to maintain reaso nable lighting levels that do not contribute to light pollution.

The City uses International Dark Sky Association (IDA) thresholds to inform its own testing, leading to a policy that allows for the use of energy-efficient lighting sources that include, but are not limited to, light-emitting diode (LED) and induction lighting technologies (City of San Marcos 2021a).

Title 20, Chapter 20.260, Ridgeline Protection and Management Overlay Zone The City of San Marcos adopted a Ridgeline Protection and Management Overlay Zone in November 2008, set forth in Ordinance 2008 -1314, to minimize visual impacts to important ridgelines. These guiding principles are in place to protect natural viewsheds, minimize physical impacts to ridgelines, and establish innovative site and architectural design standards. The Ordinance identifies primary and secondary ridgelines within the City, plus buffer zones, and Ridgeline Overlay Zones (ROZ),

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surrounding these ridgelines (City of San Marcos 2021b). No primary or secondary ridgelines are located within or adjacent to the project site; the nearest ridgeline is a secondary ridgeline is located approximately two miles southwest of the project site. The nearest primary ridgeline is located approximately 2.25 miles southwest of the project site.

The San Marcos Municipal Code and Zoning Ordinance are the primary implementation tools for the policies of the General Plan. The Zoning Ordinance provides more detailed direction related to design and development standards; permitted, conditionally permitted, and prohibited uses; and other regulations such as lighting and sign regulations. The land uses specified in the Zoning Ordinance are based upon and consistent with the land use policies set forth in the General Plan. Specifically, building design, setbacks, lighting, and signage standards as well as open space requirements for development to protect open space and ambient light levels in the City. Lighting standards of the Ordinance require energy -efficient lighting that limits light and glare for private projects, with exceptions for specialized streetscape lighting. Private developments are required to submit lighting plans to ensure consistency with dark sky needs of the region.

The City of San Marcos Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080 describes the lighting and glare standards for the City. These standards require lighting to be directed downward, and limit the type and spacing of lighting to maintain reasonable lighting lev els that do not contribute to light pollution. The City uses International Dark Sky Association thresholds to inform its own testing, leading to a policy that allows for the use of energy -efficient lighting sources that include, but are not limited to, LED and induction lighting technologies

3.1.3 Thresholds of Significance
According to Appendix G of the California Environmental Quality Act (CEQA) Guidelines , visual quality and aesthetics impacts are considered potentially significant if the project would:
• Threshold #1: Have a substantial adverse impact on a scenic vista; • Threshold #2: Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway; • Threshold #3: In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the pr oject conflict with applicable zoning and other regulations governing scenic quality;
• Threshold #4: Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

3.1.4 Project Impact Analysis
Project construct ion involves grading and site preparation activities to prepare the site for future residential buildings, and circulation and infrastructure improvements. Construction could require staging areas with construction equipment and supplies, and portable trai lers to serve as temporary office space or storage. Grading on the site would change or alter the existing topography on the project site to prepare the site for development. The project plans are included in Appendix A.2.

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The project proposes 151 multi -family residential units situated on approximately 10.6 gross acres.

The site plan is included as Figure 2 -2 in Chapter 2. Residential buildings compose approximately

2.8-acres of the project site. Multi- family residential dwelling units are comprised of one , two, and three-story condominiums with ten dwelling unit types interspersed throughout the project site.

Overall building heights will not exceed 40 feet.

The proposed landscape plan includes a mix of trees, shrubs, grasses and groundcover and the plant selection emphasizes moderate water use species. The landscape concept plan and the plant material guide are included as Figures 2 -4a and 2 -4b in Chapter 2. Proposed tree species include desert willow, majestic beauty Indian hawthorn, California laurel, columnar Italian cypress, fern pine, western redbud, European olive, Mexican palo verde, African suman, strawberry tree, flaxleaf paperbark, and date palms.

The project will have a Contemporary Spanish architectural style. Proposed materials include wood, stucco, brick with decorative metal accents and trims . The project includes a variety of floor plans to allow for the articulation of the building elevations. One -story, two-story, and three -story product types are included with the project. The project prop oses 19 7 -Plex Buildings (133 units) and six 3 - plex buildings (18 units) for a total of 151 units. A 1,160 square foot (s.f.) central recreation building is also proposed that would have a kitchen, living room, dining room, California room, patio, restroom, and storage area. Architectural concepts for the presented in Chapter 2, Project Description. Figure 2-5a presents the architectural concept for the 3 -plex buildings and Figures 2 -5b and 2-5c presents the architectural concepts for the 7 -plex buildings. A rendering of the project site in presented in
Figure 3.1-7.

Threshold #1: Have a substantial adverse impact on a scenic vista The project site is not identified as a protected scenic vista. The proposed residential development would be adjacent to existing residential development to the east and southwest and an existing church and preschool to the west with additional residential uses in the project vicinity. To the north is E. Barham Drive, a sound wall, and then SR -78. The project vicinity is urbanized . Thus, the proposed project would be compatible with the surrounding environment and blend with adjacent developments. While the project site is not identified as a scenic vista in the San Marcos General Plan, the General Plan does include policies regard ing the protection of scenic resources (City of San Marcos 2012). Below is a summary of the proposed project’s consistency with applicable scenic resource preservation policies.

Policy COS -3.1 of the Conservation and Open Space Element of the General Plan call for the preservation of scenic resources, including prominent landforms such as Double Peak, Owens Peak, San Marcos Mountains, Merriam Mountains, Cerro de Las Posas, Franks Peak, and canyon areas through conservation and management policies. The proposed project site does not fall within any of the specific areas called out in this policy, therefore the project would not conflict with this policy.

Policy COS -3.2 encourages high -quality architectural and landscaping designs that enhance or complement the hillsides, ridgelines, canyons, and view corridors that comprise the visual character of San Marcos (City of San Marcos 2012). The Hallmark -Barham Specific Plan includes design rules and themes to create a foundation for development (see EIR Appendix A.1 ). The project proposes a high-quality architectural and landscaping design that will enhance the project site and be compatible with the existing visual character of the vicinity . The architectural style proposed for the project is Contemporary Spanish. P roposed materials include wood, stucco, brick with decorative metal accents and trims . The project includes a variety of floor plans to allow for the articulation of the building elevations. One -story, two-story, and three -story product types are included with the

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project. The proposed landscape plan includes a mix of trees, shrubs, grasses and groundcover and the plant selection emphasizes moderate water use species. The landscape concept plan and the plant material guide areas are included as Figures 2 -4a and 2 -4b in Chapter 2 . Proposed tree species include desert willow, majestic beauty Indian hawthorn, California laurel, columnar Italian cypress, fern pine, western redbud, European olive, Mexican palo verde, African suman, strawberry tree, flaxleaf paperbark, and date palms.

Implementation of the proposed project would result in changes in the existing visual character and quality of the project site; however, these changes are not characterized as a substantial degradation. The project incorporates extensive design features t hat address landscaping, and architectural treatments and design. In summary, the project would not have a substantial adverse impact on a scenic vista, or City scenic resources, and impacts would be less than significant.

Threshold #2: Substantially damag e scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway SR-78 is located approximately 200 feet north of the project site and provides views of the San Marcos Mountains, Merriam Mounta ins, Mount Whitney, Double Peak, CSUSM, and Palomar Community College. As previously noted, the section of SR -78 proximate to the project site is not identified as a Scenic Highway per the Caltrans State Scenic Highways Program, although the City has designated SR-78 as a view corridor to surrounding ridgelines.

The project site is visible from SR -78 and future development on the site would be visible from SR -

78. However, due to the site topography and the site’s location at a lower level than other topographic features in the area, views of the surrounding hillsides would remain unobstructed from SR-78 and the existing views to these hillsides would not be significantly altered.

Based upon the cultural resources study and historical evaluation prepared for the project (ASM 2020 and ASM 2021), several historic features were identified 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. ASM recorded and documented these features as a historic site on the appropriate DPR forms. A total of six historic features were identified at the site, including the remains of what appear to be a formed concre te retaining wall, a cinder block house foundation and associated septic tank and concrete stairs, a cinder block garage foundation, a concrete and cinder block water storage cistern, a concrete shed foundation, and a small concrete pad. The historic build ing remains and historic refuse were not eligible for listing in the California Register of Historical Resources.

In addition, the project site does not support any significant trees or rock outcroppings as identified or protected by the City’s General Pla n. Therefore, the proposed project would not substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway. Impacts would be
less than significant.

Threshold #3: In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized ar ea, would the project conflict with applicable zoning and other regulations governing scenic quality The City of San Marcos (which includes the project site) is considered an urbanized area per the Public Resources Code (PRC) . Per PRC Section 21071, an “ur banized area” is defined as “(a) an incorporated city that meets either of the following criteria: (1) Has a population of at least 100,000

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persons, or (2) Has a population of less than 100,000 persons if the population of that city and not more than two c ontiguous incorporated cities combined equals at least 100,000 persons.” As of July 1, 2019, the US Census Bureau estimated the population of San Marcos to be 96,664 persons (USCB 2019). While this is less than 100,000 persons, the City of San Marcos is c ontiguous with the City of Escondido, which has an estimated population of 151,625 persons as of July 1, 2019 (USCB 2019). The combined estimated population of these two contiguous cities is 248,289 persons, which is well over the 100,000 persons threshold . Thus, the City would be considered an urbanized area per CEQA . Therefore, the first question of this aesthetics threshold does not apply to the proposed project, as it is directed at non-urbanized areas.

The second part of this threshold is for projects in urbanized areas, which is what applies to the project. A significant impact would occur if the project conflicts with the applicable zoning and other regulations that govern scenic quality.

The City of San Marcos adopted a Ridgeline Protection and Manag ement Overlay Zone in November 2008, set forth in Ordinance 2008 -1314, to minimize visual impacts to important ridgelines. These guiding principles are in place to protect natural viewsheds, minimize physical impacts to ridgelines, and establish innovative site and architectural design standards. The Ordinance identifies primary and secondary ridgelines within the City, plus buffer zones, or Ridgeline Overlay Zones (ROZ), surrounding these ridgelines (City of San Marcos 2021b). No primary or secondary ridge lines are located within or adjacent to the project site; the nearest ridgeline is a secondary ridgeline located approximately two miles southwest of the project site. The nearest primary ridgeline is located approximately 2.25 miles southwest of the proje ct site. Therefore, the project will conflict with the ordinance.

The project’s consistency with goals and policies related to scenic views and aesthetics is presented in Table 3.10-5 in Section 3.10. No conflicts were identified.

Grading will consist of a pproximately 39,711 cubic yards (CY) of cut material and 86,052 CY of fill material requiring an import of approximately 46,341 CY of material. A grading variance is requested for the project, since the design includes slopes that exceed 20 feet in height without benching.

Areas where slopes are proposed to be greater than 20 feet include the southern extent of development (31.6-foot maximum slope height), a small area on the western edge of the project site (25.8-foot maximum slope height) and a portion of the project frontage with E. Barham Drive (22.8 - foot maximum slope height with 6 -foot retaining wall). Figure 2 -11 in Chapter 2 depicts the areas that are proposed to have manufactured slopes without benching in excess of 20 feet in height.

These slopes w ill be landscaped and visibility to these slopes will be limited due to intervening residential buildings.

The project design incorporates architectural treatments and design to break up the bulk and scale of the residential buildings. The site design take s into consideration the existing topography of the site and will stair step the residential buildings on the site. The highest elevation areas of the project site, located in the southern portion of the site, will not be developed and will remain as part of the 150-foot fire fuel modification buffer. The proposed landscaping plan will further enhance the project site through implementation of a comprehensive and aesthetically pleasing landscape design, which will be maintained by the Home Owner’s Association. This includes street trees along E. Barham Drive.

The project would not conflict with applicable zoning and other regulations governing scenic quality and impacts would be less than significant.

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 3.1-9
Threshold #4: Would the project create a new source of su bstantial light or glare which would adversely affect day or nighttime views in the area?
Lighting in the project vicinity is associated with roadway lighting along E. Barham Drive and lighting associated with existing residential uses in the area and imme diately adjacent to the project site.

Development of the proposed project would introduce lighting to a site that is currently undeveloped and does not have lighting.

Excessive, poorly designed, or unshielded lighting can be detrimental to astronomical obs ervations.

Two significant observatories are located in San Diego County: Palomar Observatory, - located over 20 miles northeast of the proposed project site/ and Mount Laguna Observatory - located approximately 50 miles southeast of the proposed project site.

The project’s lighting plan is included in Figure 2 -7 in Chapter 2 . As proposed, the project’s exterior lighting will include street lights, wall lanterns, bollard lights and step lights. All lighting proposed for the project will be energy efficient, architecturally appropriate fixtures designed to minimize glare, conflict, and light pollution, while providing illumination levels that create a safe environment for both vehicles and pedestrians. To achieve these goals, all areas of the community will b e aptly lit to coincide with their relevant use and activities. Street area lights will be full cut -off fixtures and will utilize house -side shields to reduce light trespass and prevent light pollution. Lighting using the highest efficiency fixtures and la mps are preferred . Common area lighting within the project will be used to enhance and complement the character of the development. Lighting will need to be varied and appropriate for each use within the common areas of the development.

Exterior lighting p roposed for the project shall be guided by the City of San Marcos Street Lighting Standards and Specifications and San Marcos Municipal Code Title 20, Section 20.300.080, Light and Glare Standards. These standards require downward -directed LED lighting, with the exception of specialized streetscape lighting or architectural detail lighting, which aid in the preservation of dark - sky conditions that are needed by the local observatories. The location, type, and direction of the lighting would be reviewed during Improvement Plan review to ensure compliance with City requirements.

The project does not propose features that would be characterized as creating a new source of glare that would adversely affect daytime or nighttime views in the area. Section 2.2.3 of the Specific Plan (Appendix A of the EIR) details the proposed materials that will be used in the project. Materials used in the project would include concrete roof tiles, wood, stucco, brick with decorative metal accents and trims. These components would be neutral in color. These roof and wall colors and materials are not reflective and would not create significant sources of glare. Since the project would be required to comply with the lighting standards set forth by the City, all lighting would be shie lded to minimize light scatter and maintain dark sky conditions, and the proposed materials to be used in the homes are not glare -inducing, the project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. Impacts would be less than significant.

3.1.5 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 projects contained in an adopted local, regional, or statewide plan, or a related planning document that

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describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to aesthetics, the cumulative analysis is based upon a list approach. All of the cumulative projects within the City identified in Table 2 -3 are considered in this cumulative analysis.

Development of past, current, and future proposed projects continue to alter the visual environment in the City of San Marcos and surrounding area. In general, the aesthetic impacts of the related projects are site ‐specific and would not necessarily combine with other projects that ar e not in the same viewshed to create a cumulative impact. Any related projects in proximity to the project site could potentially contribute to a cumulative impact to visual resources in combination with the impacts of the project site development.

Cumulative effects of lighting are visible over a wide area, due to the potential for lighting from a number of projects to create sky glow. Currently, the project site does not have night lighting since it is undeveloped. Existing sources of light include residential developments to the east and northwest of the project site and commercial and light industrial developments north of the project site on the opposite side of SR -78. As described in Section 3.1.4, the project would introduce new lighting sources at the project site; however, these fixtures would be shielded to minimize light scatter and maintain dark sky conditions and would be required to comply with the lighting standards set forth by the City. Cumulative project would also be required to adhe re to the lighting standards of the jurisdictions in which they are located. Therefore, the project would not have a considerable contribution to sky glow such that a new significant cumulative sky glow impact would occur.

Cumulative impacts would be less than significant.

3.1.6 Mitigation Measures
Based upon the analysis in section 3.1.4 and 3.1.5, aesthetics impacts would be less than significant and no mitigation measures are required.

3.1.7 Conclusion
Development of the proposed project would result in a less than significant impact to scenic vistas and resources. The project would not develop on any primary or secondary ridgelines nor would the project substantially affect a scenic vista.

The project site is not located proximate to a Scenic Highway per the Ca ltrans State Scenic Highway Program, although the City has designated SR-78 a view corridor to surrounding ridgelines. While the be visible from SR -78, the project would not impede views to any primary or secondary ridgelines from SR-78.

Implementation of the project would result in changes to the visual character of the site from undeveloped to residential development; however, impacts would be less than significant due to incorporation of landscaping and architectural treatments and design features. These design features provide for smooth transitions between graded and natural areas and provide landscaping and architectural components for a pleasing aesthetic.

Lighting and glare impacts were also determined to be less than significant, as the future multi- family buildings would not include highly reflective finishes or excessive lighting. Further, exterior lighting proposed for the project will comply with the City of San Marcos Street Lighting Standards and Specifications and San Marcos Municipal. Cumulat ive impacts were determined to be less than significant. Therefore, aesthetic impacts are concluded to be less than significant.

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Figure 3.1-1 Site Photos 1 and 2

3.1 Aesthetics
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Figure 3.1-2 Site Photos 3 and 4

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Figure 3.1-3 Site Photos 5 and 6

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Figure 3.1-4 Site Photos 7 and 8

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Figure 3.1-5 Site Photos 9 and 10

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Figure 3.1-6 Site Photos 11 and 12

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Figure 3.1-7. Architectural Rendering

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 3.2-1

3.2 Air Quality
Introduction
This air quality section identifies, describes, and evaluates air quality issues associated with the proposed project. This section analyzes short -term construction impacts and long -term operational impacts to air quality and determines whether the project would result in a significant impact. This section is based upon the following report, which is included as Appendix D of this document2:
• Air Quality Assessment , East Barham Residential Development Project, prepared by LDN Consulting, September 23, 2021 (LDN 2021).

Table 3.2-1 summarizes the project- and cumulative-level air quality impacts, by threshold.

Table 3.2-1. Air Quality Summary of Impacts
Threshold of Significance Project Direct
Impact
Project Cumulative
Impact
Impact After
Mitigation
#1 - Conflict with or obstruct
implementation of the applicable
air quality plan.

Less than
Significant
Less than
Significant
Less than
Significant
#2 - Result in a cumulatively
considerable net increase of any
criteria pollutant for which the
project region is in non-
attainment under an applicable
federal or state ambient air
quality standard?
Less than
Significant
Less than
Significant
Less than
Significant
#3 - Expose sensitive receptors to
substantial pollutant
concentrations.

Less than
Significant
Less than
Significant
Less than
Significant
#4 – Result in other emissions
(such as those leading to odors)
adversely affecting a substantial
number of people?
Less than
Significant
Less than
Significant
Less than
Significant

3.2.1 Existing Conditions
This section introduces the meteorologic/climate conditions for the project area and presents the current physical setting and pollutant levels in the proximity of the proposed project.

Meteorology/Climate
Climate within the San Diego Air Basin (SDAB) area often varies dramatically over short geographical distances with cooler temperatures on the western coast gradually warming to the east a s prevailing

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

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winds from the west heats up. Most of southern California is dominated by high-pressure systems for much of the year, which keeps San Diego mostly sunny and warm . Typically, during the winter months, the high -pressure systems drop to the south and brings cooler, moister weather from the north.

Meteorological trends within the City of San Marcos produce daytime highs typically ranging between 69ºF in the winter to approximately 85ºF in the summer with August usually being the hottest month.

Median temperatures range from approximately 55ºF in the winter to approximately 74ºF in the summer. The average humidity is approximately 64% in the winter and about 74 % in the summer (LDN 2021).

Baseline Air Quality
Regional
The project site is located in the land use jurisdictions of the City of San Marcos (City) within the County of San Diego, within the northwestern coastal portion of the SDAB under the jurisdiction of the San Diego Air Pollution Control District (SDAPCD). The SDAB is one of 15 air basi ns that geographically divide the State of California.

Project area air quality can best be characterized from ambient measurements made by the SDAPCD. SDAPCD operates a network of ambient air monitoring stations throughout San Diego County, which measure ambient concentrations of pollutants and determine whether the ambient air quality meets national and state air quality standards. Pursuant to the 1990 Clean Air Act amendments, U.S. Environmental Protection Agency (USEPA) classifies air basins (or portion s thereof) as “attainment” or “nonattainment” for each criteria air pollutant, based on whether the National Ambient Air Quality Standards (NAAQS) have been achieved. Generally, if the recorded concentrations of a pollutant are lower than the standard, the area is classified as “attainment” for that pollutant. If an area exceeds the standard, the area is classified as “nonattainment” for that pollutant. As explained further below, these standards are set by USEPA or the California Air Resources Board (CARB) for the maximum level of a given air pollutant that can exist in the outdoor air without unacceptable effects on human health or the public welfare. If there is not enough data available to determine whether the standard is exceeded in an area, the area i s designated as “unclassified” or “unclassifiable.” The designation of “unclassifiable/attainment” means that the area meets the standard or is expected to meet the standard despite a lack of monitoring data.

Areas that achieve the standards after a nonatt ainment designation are re -designated as maintenance areas and must have approved maintenance plans to ensure continued attainment of the standards. The California Clean Air Act, like its federal counterpart, calls for the designation of areas as “attainment” or “nonattainment,” but based on the California Ambient Air Quality Standards (CAAQS) rather than the NAAQS.

Current attainment designations for the SDAB are presented in Table 3.2 -2. As shown, the SDAB currently exhibits a non-attainment status for the federal 8-hour standard for ozone (O3). Additionally, the SDAB is either in attainment or unclassified for federal standards of 1 -hour O3, carbon monoxide (CO), respirable particulate matter (PM 10), fine particulate matter (PM 2.5), nitrogen dioxide (NO 2), sulfur dioxide (SO 2), and lead (Pb). The SDAB is also in attainment of state air quality standards for all pollutants except for O3, PM10, and PM2.5.

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Table 3.2-2. San Diego County Air Basin Attainment Status by Pollutant Criteria Pollutant Federal Designation State Designation Ozone (O3) – 8-hour Nonattainment Nonattainment
Ozone (O3) – 1-hour Attainment Nonattainment(1)
Carbon Monoxide (CO) Attainment Attainment
Respirable Particulate Matter (PM10) Unclassifiable(2) Nonattainment Fine Particulate Matter (PM2.5) Attainment Nonattainment Nitrogen Dioxide (NO2) Attainment Attainment
Sulfur Dioxide (SO2) Attainment Attainment
Lead (Pb) Attainment Attainment
Sulfates No Federal Standard Attainment
Hydrogen Sulfide No Federal Standard Unclassified
Visibility Reducing Particles No Federal Standard Unclassified Source: SDAPCD 2021.

Notes: (1) The federal 1-hour standard of 12 parts per hundred million (pphm) was in effect from 1979 through June 15, 2005. The revoked standard is referenced here because it was employed for such a long period and because this benchmark is addressed in State Implementation Plans. (2) At the time of designation, if the available data does not support a designation of attainment or nonattainment, the area is designated as unclassifiable.

Local
The SDAPCD air quality monitoring stations located in Carmel Mount Ranch and Camp Pendleton are the closest stations to the project area that monitors the full spectrum of air qua lity. Table 3.2 -3 summarizes the two most recent years of monitoring data from the Carmel Mountain Ranch and Camp Pendleton monitoring stations which are 11 and 15.5 miles from the project site, respectively.

Sensitive Receptors
Some land uses are consider ed more sensitive to changes in air quality than others, depending on the population groups and the activities involved. People most likely to be affected by air pollution, as identified by CARB, include children, the elderly, and people with cardiovascula r and chronic respiratory diseases. Sensitive receptors include residences, schools, playgrounds, childcare centers, long-term healthcare facilities, rehabilitation centers, convalescent centers, and retirement homes. The project vicinity is developed prim arily with residential uses. To the east of the project is the Mira Lago residential development and further east is a mobile home park. To the southeast is the Williamsburg residential development. West of the project site is Grace Church, which includes a

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day care and preschool, and the Barham Park & Ride. Southwest of the project site is residential development associated with the Walnut Hills II Specific Plan.

Table 3.2-3. Two Year Ambient Air Quality Summary Near the Project Site (Camp Pendleton or Carmel Mountain Ranch Stations)
Pollutant(1) Averaging
Time CAAQS NAAQS 2019 2020
Days
Exceeded
Over 2 Years
O3
(ppm)
1 hour 0.09 ppm No Standard 0.08 0.09 0
8 hour 0.070 ppm 0.075 ppm 0.06 0.07 6
PM10
(µg/m3)
24 hour 50 µg/m3 150 µg/m3 PM10 Data Not Available
for Monitoring Sites
near Project Site.

Annual 20 µg/m3 No Standard
PM2.5(2)
(µg/m3)
24 hour No Standard 35 µg/m3 18.9 40.2 N/A
Annual 12 µg/m3 15 µg/m3 8.2 9.3 N/A
NO2
(ppm)
Annual 0.030 ppm 0.053 ppm 0.011 0.013 N/A
1 hour 0.18 ppm 0.100 ppm 0.086 0.056 N/A
CO(2)
(ppm)
8 hour 9 ppm 9 ppm 4.1 3.3 N/A
1 hour 35 ppm 20 ppm 2.5 1.78 N/A
Source: LDN Consulting 2021.

Notes: (1) SO2 is only monitored at the El Cajon Monitoring Station. Within the entire County of San Diego, SO2 emissions within the County are essentially Zero for all metrics including the Average, Maximum 24 hour and 1- hour standards. The Highest 1-hr measurement identified is 0.004 ppm and the most restrictive standard (CAAQS for SO2) is 0.25 ppm.
(2) Data was collected from Carmel Mountain Ranch station which began in 2019. All other data presented was collected at the Camp Pendleton Monitoring Station.

Pollutants and Effects
Criteria Air Pollutants
Criteria air pollutants are defined as pollutants for which the federal and state governments have established ambient air quality standards, or criteria, for outdoor concentrations to protect public health. The federal and state standards have been set, with an adequate margin of safety, at levels above which concentrations could be harmful to human health and welfare. These standards are designed to protect the most sensitive persons from illness or discomfort. The crit eria air pollutants that are monitored by the USEPA are ozone (O
3), carbon monoxide (CO), nitrogen dioxide (NO 2),
particulate matter less than or equal to 10 microns or 2.5 microns in diameter (PM 10, and PM 2.5) sulfur dioxide (SO 2), and lead (Pb). These pollutants, as well as toxic air contaminants (TACs), are discussed in the following text. In California, sulfates, vinyl chloride, hydrogen sulfide, and visibility - reducing particles are also regulated as criteria air pollutants. Examples of sources and eff ects of these pollutants are identified below:

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Ozone (O3): A strong smelling, pale blue reactive toxic chemical gas consisting of three oxygen atoms.

It is a product of the photochemical process involving the sun's energy. O 3 exists in the upper atmosphere O3 layer, as well as at the earth’s surface. O 3 at the earth's surface causes numerous adverse health effects, including lung inflammation, tissue damage, and impaired lung functioning, is a major component of smog, and can damage materials such as rubber, fabrics, and plastics.

Carbon Monoxide (CO): Carbon monoxide is a colorless, odorless, tasteless, and toxic gas resulting from the incomplete combustion of fossil fuels. CO interferes with the blood's ability to carry oxygen to the body's tissues and res ults in numerous adverse health effects including fatigue, headaches, confusion, and dizziness.

Nitrogen Dioxide (NO2): NO2 is formed when nitrogen (N 2) combines with oxygen (O 2). Its life span in the atmosphere ranges from one to seven days. NO 2 is typica lly created during combustion processes and is a major contributor to smog formation and acid deposition. NO 2 may result in numerous adverse health effects, including respiratory damage. It absorbs blue light, resulting in a brownish-red cast to the atmosphere and reduced visibility.

Particulate Matter Less Than or Equal to 10 Microns in Diameter (PM 10): A major air pollutant consisting of tiny solid or liquid particles of soot, dust, smoke, fumes, and aerosols. The size of the particles (equal to 10 micron s or smaller, about 0.0004 inch or less in diameter) allows them to easily enter the lungs where they may be deposited, resulting in adverse health effects, including allergies, asthma, and respiratory illness. PM
10 also causes visibility reduction.

Particulate Matter Less Than or Equal to 2.5 Microns in Diameter (PM 2.5): A similar air pollutant consisting of tiny solid or liquid particles which are 2.5 microns or smaller (which are often referred to as fine particles). These particles are formed in the atm osphere from primary gaseous emissions that include sulfates formed from SO 2 released from power plants and industrial facilities and nitrates that are formed from NO x released from power plants, automobiles, and other types of combustion sources. The chem ical composition of fine particles depends mostly on location of the emissions, time of year, and weather conditions. Adverse health effects of PM 2.5 are similar to those of PM10.

Sulfur Dioxide (SO 2): Typically strong smelling, colorless gas that is formed by the combustion of fossil fuels. SO 2 and other sulfur oxides contribute to the problem of acid deposition as well as adverse health effects including respiratory constriction and, with continued exposure, in creased incidents of pulmonary symptoms.

Lead (Pb): Lead in the atmosphere occurs as particulate matter. Lead has historically been emitted from vehicles combusting leaded gasoline, as well as from industrial sources. With the phase -out of leaded gasoline, large manufacturing facilities are the sources of the largest amounts of lead emissions. Lead has the potential to accumulate over time and cause gastrointestinal, central nervous system, kidney, and blood diseases upon prolonged exposure. Lead is also cl assified as a probable human carcinogen.

Non-Criteria Air Pollutants
Toxic Air Contaminants . A substance is considered toxic if it has the potential to cause adverse health effects in humans, including increasing the risk of cancer upon exposure, or acute and/or chronic noncancer health effects. A toxic substance released into the air is conside red a TAC. TACs are identified by federal and state agencies based on a review of available scientific evidence. In the State of California, TACs are identified through a two- step process that was established in 1983

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under the Toxic Air Contaminant Identif ication and Control Act. This two- step process of risk identification and risk management and reduction was designed to protect residents from the health effects of toxic substances in the air. In addition, the California Air Toxics “Hot Spots” Information and Assessment Act, Assembly Bill (AB) 2588, was enacted by the legislature in 1987 to address public concern over the release of TACs into the atmosphere. The law requires facilities emitting toxic substances to provide local air pollution control distri cts with information that will allow an assessment of the air toxics problem, identification of air toxics emissions sources, location of resulting hotspots, notification of the public exposed to significant risk, and development of effective strategies to reduce potential risks to the public over 5 years.

Examples include certain aromatic and chlorinated hydrocarbons, certain metals, and asbestos.

TACs are generated by several sources, including stationary sources, such as dry cleaners, gas stations, combu stion sources, and laboratories; mobile sources, such as automobiles; and area sources, such as landfills. Adverse health effects associated with exposure to TACs may include carcinogenic (i.e., cancer -causing) and noncarcinogenic effects. Noncarcinogenic effects typically affect one or more target organ systems and may be experienced on either short -term (acute) or long-term (chronic) exposure to a given TAC.

CARB classified “particulate emissions from diesel - fueled engines” (i.e., diesel particulate matt er [DPM]) as a TAC in August 1998. DPM is part of a complex mixture that makes up diesel exhaust.

Diesel exhaust is composed of two phases, gas and particle, both of which contribute to health risks.

DPM is emitted from a broad range of diesel engines: on -road diesel engines of trucks, buses, and cars and off-road diesel engines including locomotives, marine vessels, and heavy -duty construction equipment, among others. Approximately 70% of all airborne cancer risk in California is associated with DPM (CARB 2000). To reduce the cancer risk associated with diesel particulate matter, CARB adopted a diesel risk reduction plan in 2000 (CARB 2000).

3.2.2 Regulatory Setting
The following section provides a general description of the applicable regulatory requirements pertaining to air quality, including federal, state, and local guidelines.

Federal
Federal Clean Air Act
The federal Clean Air Act (CAA), passed in 1970 and last amended in 1990, forms the basis for the national air pollution control effort. The U.S. Environmental Protection Agency is responsible for implementing most aspects of the Clean Air Act, including setting National ambient air quality standards (NAAQS) for major air pollutants, setting hazardous air pollutant standards, approving state attainment plans, setting motor vehicle emission standards, issuing stationary source emission standards and permits, and establishing acid rain control measures, stratospheric O3 protection measures, and enforcement provisions. Under the Clean Air Act, NAAQS are established for the criteria pollutants O
3, CO, NO2, SO2, PM10, PM2.5, and lead and shown in Table 3.2-4.

The NAAQS describe acceptable air quality conditions designed to protect the health and welfare of the citizens of the nation. The NAAQS (other than for O 3, NO2, SO2, PM10, PM2.5, and those based on
annual averages or arithmetic mean) are not to be exceeded more than once per year. NAAQS for O3, NO2, SO2, PM10, and PM2.5 are based on statistical calculations over 1 - to 3-year periods, depending on the pollutant. The Clean Air Act requires the USEPA to reassess the NAAQS at least every 5 years to determine whether adopted standards are adequate to protect public health based on current

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scientific evidence. States with areas that exceed the NAAQS must prepare a S tate Implementation Plan (SIP) that demonstrates how those areas will attain the standards within mandated time frames.

These plans must include pollution control means that demonstrate how the standards will be met as expeditiously as possible.

Table 3.2-4. Ambient Air Quality Standards
Pollutant Average
Time
California Standards1 National Standards2
Concentration3 Method4 Primary3,5 Secondary3,6 Measurement Method7
Ozone (O3)8
1 Hour 0.09 ppm
(180 µg/m3) Ultraviolet
Photometry
Same as
Primary
Standard
Ultraviolet
Photometry
8 Hour 0.070 ppm
(137 µg/m3)

0.070 ppm
(137 µg/m3)
Respirable
Particulate
Matter
(PM10)9
24 Hour 50 µg/m3
Gravimetric
or Beta
Attenuation
150 µg/m3
Same as
Primary
Standard
Inertial
Separation
and
Gravimetric
Analysis
Annual
Arithmetic
Mean
20 µg/m3
Fine
Particulate
Matter
(PM2.5)9
24 Hour No Separate State Standard 35 µg/m3
Same as
Primary
Standard
Inertial
Separation
and
Gravimetric
Analysis
Annual
Arithmetic
Mean
12 µg/m3
Gravimetric
or Beta
Attenuation

12.0 µg/m3 15 µg/m3
Carbon
Monoxide
(CO)
8 hour 9.0 ppm
(10mg/m3) Non-
Dispersive
Infrared
Photometry
(NDIR)
9 ppm (10
mg/m3) -
Non-
Dispersive
Infrared
Photometry 1 hour 20 ppm
(23 mg/m3)
35 ppm
(40 mg/m3)
8 Hour
(Lake
Tahoe)
6 ppm
(7 mg/m3)
Nitrogen
Dioxide
(NO2)10
Annual
Arithmetic
Mean

0.030 ppm
(57 µg/m3) Gas Phase
Chemilumin
escence

0.053 ppm
(100
µg/m3)8
Same as
Primary
Standard Gas Phase
Chemilumines
cence 1 Hour 0.18 ppm
(339 µg/m3)

0.100 ppm8
(188/
µg/m3)
-
Sulfur
Dioxide
(SO2)11
Annual
Arithmetic
Mean
- Ultraviolet
Fluorescen
ce

0.030 ppm10
(for Certain
Areas)
- Ultraviolet
Fluorescence;
Spectrophoto
metry 24 Hour 0.04 ppm 0.14 ppm10 -

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Pollutant Average
Time
California Standards1 National Standards2
Concentration3 Method4 Primary3,5 Secondary3,6 Measurement Method7
(105 µg/m3) (for Certain
Areas) (See
Footnote 9)
(Pararoosanili
ne Method)9
3 Hour -

0.5 ppm
(1300
µg/m3)
1 Hour 0.25 ppm
(655 µg/m3)
75 ppb
(196 µg/m3) -
Lead12,13
30 Day
Average 1.5 µg/m3
Atomic
Absorption
- -
Calendar
Quarter - 1.5 µg/m3
Same as
Primary
Standard
High Volume
Sampler and
Atomic
Absorption
Rolling 3-
Month
Average
- 0.15 µg/m3
Visibility
Reducing
Particles
8 Hour See footnote 13
Sulfates 24 Hour 25 µg/m3
Ion
Chromatogr
aphy

Hydrogen
Sulfide 1 Hour 0.03 ppm
(42 µg/m3)
Ultraviolet
Fluorescen
ce

Vinyl
Chloride12
24 Hour 0.01 ppm
(26 µg/m3)
Gas
Chromatogr
aphy

1. California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1 and 24 hour), nitrogen dioxide, and particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded.

All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.

2. National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 µg/m3 is equal to or less than one. For PM2.5, the 24-hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard. Contact the U.S. EPA for further clarification and current national policies.

3. Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.

4. Any equivalent procedure which can be shown to the satisfaction of the ARB to give equivalent results at or near the level of the air quality standard may be used.

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Pollutant Average
Time
California Standards1 National Standards2
Concentration3 Method4 Primary3,5 Secondary3,6 Measurement Method7

6. National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health

7. National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.

8. Reference method as described by the EPA. An “equivalent method” of measurement may be used but must have a “consistent relationship to the reference method” and must be approved by the EPA.

9. On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm.

10. On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3 to 12.0 μg/m3 . The existing national 24- hour PM2.5 standards (primary and secondary) were retained at 35 μg/m3 , as was the annual secondary standard of 15 μg/m3 . The existing 24-hour PM10 standards (primary and secondary) of 150 μg/m3 also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years.

11. To attain the 1-hour national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 ppb. Note that the national 1-hour standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the national 1-hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm.

12. On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain the 1-hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.

13. The ARB has identified lead and vinyl chloride as 'toxic air contaminants' with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.

14. The national standard for lead was revised on October 15, 2008 to a rolling 3-month average. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.

15. In 1989, the ARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are "extinction of 0.23 per kilometer" and "extinction of 0.07 per kilometer" for the statewide and Lake Tahoe Air Basin standards, respectively.

Source: CARB 2016, http://www.arb.ca.gov/research/aaqs/aaqs2.pdf ppm = parts per million
µg/m3 = micrograms per cubic meter
mg/m3= milligrams per cubic meter

The NAAQS were amended in July 1997 to include an additional standard for O 3, and to adopt a standard for fine particulates (PM 2.5). In June 2002, a stringent statewide PM 2.5 standard was adopted. In 2012, the PM2.5 standard was lowered further based on air quality monitoring data.

National Ambient Air Quality Standards (NAAQS)
To gauge the significance of the air quality impacts of the proposed project, those impacts, together with existing bac kground air quality levels, must be compared to the applicable ambient air quality standards. These standards are the levels of air quality considered safe, with an adequate margin of safety, to protect public health and welfare. Primary standards set limits for the protection of public health, including those people most susceptible to further respiratory distress such as asthmatics, children, and the elderly, or sensitive receptors. Secondary standards set limits to protect public welfare and include prot ection against decreased visibility and damage to animals, crops,

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vegetation, and buildings. Research has shown that chronic exposure to O 3 at levels that just marginally meet clean air standards may nevertheless have adverse health effects. State and federal agencies, therefore, have promulgated a more stringent 8 -hour O 3 standard that better reflects human health response to more chronic exposure, shown in Table 3.2-4.

State
California Ambient Air Quality Standards (CAAQS)
In California, the task of air q uality management and regulation has been legislatively granted to CARB, with subsidiary responsibilities assigned to air quality management districts and air pollution control districts at the regional and county levels. CARB, which became part of the Cal ifornia Environmental Protection Agency in 1991, is responsible for ensuring implementation of the California Clean Air Act of 1988, responding to the federal Clean Air Act, and regulating emissions from motor vehicles and consumer products.

The CARB has established California ambient air quality standards (CAAQS), which are generally more restrictive than the NAAQS. The CAAQS describe adverse conditions; that is, pollution levels must be below these standards before a basin can attain the standard. Air quality is considered “in attainment” if pollutant levels are continuously below the CAAQS and violate the standards no more than once each year. The CAAQS for O
3, CO, SO 2 (1-hour and 24 -hour), NO 2, PM 10, and PM 2.5 and visibility-reducing particles are values that are not to be exceeded. All others are not to be equaled or exceeded. Additionally, sulfates, vinyl chloride, hydrogen sulfide, and visibility -reducing particles are also regulated as criteria air pollutants in California. The CAAQS currently in effect in California are also shown in Table 3.2 -4 and include the most recently adopted federal standards for chronic (8 - hour) O3 exposure and for ultra-small diameter particulate matter of 2.5 microns or less in diameter (PM2.5). CAAQS restrict four add itional contaminants: visibility reducing particles, sulfates, hydrogen sulfide, and vinyl chloride. Current attainment designations for the SDAPCD are presented in Table

3.2-2.

California Clean Air Act
The California Clean Air Act (CCAA), signed into law in 1988, requires all areas of the state to achieve and maintain the CAAQS by the earliest practical date. Air pollution from commercial and industrial facilities is regulated by local air quality management districts, whereas mobile sources of air pollution are regulated by the California Air Resources Board (CARB) and the USEPA. All air pollution control districts have been formally designated as “attainment” or “nonattainment” for each state air quality standard, as shown in Table 3.2 -2. Areas in Califor nia where ambient air concentrations of pollutants are higher than the state standard are considered to be in “non -attainment” status for that pollutant. Non -attainment designations are categorized into three levels of severity: (1) moderate, (2) serious, and (3) severe. If there are inadequate or inconclusive data to make a definitive attainment designation, districts are considered “unclassified.” Local
San Diego Air Pollution Control District
Although CARB is responsible for the regulation of mobile emission sources within the state, local air quality management districts and air pollution control districts are responsible for enforcing standards and regulating stationary sources. The project is located within the SDAB and is subject to SDAPCD guidelines and regulations. In San Diego County, O3 and particulate matter are the

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pollutants of main concern, because exceedances of the CAAQS for those pollutants are experienced here in most years. For this reason, the SDAB has been designated as a nonattainment area for the state PM10, PM2.5, and O 3 (1-hour and 8 -hour) standards. San Diego County is currently designated as a Serious Nonattainment Area for the 2008 ozone NAAQS (75 ppb), and a Moderate Nonattainment Area for the 2015 ozone NAAQS (70 ppb). Accordingly, the SDAPCD must prepare and submit to the USEPA, via CARB, two ozone SIPs identifying control measures and associated emissions reductions necessary to demonstrate attainment of the 75 -ppb standard by July 20, 2021 (2020 attainment year) and attainment of the 70-ppb standard by August 3, 2024 (2023 attainment year). The 2020 Plan for Attaining the National Ozone Standards (SDAPCD 2020) addresses all requirements for both ozone standards.

SDAPCD and the San Diego Association of Governments (SANDAG) are responsible for developing and implementing the clean air plan for attainment and maintenance of the ambient air quality standards in the SDAB. The Regional Air Quality Strategy (RAQS) for the SDA B was initially adopted in 1991 and is updated every 3 years (most recently in 2016) (SDAPCD 2016). The RAQS outlines SDAPCD’s plans and control measures designed to attain the CAAQS for O3. The RAQS details how the region will manage and reduce O3 precurs ors (NOx and VOCs) by identifying measures and regulations intended to reduce these contaminants. The control measures identified in the RAQS generally focus on stationary sources; however, the emissions inventories and projections in the RAQS address all potential sources, including those under the authority of CARB and USEPA.

Incentive programs for reduction of emissions from heavy -duty diesel vehicles, off -road equipment, and school buses are also established in the RAQS
The RAQS relies on information fr om CARB and SANDAG, including mobile and area source emissions, as well as information regarding projected growth in San Diego County and the cities in the County, to project future emissions and then determine from that the strategies necessary for the re duction of emissions through regulatory controls. CARB mobile source emission projections and SANDAG growth projections are based on population, vehicle trends, and land use plans developed by the County and the cities in the County as part of the developm ent of their general plans. Projects that produce less growth than predicted by SANDAG would generally conform to the RAQS.

In December 2005, SDAPCD prepared a report titled “Measures to Reduce Particulate Matter in San Diego County” to address implementat ion of Senate Bill (SB) 656 in San Diego County (SB 656 required additional controls to reduce ambient concentrations of PM10 and PM2.5). In the report, SDAPCD evaluates the implementation of source -control measures that would reduce particulate matter emissions associated with residential wood combustion (SDAPCD 2005).

City of San Marcos General Plan – Conservation and Open Space Element The Conservation and Open Space Element of the City’s General Plan identifies one goal and a number of policies regardin g air quality. Those policies that are applicable to the project are listed below:
• Goal COS -4: Improve regional air quality and reduce greenhouse gas emissions that contribute to climate change.
o Policy COS-4.1: Continue to work with the U.S. EPA, CARB, SAN DAG, and the SDAPCD to meet State and federal ambient air quality standards.

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o Policy COS-4.5: Encourage energy conservation and the use of alternative energy sources within the community.
o Policy COS-4.6: Promote efficient use of energy and conservation of a vailable resources in the design, construction, maintenance and operation of public and private facilities, infrastructure, and equipment.
o Policy COS -4.8: Encourage and support the generation, transmission, and use of renewable energy.

The project’s consis tency with applicable General Plan goals and policies is discussed in Section

3.10, Land Use and Planning. As detailed in Table 3.10 -5, the project is consistent with the applicable General Plan goals and policies pertaining to air quality.

3.2.3 Thresholds of Significance
The State of California has developed guidelines to address the significance of air quality impacts based on Appendix G of the California Environmental Quality Act (CEQA) Guidelines which provides guidance that a project would have a significant environmental impact if it would:
• Threshold #1: Conflict with or obstruct implementation of the applicable air quality plan; • Threshold #2: Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or state ambient air quality standard;
• Threshold #3: Expose sensitive receptors to substantial pollutant concentrations; • Threshold #4: Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
To determine whether a project would: (a) result in emissions that would violate any air quality standard or contribute substantially to an existing or projected air quality violation; or (b) result in a cumulatively considera ble net increase of PM
10 or PM 2.5 or exceed quantitative thresholds for O 3
precursors, nitrogen oxides (NO x) and volatile organic compounds (VOCs), project emissions may be evaluated based on the quantitative emission thresholds established by the SDAPCD, the agency responsible for air quality planning, monitoring, and enforcement within this basin. As part of its air quality permitting process, the SDAPCD has established thresholds in Rule 20.2 for the preparation of Air Quality Impact Assessments (AQIAs) (SDAPCD 1998).

For CEQA purposes, these screening criteria can be used as numeric methods to demonstrate that a project’s total emissions would not result in a significant impact to air quality. Since SDAPCD does not have AQIA thresholds for emissions of V OCs, the use of the Coachella Valley VOC threshold from the South Coast Air Quality Management District is acceptable.

The thresholds listed in Table 3.2 -5 represent screening -level thresholds that can be used to evaluate whether project -related emissions could cause a significant impact on air quality for both construction and operation. Emissions below the screening -level thresholds would not cause a significant impact. If emissions exceed these thresholds, modeling would be required to demonstrate that the project’s total air quality impacts result in ground -level concentrations that are below the State and Federal AAQS, including appropriate background le vels. For nonattainment pollutants (PM10 and PM 2.5 plus O 3, with O 3 precursors NO x and VOCs), if emissions exceed the thresholds

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shown in Table 3.2 -5, the project could have the potential to result in a cumulatively considerable net increase in these pollutants and thus could have a significant impact on the ambient air quality.

In addition to impacts from criteria pollutants, project impacts may include emissions of pollutants identified by the state and federal government as toxic air contaminants (TACs) or Hazardous Air Pollutants (HAPs). SDAPCD Regulation XII establishes acceptable risk levels and emission control requirements for new and modified facilities that may emit additional TACs. Under Rule 1210 (adopted in 1996 and revised several times, most r ecently 2021), emissions of TACs that result in a cancer risk of 10 in 1 million or less and a health hazard index of one or less would not be required to notify the public of potential health risks. If a project has the potential to result in emissions of any TAC or HAP that results in a cancer risk of greater than 10 in 1 million, the project would be deemed to have a potentially significant impact and would be required to implement toxics best available control technology (T-BACT) (SDAPCD 1996).

Table 3.2-5. Screening-Level Criteria for Air Quality Impacts Pollutant Total Emissions (Pounds/Day)
Construction Emissions
Respirable Particulate Matter (PM10) 100
Particulate Matter (PM2.5) 55
Nitrogen Oxide (NOx) 250
Sulfur Oxide (SOx) 250
Carbon Monoxide (CO) 550
Volatile Organic Compounds (VOCs) 75
Reactive Organic Gases (ROG) (SCAQMD) 75
Operational Emissions
Respirable Particulate Matter (PM10) 100
Particulate Matter (PM2.5) 55
Nitrogen Oxide (NOx) 250
Sulfur Oxide (SOx) 250
Carbon Monoxide (CO) 550
Lead and Lead Compounds 3.2
Volatile Organic Compounds (VOCs) 75
Reactive Organic Gases (ROG) SCAQMD 75
Source: LDN Consulting 2021.

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Air quality regulators typically define sensitive receptors as schools (Preschool-12th Grade), hospitals, resident care facilities, day -care centers, or other facilities that may house individuals with health conditions that would be adversely impacted by changes in air quality. Any project that has the potential to directly impact a sensit ive receptor located within one mile and that results in a health risk greater than 10 in 1 million would be deemed to have a potentially significant impact3.

SDAPCD Rule 51 (Public Nuisance) also prohibits emission of any material which causes nuisance to a considerable number of persons or endangers the comfort, health, or safety of any person (SDAPCD 1976). A project that proposes a use which would produce objectionable odors would be deemed to have a significant odor impact if it would affect a consider able number of offsite receptors. The impacts associated with construction and operation of the project were evaluated for significance based on the aforementioned significance criteria.

3.2.4 Project Impact Analysis
Threshold #1: Conflict with or obstruct implementation of the applicable air quality plan As part of the RAQS and SIP planning process, the SDAPCD develops an emission inventory, based on growth projections from SANDAG and existing emissions figures within the SDAB. The SDAPCD then uses the emission inventory to conduct modeling to demonstrate that the SDAB will attain and maintain the state and federal O
3 standards. This inventory could be thought of as an “emissions budget” for the SDAB, accounting for current emissions as well as previously approve d projects consistent with current General Plan policies.

Projects that are consistent with the currently adopted General Plan are determined to be consistent with SDAB’s air quality plans, including the RAQS and the SIP. If a project proposes development that is consistent with or less than estimates provided in the General Plan, the project would not conflict with or obstruct implementation of the RAQS or SIP.

The project site has an existing General Plan Land Use designation of Mixed Use 3 (MU3), which is a mixed-use non -residential designation with a maximum floor area ratio (FAR) of 1.50 . The project includes a General Plan amendment request to change the existing MU3 designation to Specific Plan. The proposed project seeks to construct 151 multi -family residential units. The existing site would allow for up to 275,000 s.f. of office use and approximately 18,000 SF of commercial (retail) use and would generate 5,410 trips (LLG 2021) or more than four times more traffic than the proposed residential uses. Therefore, the project’s development intensity and density will decrease from its current General Plan designation. The project is therefore considered consistent with the County’s RAQS and would comply with the state’s SIP. Impacts would be less than significant.

Threshold #2: Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non -attainment under an applicable federal or state ambient air quality standard
Air quality impacts associated with the proposed project would likely come from two potential sources. The first is related to project construction, such as impacts related to construction equipment emissions, grading and rock crushing activities, and haul trucks for soils import. The second is operational from mobile source emissions from vehicles traveling to and from the proposed project as well as natural gas emission sources. Presented below are the analyses and findings for these two impact areas.

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Construction Emissions Analysis
Construction activities are a source of fugitive dust emissions that may have a temporary, but substantial, impact on local air quality. These emissions are generally associated with grading, heavy equipment usage, blasting, and from construction worker commutes. Du st emissions and impacts vary with the level of activity, specific operations conducted, and prevailing winds. For the proposed project, rough grading activities assume site preparation, rock drilling, grading, paving, building construction and architectur al coating. It should be noted that the project would utilize Tier IV or better construction equipment, which include diesel particulate filters, as required by current regulations.

Construction grading operations for the project are anticipated to include 46,341 cubic yards (cy) of imported fill. It is anticipated that earthwork activities would include a rock crusher and blasting. The project would start grading late 2022 with construction of the residential buildings to start shortly thereafter. Construction of all residential buildings would be expected sometime in 2024.

The California Emissions Estimator Model (CalEEMod) 2020.4.0 was used to calculate worst case construction-related emissions. Emissions resulting from blasting and rock crushing, as well as fugitive dust generation were evaluated using emission factors from the USEPA AP -42 publication.

The AERSCREEN dispersion model was used to determine the concentration for air pollutants at any location near the pollutant generator as well as pr edict the maximum exposure distance and concentrations. The following design features were assumed within the CalEEMod analysis:
• All heavy diesel construction equipment will be classified as Tier IV. • In accordance with Rule 67 of the California Air Resourc e Board, only Low VOC paints shall be utilized onsite.
• Compliance with SDAPCD’s fugitive dust rules and fugitive dust control measures which will be provided by the City of San Marcos.

Table 3.2 -6 presents construction -related emissions. As shown in Table 3.2 -6, construction emissions for all criteria pollutants will be below the screening level thresholds.

Table 3.2-6. Construction Emissions (lbs/day)
Year ROG NOx CO SO2 PM10
(Dust)
PM10
(Exhaust)
PM10
(Total)
PM2.5
(Dust)
PM2.5
(Exhaust)
PM2.5
(Total)
2022 1.79 28.17 50.38 0.18 22.50 0.37 22.79 10.86 0.36 11.14 2023 1.41 23.39 48.14 0.17 12.09 0.30 12.39 4.42 0.29 4.71 2024 42.91 3.44 22.83 0.04 1.32 0.06 1.37 0.35 0.06 0.41 Blasting
Emissions 102 402 20.59 20.59
Total
Construction
Emissions
With
Blasting

46.11 157 523.35 0.39 56.5 0.73 57.14 15.63 0.71 16.26

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Year ROG NOx CO SO2 PM10
(Dust)
PM10
(Exhaust)
PM10
(Total)
PM2.5
(Dust)
PM2.5
(Exhaust)
PM2.5
(Total)
Screening
Level
Threshold
75 250 550 250 - - 100 - - 55
Exceed
Threshold? No No No No - - No - - No
Source: LDN Consulting 2021
The proposed project would utilize approximately six tons of ammonium nitrate per blast, which would generate up to 402 lbs (67 lbs/ton * 6 tons) of carbon monoxide and up to 102 lbs (17 lbs/ton * 6 tons) of nitrogen oxides during a blast . These quantities would be additive to the mass grading operations for the entire project site and could be added to the worst -case mass grading daily CO and NOx output . Additional particulates derived from each blast is estimated over a 20,000 s.f. area roughly 100 -foot by 200 -foot in dimension. Given this and according to USEPA guidance (USEPA 1995), it’s estimated that each blast would generate 20.59 lb/blast as is shown in the equation below:

𝑃𝑃𝑀𝑀10(𝑙𝑙𝑙𝑙/𝐵𝐵𝑙𝑙𝐵𝐵𝐵𝐵𝐵𝐵) = 0.000014 ∗ (20,000𝑓𝑓𝐵𝐵2)1.5 ∗ 0.52 = 20.59(𝑙𝑙𝑙𝑙/𝑙𝑙𝑙𝑙𝐵𝐵𝐵𝐵𝐵𝐵) Assuming six tons of ANFO use per d ay, maximum daily emissions from explosives would be 451 pounds per day of CO and 140 pounds per day of NOx, as shown in Table 3.2-6.

Architectural Coatings
The project will use architectural coatings (e.g., paint and interior finishing products) in home construction. According to the USEPA, VOC exposure in humans can result in health effects in humans including eye, nose, and throat irritation (USEPA 2017). In San Diego County any person who manufactures, blends, or repackages, supplies, sells, offers for sale, applies, or solicits the application of any architectural coating for use within the County must comply with SDAPCD Rule

67.0.1 (Architectural Coatings). As required by Rule 67.0.1, the project would utilize low -VOC paint that does not exceed 100 grams of VOC per liter for interior surfaces and 150 grams of VOC per liter for exterior surfaces3. This assumption was added into the CalEEMod model run for the project.

In summary, and as shown in Table 3.2 -6, construction -related emissions would be below the screening level thresholds for all pollutants. Therefore, construction -related air emissions would not violate any air quality standards and impacts are less than significant.

Operational Emissions Analysis
Daily project operations would generate emissions from sources such as area, energy, mobile, waste and water use. Area Sources include consumer products, landscaping, and architectural coatings as part of regular m aintenance. Operational emissions were calculated using the CalEEMod 2020.4.0 model for both summer and winter scenarios. The traffic inputs for CalEEMod were adjusted to be consistent with the proposed project traffic study. Based on that study, the proposed project would generate 1,208 net average daily trips (LLG 2021). The project traffic trip distances are based on an

3 https://www.arb.ca.gov/DRDB/SD/CURHTML/R67.0.1.pdf

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average trip distance within the County which can be calculated using the total daily VMT within the county (86,284,768) miles divided by the total trips in the County (16,007,853) or roughly 5.4 miles.

Table 3.2-7 summarizes project-related operational emissions, including vehicular and fixed -source emissions. As shown, total operational emissions of the project would be below the SDAPCD screening thresholds for all criteria pollutants in both summer and winter. Therefore, operation - related impacts would not violate any air quality standard and would be less than significant.

Table 3.2-7. Operational Emissions (lbs/day)
ROG NOx CO SOx PM10 PM2.5
Summer Scenario
Area Source 4.13 0.14 12.45 0.00 0.07 0.07
Energy Use 0.06 0.51 0.22 0.00 0.04 0.04
Mobile Emissions 2.71 2.29 20.38 0.04 4.47 1.21
Total 6.90 2.95 33.05 0.05 4.58 1.32
Screening Level Threshold 75 250 550 250 100 55
Above threshold? No No No No No No
Winter Scenario
Area Source 4.13 0.14 12.45 0.00 0.07 0.07
Energy Use 0.06 0.51 0.22 0.00 0.04 0.04
Mobile Emissions 2.61 2.49 21.41 0.04 4.47 1.21
Total 6.80 3.15 34.08 0.04 4.58 1.32
Screening Level Threshold 75 250 550 250 100 55
Above Threshold? No No No No No No
Source: LDN Consulting 2021a.

Notes: Daily pollutant generation assumes trip distances within CalEEMod Threshold #3: Expose sensitive receptors to substantial pollutant concentrations Sensitive receptors are defined as schools, hospitals, resident care facilities, or day -care centers, as well as residential receptors in the project vicinity. The nearest sensitive receptors are the existing residences to the east of the pr oject site. The threshold related to sensitive receptors addresses whether the project could expose sensitive receptors to substantial pollutant concentrations of criteria pollutants or TACs.

As identified above, if a project has the potential to result in emissions of any TAC that results in a cancer risk of greater than 10 in 1 million or substantial non -cancer risk, the project would be deemed to have a potentially significant impact.

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To address the potential for emissions of construction -related TAC emissions to result in exposure of sensitive receptors to substantial pollutant concentrations, a screening health risk assessment was conducted for construction emissions. The risk -driving toxic air contaminant that would be emitted during construction would be diesel particulate matter.

Risks were calculated based on the Office of Environmental Health Hazards Assessment update guidance (OEHHA 2015). Cancer risk is calculated by multiplying the daily inhalation or oral dose, by a cancer potency factor, the age sensitivity factor, the frequency of time spent at home, and the exposure duration divided by averaging time, to yield the excess cancer risk. Based upon the air quality modeling, worst -case onsite PM 10 from onsite construction exhaust would cum ulatively produce 0.0086 tons over the construction duration (503 calendar days) or an average of 4.36x10 -9 grams/second.

Utilizing these figures and based on the AERSCREEN dispersion model, the maximum 1 -hr concentration is 0.016 µg/m3 during the worst -case construction period. The annual concentration is 0.0123 µg/m 3. Therefore, the inhalation cancer risk is 3.10 at the point of maximum exposure 125 meters (410 feet) away. As a condition of project approval, the project would be required to utilize Tier 4 diesel equipment. Since the threshold is 10 per million exposed with T -BACT installed, the project would have a less than significant impact and would be in compliance with the City’s thresholds. It should be noted that sensitive residential receptors are adjacent to the project site.

Since the maximum risk is 3.10 per million exposed (and the threshold is 10 per million), all sensitive receptors would have cancer risks at or less than 3.10 per million exposed which would also represent a less than signifi cant impact. Therefore, toxic air contaminant impacts associated with the project would be
less than significant.

Threshold #4: Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Construction
Construction activities associated with development of the project site could generate trace amounts of substances such as ammonia, carbon dioxide, hydrogen sulfide, methane, dust, organic dust, and endotoxins. Any generation of odors related to these substanc es would occur intermittently during construction. Construction activities may also generate odors associated with diesel equipment at various locations. Odors would be strongest at the source and would quickly dissipate. The buffer between the project sit e and nearby residences, combined with the short term and intermittent duration of any odor emissions, would ensure construction-related impacts are less than significant.

Operation
Future development on the project site includes multi- family residences. T his type of use is not typically characterized as one that would generate odors, compared to uses such as industrial and manufacturing. Therefore, odor -related impacts from future uses on the project site are determined to be less than significant.

3.2.5 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 adequa te 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,

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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 air quality, the cumulative a nalysis is based upon a summary of projections contained in an adopted local, regional, or statewide plan, or a related planning document air quality.

As part of the RAQS and SIP planning process, the SDAPCD develops an emission inventory, based on growth projections from SANDAG and existing emissions figures within the SDAB. The SDAPCD then uses the emission inventory to conduct modeling to demonstrate that the SDAB will attain and maintain the state and federal O
3 standards. This inventory could be though t of as an “emissions budget” for the SDAB, accounting for current emissions as well as previously approved projects consistent with current General Plan policies.

Projects that are consistent with the currently adopted General Plan are determined to be consistent with SDAB’s air quality plans, including the RAQS and the SIP. If a project proposes development that is consistent with or less than estimates provided in the General Plan, the project would not conflict with or obstruct implementation of the RAQ S or SIP. Provided a project’s emissions are consistent with the projections within the RAQS and SIP, the project would not result in a cumulatively considerable impact on O
3 within the SDAB.

Currently, the project site has a General Plan Land Use designat ion of Mixed Use 3 (MU3), which is a mixed- use non-residential designation with a maximum FAR of 1.50 . The project includes a General Plan amendment to change the existing MU3 designation to Specific Plan Area (SPA). The proposed project seeks to construct 151 multi -family residential units. The existing site would allow for up to 275,000 s.f. of office use and approximately 18,000 s.f. of commercial (retail) use and would generate up to four times more traffic than the proposed residential uses.

Since the largest component of air quality emissions are typically derived from vehicular trips, the site would be considered less intense. Therefore, the project’s development intensity and density will decrease from its current General Plan designation. The proje ct is therefore considered consistent with the County’s RAQS and would comply with the state’s SIP. Cumulative impacts would be less than significant.

3.2.6 Mitigation Measures
Based upon the analysis presented in Sections 3.2.4 and 3.2.5, project and cumulative air quality impacts would be less than significant. Therefore, no mitigation measures are necessary.

3.2.7 Conclusion
Implementation of the proposed project would not violate any air quality standard or contribute substantially to an existing or projected air quality violation during construction or operation, nor would the project conflict with or obstruct implementation of the RAQS or SIP. Additionally, due to the nature of the project, sensitive receptors would not be exposed to substantial pol lutant concentrations nor would a substantial number of people be exposed to objectionable odors.

Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 3.3-1

3.3 Biological Resources
Introduction
This section provides a biological resources impact analysis for the proposed project. The analysis in this section is based upon the following reports prepared by Rocks Biological Consulting (RBC) • Barham Drive Residential Project Biological Technical Report . Prepared by Rocks Biological Consulting, October 27, 2020. (RBC 2020a)
• 45 Day Repor t for Coastal California Gnatcatcher Surveys for the Barham Drive Residential Project, City of San Marcos, San Diego County, California. Prepared by Rocks Biological Consulting, July 16, 2020. (RBC 2020b)
• Special-Status Plant Survey Results for the Barham Drive Residential Project, San Marcos, California. Prepared by Rocks Biological Consulting, June 17, 2020 (RBC 2020c). • Jurisdictional Findings for 943 Barham Drive Project Site, San Marcos. Prepared by Helix Environmental Planning. May 27, 2020.

These reports are included as Appendices E.1, E.2, E3 and E.4. of this Environmental Impact Report (EIR).

Table 3.3 -1 summarizes the project - and cumulative -level impact analysis by threshold for the proposed project.

Table 3.3-1. Biological Resources Summary of Impacts
Threshold of Significance Project Direct
Impact
Project Cumulative
Impact
Impact After
Mitigation
#1: Have a substantial adverse
effect either directly or through
habitat modifications, on any
species identified as a candidate,
sensitive or special status species
in local or regional plans, policies,
or regulations or by the California
Department of Fish and Wildlife or
U.S. Fish and Wildlife Service.

Significant Impact Less than
Significant
Mitigated to Less
Than Significant
#2: Have a substantial adverse
effect on any riparian habitat or
other sensitive natural community
identified in local or regional plans,
policies, regulations or by the
California Department of Fish and
Wildlife or the U.S. Fish and
Wildlife Service.

Significant Impact Less than
Significant
Mitigated to Less
Than Significant

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Threshold of Significance Project Direct
Impact
Project Cumulative
Impact
Impact After
Mitigation
#3: Have a substantial adverse
effect on state or federally
protected wetlands (including but
not limited to marsh, vernal pool,
coastal, etc.) through direct
removal, filling, hydrologic
interruption, or other means.

Less than
Significant
Less than
Significant
Less than
Significant
#4: Interfere substantially with the
movement of any native resident
or migratory fish or wildlife species
or with established native resident
or migratory wildlife corridors, or
impede the use of native wildlife
nursery site.

Less than
Significant
Less than
Significant
Less than
Significant
#5: Conflict with any local policies
or ordinances protecting biological
resources, such as tree
preservation policy or ordinance.

Less than
Significant
Less than
Significant
Less than
Significant
#6: Conflict with the provisions of
an adopted Habitat Conservation
Plan, Natural Community
Conservation Plan, or other
approved local, regional, or state
habitat conservation plan.

Less than
Significant
Less than
Significant
Less than
Significant

3.3.1 Existing Conditions
The 10.56-acre 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. The site has a north -aspect slope with elevations of approximately 650 to 710 feet above mean sea level (AMSL). The site occurs within a relatively developed area, with residential development to the east and west of the site. The northern project boundary borders East Barham Drive, and the southern project boundary borders undeveloped lands that support Diegan coastal sage scrub and chaparral habitat.

The majority of the project site supports non -native grassland, with Diegan coastal sage scrub habitat occurring a long the southern project site boundary ( Figure 3.3-1). A smaller area of Diegan coastal sage scrub – Baccharis dominated habitat occurs along the eastern project boundary, and disturbed land and ornamental vegetation occur scattered throughout the non -native grassland across the majority of the site. Developed, ruderal, and ornamental land border the north, east, and west project boundaries. Site photographs are presented in Appendix A of the Biological Technical Report included in Appendix E.1 of this EIR.

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Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 3.3-3
Vegetation Mapping and Biological Surveys
To locate and characterize natural vegetation communities, including habitats for special -status species, within the project area, RBC conducted a field survey in March 2020, including a general biological survey, vegetation mapping, general habitat assessment for special -status specie, and a reconnaissance-level aquatic resource assessment of potential local, state, and/or federal jurisdictional wetland and/or non -wetland waters of the U.S./State . Helix prepared a jurisdictional assessment in April 2020 (Helix 2020) to identify potential areas that may be considered jurisdictional.

RBC biologists identified plant species using The Jepson Manual: Vascular Plants of California (Baldwin et al. 2012) and local botanical knowledge. The project site was traversed on foot and binoculars (10x42) were used to aid in field identification of wildlife species. Plant and wildlife species observed on the project site are presented in Appendix C. Vegetation was mapped directly on a 200 -scale (1”= 200’) aerial photograph following Holland’s Preliminary Descriptions of the Terrestrial Natural Communities of California (Holland 1986).

A 50 -foot survey buffer was included in vegetation mapping provided in the Biological Technical Report (RBC 2020a). Vegetation was identified in buffer areas via binoculars from the project site during the general biological survey. Buffer areas were included in the analysis in order to assess the potential for special -status species or resources in area s immediately adjacent the project site that could be impacted by the project.

Rare Plant Surveys
RBC biologists conducted special -status plant surveys for the project site in Spring 2020 (RBC 2020c). Two on -site surveys were performed to maximize detection of spring annual and bulb species, one on May 6, 2020 and a second on May 20, 2020. In addition, reference populations of both San Diego thornmint ( Acanthomintha ilicifolia ; federally threatened, state endangered, CRPR 1B.1) and thread -leaved brodiaea ( Brodiaea filifolia; federally threatened, state endangered, CRPR 1B.1) were visited to ensure proper survey timing as both of these species have a narrow window of observation.

Focal species for the rare plant surveys were San Diego thornmint, thread -leaved brodiaea, spreading navarretia (Navarretia fossalis; federally threatened, CRPR 1B.1), San Diego button celery (Eryngium aristulatum var. parishii ; federally endangered, state endangered, CRPR 1B.1), Del Mar manzanita (Arctostaphylos glandulosa ssp. crassifolia ; federally endangered, CRPR 1B.1) and wart - stemmed ceanothus ( Ceanothus verrucosus; CRPR 2B.2); however, all plant species on site were identified during surveys, and other special -status plant species would have likely been incidentally observed, if present.

Surveys were conducted in accordance with Protocols for Surveying and Evaluating Impacts on Special Status Plant Populations and Natural Communities. Biologists walked transects throughout the project site and survey buffer and were prepared to map special -status plant occurrences using handheld ArcGIS Collector. During surveys all vascular plant species on the site were identified to species, subspecies, or varietal level.

Coastal California Gnatcatcher Surveys
RBC biologists conducted six breed ing season coastal California gnatcatcher surveys from May 13, 2020 through June 17, 2020 (RBC 2020b). Survey methods followed the United States Fish and

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Wildlife Service (USFWS) presence/absence breeding season protocol (USFWS 1997) for area that are not within Natural Community Conservation Planning (NCCP) areas. RBC surveyed all suitable coastal California gnatcatcher habitat within the project site and a 300 -foot buffer using taped vocalizations to elicit a response from coastal California gnatcatcher.

Vegetation Communities
The following vegetation communities were identified and mapped during a general biological survey conducted in March 2020.

Figure 3.3 -1 shows the geographical extent of the vegetation communities.

Developed
Developed lands within th e project site (0.40 acre) support no native vegetation and are comprised of paved roads. Developed lands occur along the northern site boundary, in the form of East Barham Drive.

Diegan Coastal Sage Scrub
Diegan coastal sage scrub habitat within the proje ct site (0.62 acre) occurs along the southern project site boundary and is dominated by coast monkey flower ( Diplacus puniceus ), black sage (Salvia mellifera ), coastal sagebrush ( Artemisia californica ), and laurel sumac ( Malosma laurina).

This vegetation community is a form of coastal sage scrub comprised of low, soft - woody subshrubs to about one meter (three feet) high, many of which are facultatively drought- deciduous.

Diegan Coastal Sage Scrub - Baccharis Dominated
Diegan coastal sage scrub – Baccharis dominated habitat within the project site (0.03 acre) occurs along the eastern project boundary and contains coyote brush ( Baccharis pilularis ssp. consanguinea). This vegetation community is a form of Diegan coastal sage scrub comprised of low, soft-woody subshrubs to about one meter high, containing more than 50% cover of one or more Baccharis species.

Disturbed Habitat
Disturbed lands within the project site (0.17 acre) support bare ground or sparse non -native plant species that have been established th rough human disturbance. Disturbed lands on the project site consist of small patches of human-disturbed land.

Non-Native Grassland
Non-native grassland supports greater than 50 percent cover of non -native grasses. Non -native grassland vegetation within the project site (9.50 acres) largely occurs in the middle of the site and consists of non -native grasses such as ripgut grass ( Bromus diandrus ), slender wild oat ( Avena barbata), and glaucous barley (Hordeum murinum ssp. glaucum).

Ornamental
Ornamental plantings are comprised of exotic trees and other ornamental vegetation. The ornamental area within the project site (0.22 acre) includes pepper trees ( Schinus spp.), Mexican fan palm (Washingtonia robusta), and China berry (Melia azedarach).

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Ruderal
Ruderal areas support vegetation capable of tolerating some form of disturbance. This disturbed community within the project site (<0.01 acre) is dominated by broad-leaf herbaceous species with a less than 50 percent cover of non -native grasses. Ruderal ve getation occurs in the center of the project site and primarily consists of black mustard ( Brassica nigra), tocalote (Centaurea melitensis), and filaree/storksbill (Erodium spp.).

Sensitive Vegetation Communities
Vegetation communities (habitats) are gener ally considered “sensitive” if: (a) they are considered rare within the region by agencies such as U.S. Fish and Wildlife Service (USFWS), California Department of Fish and Wildlife (CDFW), and other local regulatory agencies; (b) if they are known to support sensitive animal or plant species; and/or (c) they are known to serve as important wildlife corridors. Sensitive habitats are typically depleted throughout their known ranges, or are highly localized and/or fragmented.

Developed, disturbed ornamental and ruderal vegetation communities are not considered by the City of San Marcos as sensitive habitat types in the City’s Draft Subarea Plan. Non -native grasslands, Diegan coastal sage scrub, and Diegan coastal sage scrub – Baccharis dominated are considered to be sensitive habitat types.

Wildlife Species
Wildlife species observed during the field survey are presented in Appendix C of the Biological Technical Report (Appendix E.1 of this EIR), and a full assessment of special -status wildlife species’ potential to occur on the project sites is provided in Table 3.3 -2. Focused 2020 breeding season coastal California gnatcatcher surveys for the project were negative. No additional federally or state - listed species have a moderate or high potential to occur on the project site. One CDFW Watch List species, Coope r’s hawk, was observed flying over the site during the project biological survey. No additional CDFW Watch List species are anticipated to have a moderate or high potential to occur on the project site.

Table 3.3-2. Wildlife Species Potential for Occurrence
Species Status Habitat Potential to Occur
Reptiles
Western
spadefoot (Spea
hammondii)
SSC Found in grassland and
occasionally woodland
habitats. Species requires
ponds to breed.

Low potential to occur. Although the site
supports potential mesic habitat, this
habitat is not capable of supporting
breeding populations of western
spadefoot.

Birds
Coastal
California
gnatcatcher
(Polioptila
californica
FT, SSC Found in coastal sage
scrub habitats including
Diegan coastal sage
scrub, often dominated by
California buckwheat
Low potential to occur. Although suitable
Diegan coastal sage scrub is present on
site, the habitat is limited, and focused
2020 breeding-season coastal California
gnatcatcher surveys for the project were

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Species Status Habitat Potential to Occur
californica) (Eriogonum fasciculatum)
and California sagebrush
(Artemisia californica).
negative.

Cooper’s hawk
(Accipiter
cooperii)
WL
(Nesting)
Found in a variety of
habitats including
woodlands, shrublands,
and urban areas. Nests in
woodlands, often near
rivers and streams.

Present. Species observed flying over the
project site during spring 2020 surveys.

Species has a low potential to nest on the
project site however due to lack of
suitable nesting trees.

Tricolored
blackbird
(Agelaius
tricolor)

ST, SSC
(Nesting
colony)
Breeds within dense
aquatic vegetation
bordering freshwater
aquatic habitats including
marshes, swamps, lakes,
and ponds. This species is
often found near
agricultural areas.

Not anticipated to occur. Suitable marsh,
swamp, lake, and pond aquatic habitats
are not present on site.

Mammals
Townsend's big-
eared bat
(Corynorhinus
townsendii)
SSC Roosts in mines, caves,
tunnels, and abandoned
buildings. Forages in a
variety of habitats
including coastal sage
scrub and arid scrub
habitats.

Not anticipated to occur. Suitable habitats
containing cavity roosts are not present
on site.

FT: Endangered Species Act (ESA) Federally Threatened Species ST: California Endangered Species Act (CESA) State Threatened Species SSC: California Department of Fish and Wildlife (CDFW) Species of Special Concern WL: California Department of Fish and Wildlife (CDFW) Watch List species Source: RBC 2020a
Avian Species
Coastal California Gnatcatcher (Polioptila californica californica) The coastal California gnatcatcher is federally listed as threatened and is considered a California Species of Special Concern. This species is a year -round resident of southern California and is found in the six southernmost California counties located within the coastal plain (San Bernardino, Ventura, Los Angeles, Orange, San Diego, and Riverside). The primary cause of this species’ decline is conversion of coastal sage scrub vegetation to urban and agricultural uses. USFWS has estimated that coastal sage scrub habitat has been reduced by 70 to 90 percent of its historical extent. Coastal California gnatcatcher generally inhabit coastal sage scrub habitats such as California buckwheat scrub dominated by California sagebrush and flat -topped buckwheat, gener ally below 1,500 feet in elevation along the coastal slope. When nesting, this species typically avoids slopes greater than 25% with dense, tall vegetation. Gnatcatcher pairs will attempt several nests each year (average of

3.3 Biological Resources
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4), each placed in a different l ocation inside their breeding territory, but most nest attempts are unsuccessful because of depredation by a variety of species. Clutch size ranges from one to 5 eggs, with 3 or 4 eggs most common. Males and females will remain paired through the non -breeding season and will often expand their home range when not breeding. This species is particularly vulnerable to habitat destruction and fragmentation because of their low dispersal rate, reliance on a specific habitat type, and low breeding success. Coasta l California gnatcatcher has been described as “an obligate resident of coastal sage scrub,” a vegetation community that is vulnerable to urban pressures. The destruction of coastal sage scrub by wildfire also has a detrimental effect on local populations. This species also inhabits chaparral vegetation where adjacent to coastal sage scrub (RBC 2020a).

This species has been reported within one mile of the project site, with one report occurring approximately 0.15 mile west of the project site (RBC 2020a). T his historical sighting is from 1997 and the area where the sighting occurred has been developed into a residential development, likely fragmenting gnatcatcher populations. Suitable gnatcatcher Diegan coastal sage scrub habitat occurs along the southern pr oject boundary. However, this habitat is surrounded by residential developments and lacks connectivity to larger expanses of habitat. Focused 2020 breeding season coastal California gnatcatcher surveys for the project were negative (RBC 2020b).

Cooper’s Hawk (Accipiter cooperii)
Cooper’s hawk is a CDFW Watch List species when nesting. This species is found across a variety of habitats, including coastal sage scrub, riparian woodlands, and urban areas. Cooper’s hawk feed on small bird species and require large trees to nest. This species often nests in riparian woodlands and will occasionally nest in large ornamental trees.

Cooper’s hawk was observed flying over the project site during the 2020 general biological survey (RBC 2020a). Although Cooper’s hawk may use the project site as a hunting territory, suitable nesting habitat containing large trees is not present. As such, Cooper’s hawk is not anticipated to nest within the project site.

Plant Species
RBC conducted special -status plant surveys for the projec t site in Spring 2020 . No special -status plant species were documented on the project site during the general biological survey or during focused rare plant surveys, and none have a moderate or high potential to occur on the project site due to absence of suitable habitat and soils (RBC 2020c). Plant species observed during the field survey are presented in Appendix C of the Biological Technical Report (Appendix E.3 of this EIR), and an assessment of the potential for special -status plant species to occur o n-site is provided in Table

3.3-3.

Table 3.3-3. Plant Species Potential for Occurrence
Species Status Habitat Potential to Occur*
Beach
goldenaster
(Heterotheca
sessiliflora ssp.
sessiliflora)
CRPR
1B.1
Perennial herb. Blooms
March-December.

Chaparral (coastal),
coastal dunes, coastal
scrub. Elev. 0-4,020 ft.

Not anticipated to occur. While the project
site and survey buffer are within the
elevational range, and supports Diegan
coastal sage scrub habitat, the species is
typically found in coastal locations.

Additionally, there are no inland

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Species Status Habitat Potential to Occur*
collections of this species in San Marcos.

California
adolphia
(Adolphia
californica)
CRPR
2B.1
Perennial deciduous
shrub. Blooms December-
May.

Chaparral, coastal scrub,
valley and foothill
grassland. Elev. 30-2,430
ft.

Low potential to occur. The project site
and survey buffer are within the
elevational range, and supports Diegan
coastal sage scrub habitats. However, this
species would have likely been observed
if present.

Coulter's
goldfields
(Lasthenia
glabrata ssp.
coulteri)
CRPR
1B.1
Annual herb. Blooms
February-June. Coastal
salt marshes and swamps,
playas, vernal pools. Elev.
3- 4,002 ft.

Low potential to occur. The site does not
support coastal salt marshes or swamps,
but supports potential vernal pool
habitats that could contain the species.

Coulter's
saltbush (Atriplex
coulteri)
CRPR
1B.2
Perennial herb. Blooms
March-October. Coastal
bluff scrub, coastal dunes,
coastal scrub, valley and
foothill grassland. Elev. 5-
1,510 ft.

Low potential to occur. This species is
typically found coastally or in the southern
part of the county where it is found inland
as well. This species would have likely
been observed if present.

Decumbent
goldenbush
(Isocoma
menziesii var.
decumbens)
CRPR
1B.2
Perennial shrub. Blooms
April-November.

Chaparral, coastal scrub
(sandy, often in disturbed
areas). Elev. 30- 455 ft.

Low potential to occur. The site supports
sandy soils, disturbed areas, and Diegan
coastal sage scrub.

Del Mar
manzanita
(Arctostaphylos
glandulosa ssp.
crassifolia)
FE,
CRPR
1B.1
Perennial evergreen
shrub. Blooms December-
July.

Chaparral (maritime,
sandy). Elev. 0-1,200 ft.

Low potential to occur. Species is typically
found coastally in maritime chaparral,
which doesn’t not occur within survey
area.

Delicate clarkia
(Clarkia delicata)
CRPR
1B.2
Annual herb. Blooms April-
June. Often gabbroic soils
within chaparral,
cismontane woodland.

Elev. 770-3,280 ft.

Not anticipated to occur. The project site
and survey buffer are within the
elevational range; however, the site does
not support gabbroic soils within habitat
on site.

Dunn's mariposa
lily
(Calochortus
dunnii)
SR,
CRPR
1B.2
Perennial bulbiferous
herb. Bloom (February)
April-June. Gabbroic or
metavolcanics, rocky soils
within closed- cone
coniferous forest,
chaparral, valley and
foothill grassland. Elev.
605-6,500 ft.

Low potential to occur. While the project
site and survey buffer are within the
elevational range and supports grassland
habitat, gabbroic soils needed for this
species are not found on site. In addition,
there are no nearby collections of this
species.

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Species Status Habitat Potential to Occur*
Encinitas
Baccharis
(Baccharis
vanessae)

FT, SE,
CRPR
1B.1
Perennial deciduous
shrub. Blooms (August)
October- November.

Sandstone soils within
chaparral (maritime) and
cismontane woodland.

Elev. 196-2,363 ft.

Not anticipated to occur. The project site
and survey buffer are within the
elevational range; however, the site does
not support chaparral habitat suitable for
the species. Would have been observed if
present.

Felt-leaved
monardella
(Monardella
hypoleuca ssp.
lanata)
CRPR
1B.2
Perennial rhizomatous
herb. Blooms June-August.

Rocky, granitic slopes or
hilltops in chaparral,
cismontane woodland.

Elev. 980-5,165 ft.

Not anticipated to occur. The project site
and survey buffer are within the
elevational range; however, the site does
not support suitable soils or habitats for
this species.

Munz's sage
(Salvia munzii)
CRPR
2B.2
Perennial evergreen
shrub. Blooms February-
April.

Chaparral, coastal scrub.

Elev. 375-3,495 ft.

Low potential to occur. While the project
site and survey buffer are within the
elevational range and supports Diegan
coastal sage scrub habitat, the species is
known only from the southern part of the
County.

Nuttall’s scrub
oak (Quercus
dumosa)
CRPR
1B.1
Perennial evergreen
shrub. Blooms February-
April (May- August). Sandy,
clay loam soils within
closed-cone coniferous
forest, chaparral, and
coastal scrub. Elev. 49-
1,313 ft.

Low potential to occur. The project site
and survey buffer are within the
elevational range, and supports sandy
loam soils and Diegan coastal sage scrub
habitat; however, species would have
likely been observed if present.

Orcutt’s brodiaea
(Brodiaea
orcuttii)
CRPR
1B.1
Perennial bulbiferous
herb. Blooms May-July.

Mesic, clay soils within
closed-cone coniferous
forest, chaparral,
cismontane woodland,
meadows and seeps,
valley and foothill
grassland, and vernal
pools. Elev. 98-5,552 ft.

Low potential to occur. The site does not
support clay soils, coniferous forest,
chaparral, or cismontane woodland, but
supports potential vernal pool habitats
that could contain the species.

Palmer's
goldenbush
(Ericameria
palmeri var.
palmeri)
CRPR
1B.1
Perennial evergreen
shrub. Blooms (July)
September- October.

Chaparral, coastal scrub.

Elev. 95-1,970 ft.

Low potential to occur. While the project
site and survey buffer support Diegan
coastal sage scrub habitat, this species is
typically found in the southern part of the
County.

Parish's
brittlescale
(Atriplex parishii)
CRPR
1B.1
Annual herb. Blooms June-
October. Alkaline habitats
including chenopod scrub,
Low potential to occur. The site does not
support chenopod scrub or playas, but
supports potential mesic habitats that

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Species Status Habitat Potential to Occur*
playas, and vernal pools.

Elev. 80-6,235 ft.
have a minor potential to support the
species. However, this species would
have likely been observed if present.

Parry's
tetracoccus
(Tetracoccus
dioicus)
CRPR
1B.2
Perennial deciduous
shrub. Blooms April-May.

Gabbroic soil in chaparral,
coastal scrub. Elev. 540-
3,280 ft.

Not anticipated to occur. While the project
site and survey buffer are within the
elevational range and supports Diegan
coastal sage scrub habitat, it does not
contain gabbroic (Las Posas) soils that
support this species.

Rainbow
manzanita
(Arctostaphylos
rainbowensis)
CRPR
1B.1
Perennial evergreen
shrub. Blooms December-
March. Chaparral. Elev.
670-2,200 ft.

Low potential to occur. The site does not
support suitable chaparral habitat for this
species.

Ramona horkelia
(Horkelia
truncata)
CRPR
1B.3
Perennial herb. Blooms
May- June. Clay, gabbroic
soils within chaparral and
cismontane woodland.

Elev. 1,310-4,265 ft.

Not anticipated to occur. The site does
not support clay or gabbroic soils within
chaparral and cismontane woodland
habitats.

San Diego
ambrosia
(Ambrosia
pumila)
FE,
CRPR
1B.1
Perennial rhizomatous
herb. Blooms April-
October. Found in sandy
loam or clay soils in
chaparral, coastal scrub,
valley and foothill
grassland, and vernal
pools. Elev. 65- 1,360 ft.

Low potential to occur. The site does not
support chaparral, but supports sandy
loam soils and potential mesic habitats
that have a minor potential to support the
species. This species would have likely
been observed if present.

San Diego barrel
cactus
(Ferocactus
viridescens)
CRPR
2B.1
Perennial stem succulent.

Blooms May-June. Found
on chaparral, coastal
scrub, valley and foothill
grassland, and vernal
pools. Elev. 5- 1,475 ft.

Low potential to occur. While the project
site and survey buffer are within the
elevational range and contains Diegan
coastal sage scrub habitat, the species is
not known from the vicinity. Would have
likely been observed if present.

San Diego
button- celery
(Eryngium
aristulatum var.
parishii)

FE, SE,
CRPR
1B.1
Annual/perennial herb.

Blooms April-June. Mesic
habitats in coastal scrub,
valley and foothill
grassland, and vernal
pools. Elev. 65- 2,035 ft.

Low potential to occur. The site supports
mesic habitats that have a minor
potential to support the species; however,
this species would have likely been
observed if present.

San Diego
goldenstar
(Bloomeria
clevelandii)
CRPR
1B.1
Perennial bulbiferous
herb. Blooms April-May.

Occurs on clay soils in
chaparral, coastal scrub,
valley and foothill
grassland, and vernal
Low potential to occur. Site does not have
suitable clay soils to support this species.

Would have likely been observed if
present.

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Species Status Habitat Potential to Occur*
pools. Elev. 164-1,525 ft.

San Diego
marsh- elder
(Iva hayesiana)
CRPR
2B.2
Perennial herb. Blooms
April- October. Occurs in
marshes, swamps, and
playas. Elev. 32-1,640 ft.

Not anticipated to occur. Site does not
support marshes, swamps, or playas.

San Diego mesa
mint
(Pogogyne
abramsii)

FE, SE,
CRPR
1B.1
Annual herb. Blooms
March- July. Vernal pools.

Elev. 295- 655 ft.

Low potential to occur. The site supports
potential mesic habitats that have a
minor potential to support the species;
however, would have likely been observed
if present.

San Diego thorn-
mint
(Acanthomintha
ilicifolia)

FT, SE,
CRPR
1B.1
Annual herb. Blooms April-
June. Clay, openings
within chaparral, coastal
scrub, valley and foothill
grassland, vernal pools.

Elev. 30-3,150 ft.

Low potential to occur. Site does not have
suitable clay soils to support this species
and species was not observed during
focused surveys.

Smooth tarplant
(Centromadia
pungens ssp.
laevis)
CRPR
1B.1
Annual herb. Blooms April-
September. Chenopod
scrub, meadows and
seeps, playas, riparian
woodland, and valley and
foothill grassland. Elev. 0-
2,100 ft.

Low potential to occur. The site does not
support chenopod scrub, meadows and
seeps, playas, or riparian woodland, but
supports grassland habitat that has minor
potential to support the species; however,
would have likely been observed if
present.

Southern
tarplant
(Centromadia
parryi ssp.
australis)
CRPR
1B.1
Annual herb. Blooms May-
November. Marshes and
swamps (margins), valley
and foothill grassland
(vernally mesic), vernal
pools. Elev. 0- 1,575 ft.

Low potential to occur. The site supports
grassland habitat and potential mesic
habitat that has a minor potential to
support the species; however, would have
likely been observed if present.

Spreading
navarretia
(Navarretia
fossalis)
FT,
CRPR
1B.1
Annual herb. Blooms April-
June. Chenopod scrub,
marshes, and swamps
(assorted shallow
freshwater), playas, vernal
pools. Elev. 95-2,150 ft.

Low potential to occur. The site supports
grassland habitat and potential mesic
habitat that has a minor potential to
support the species; however, would have
likely been observed if present.

Sticky dudleya
(Dudleya viscida)
CRPR
1B.2
Perennial herb. Blooms
May- June. Coastal bluff
scrub, chaparral,
cismontane woodland,
coastal scrub. Elev. 30-
1,805 ft.

Low potential to occur. The project site
and survey buffer are within the
elevational range and supports Diegan
coastal sage scrub. However, this species
would have likely been observed if
present.

Summer holly
(Comarostaphylis
diversifolia ssp.

CRPR
1B.2
Perennial evergreen
shrub. Blooms April-June.

Chaparral, cismontane
Not anticipated to occur. Site does not
support chaparral or cismontane
woodland.

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Species Status Habitat Potential to Occur*
diversifolia) woodland. Elev. 98-2,592
ft.

Thread-leaved
brodiaea
(Brodiaea
filifolia)

FT, SE,
CRPR
1B.1
Perennial bulbiferous
herb. Blooms March-June.

Found in often clay soils in
chaparral (openings),
cismontane woodland,
coastal scrub, playas,
valley and foothill
grassland, vernal pools.

Elev. 80-3,675 ft.

Low potential to occur. While the site
supports Diegan coastal sage scrub
habitat and the species is known from the
nearby vicinity, appropriate clay soils do
not occur on site. Species was not
observed during focused surveys.

Variegated
dudleya
(Dudleya
variegata)
CRPR
1B.2
Perennial herb. Blooms
April-June. Chaparral,
cismontane woodland,
coastal scrub, valley and
foothill grassland, vernal
pools. Elev. 5-1,905 ft.

Low potential to occur. The site supports
grassland habitat and potential mesic
habitat that has a minor potential to
support the species; however, species
would have likely been observed if
present.

Wart-stemmed
ceanothus
(Ceanothus
verrucosus)
CRPR
2B.2
Perennial evergreen
shrub. Blooms December-
May. Chaparral. Elev. 3-
1,247 ft.

Not anticipated to occur. Site does not
support suitable chaparral habitat.

Source: RBC 2020a
*: Sensitive plants were not observed during 2020 Focused Rare Plant Surveys California Rare Plant Rank (CRPR)
1A: presumed extirpated in California and rare or extinct elsewhere 1B: rare, threatened, or endangered in California and elsewhere 2A: presumed extirpated in California but more common elsewhere 2B: rare, threatened, or endangered in California but more common elsewhere 3: plants for which more information needed
4: plants of limited distribution
CRPR Threat Ranks

0.1: Seriously threatened in California (over 80% of occurrences threatened / high degree and immediacy of threat) 0.2:

Moderately threatened in California (20-80% occurrences threatened / moderate degree and immediacy of threat) 0.3:

Not very threatened in California (<20% of occurrences threatened / low degree and immediacy of threat or no current threats known)
FE: Endangered Species Act (ESA) Federally Endangered Species FT: Endangered Species Act (ESA) Federally Threatened Species
SE: California Endangered Species Act (CESA) State Endangered Species ST: California Endangered Species Act (CESA) State Threatened Species SR: California Endangered Species Act (CESA) State Rare Species

Potential Federal and State Jurisdictional Aquatic Resources RBC documented curly dock ( Rumex crispus), a wetland indicator species with a facultative (FAC) rating within a low -lying area in the center of the site during the general biological survey conducted on March 11, 2020 (RBC 2020a). In addition, RBC documented two plant species commonly associated with depressional areas confined by clay soils, coastal plantain ( Plantago elongata ; FACW) and slender woolly marbles ( Psilocarphus tenellus; OBL), within another low -lying area in t he

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southern portion of the site (RBC 2020a). No defined bed or bank or other regular flow indicators were observed during the initial aquatic resources assessment; thus, no potential non -wetland waters of the U.S./State or CDFW streambed were observed on site.

These two areas were further investigated by Helix on April 24, 2020 to determine their anticipated jurisdictional status per United States Army Corps of Engineers (USACE), Regional Water Quality Control Board (RWQCB), or CDFW regulations and protocol s. Helix staff took four wetland delineation sampling points within and near the two areas noted during RBC’s initial aquatic resources assessment. None of the four sampling points met the required federal - or state -jurisdictional wetland parameters per He lix’s findings. As such, HELIX concluded that the on -site low-lying areas are not expected to be jurisdictional under the USACE, RWQCB, or CDFW (Helix 2020).

Wildlife Corridors and Habitat Linkages
A wildlife corridor can be defined as a physical feature t hat links wildlife habitat, often consisting of native vegetation that joins two or more larger areas of similar wildlife habitat. Corridors enable migration, colonization, and genetic diversity through interbreeding and are therefore critical for the movement of animals and the continuation of viable populations. Corridors can consist of large, linear stretches of connected habitat (such as riparian vegetation) or as a sequence of steppingstones across the landscape (discontinuous areas of habitat such as wetlands and ornamental vegetation), or corridors can be larger habitat areas with known or likely importance to local fauna.

Regional corridors are defined as those linking two or more large patches of habitat, and local corridors are defined as those all owing resident animals to access critical resources (food, cover, and water) in a smaller area that might otherwise be isolated by urban development. A viable wildlife migration corridor consists of more than an unobstructed path between habitat areas. App ropriate vegetation communities must be present to provide food and cover for both transient species and resident populations of less mobile animals. There must also be a sufficient lack of stressors and threats within and adjacent to the corridor for species to use it successfully. According to Figure 4 -2 of the City’s General Plan, the project area does not occur within a local movement corridor (City of San Marcos 2012).

3.3.2 Regulatory Setting
Federal
United States Army Corps of Engineers – Clean Water Act Recognizing the potential for continued or accelerated degradation of the Nation's waters, the U.S.

Congress enacted the Clean Water Act (CWA), formerly known as the Federal Water Pollution Control Act (33 U.S.C. 1344). The objective of the CWA is to maintain and restore the chemical, physical, and biological integrity of the waters of the United States. Section 404 of the CWA authorizes the Secretary of the Army, acting through the Chief of Engineers, to issue permits for the discharge of dredged or fill material into the waters of the United States, including wetlands.

United States Fish and Wildlife Service – Endangered Species Act The USFWS is responsible for enforcing the federal Endangered Species Act (ESA), Migratory Bird Treaty Act, and Wildlife Coordination Act, and reviews and comments on applications for Section 404 CWA permits submitted to the USACE. If the proposed project is determined to have an adverse

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effect on a species that is federally listed as threatened or endangered, consultation with the USFWS would be required. If the proposed project may result in “take” of a federally listed species, an incidental take permit would be required. “Take” is defined in the ESA as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or colle ct, or attempt to engage in any such conduct.” The project site does not contain any areas mapped as “critical habitat,” as mapped by USFWS.

United States Fish and Wildlife Service – Migratory Bird Treaty Act The Migratory Bird Treaty Act (MBTA) (16 USC 70 3 et seq.) is a federal statute that implements treaties with several countries on the conservation and protection of migratory birds. The number of bird species covered by the MBTA is extensive and is listed in 50 CFR 10.13. The regulatory definition of “ migratory bird” is broad and includes any mutation or hybrid of a listed species and includes any part, egg, or nest of such bird (50 CFR 10.12). Migratory birds are not necessarily federally listed endangered or threatened birds under the ESA. The MBTA, w hich is enforced by USFWS, makes it unlawful “by any means or in any manner, to pursue, hunt, take, capture, [or] kill” any migratory bird or attempt such actions, except as permitted by regulation. The applicable regulations prohibit the take, possession, import, export, transport, sale, purchase, barter, or offering of these activities, except under a valid permit or as permitted in the implementing regulations (50 CFR 21.11).

State
California Department of Fish and Wildlife
The CDFW has the authority to reach an agreement with an agency or private party proposing to affect intermittent or permanent wetlands habitat, pursuant to Sections 1601-1616 of the State Fish and Game Code. Section 1602 of the State Fish and Game Code requires notification to CDFW pr ior to diversion of, obstruction of, use of material from, or deposition of materials in any river, stream, or lake. In accordance with its policy of “no net loss of wetland habitats,” the Department requires mitigation for all impacts to any wetlands, regardless of acreage.

California Endangered Species Act
The California ESA (California Fish and Game Code §2050, et seq.) generally parallels the main provisions of the Federal ESA and is administered by the CDFW. Its intent is to prohibit “take” and protect state listed endangered and threatened species of fish, wildlife, and plants. Unlike its federal counterpart, the California ESA also applies the take prohibitions to species petitioned for listing (state candidates).

Natural Community Conservation Planning
CDFW's NCCP program is an effort by the State of California, and numerous private and public partners, that takes a broad -based ecosystem approach to planning for the protection and perpetuation of biological diversity. An NCCP identifies and provides for the regional or areawide protection of plants, animals, and their habitats, while allowing compatible and appropriate economic activity.

Multiple Habitat Conservation Program (MHCP) - The MHCP is a comprehensive conservation planning process that addresses the needs of multiple plant and animal species in Northwestern San Diego County. The MHCP encompasses the cities of Carlsbad, Encinitas, Escondido, Oceanside, San Marcos, Solana Beach, and Vista. Its goal is to conserve approximately 19,000 acre s of habitat,

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of which roughly 8,800 acres (46 percent) are already in public ownership and contribute toward the habitat preserve system for the protection of more than 80 rare, threatened, or endangered species.

The City of San Marcos began preparing a d raft of the City Subarea Plan of the MHCP in December 1999 and although the City’s Draft Subarea Plan has not yet been approved by the USFWS and CDFW, the plan is a component of the adopted MHCP, and is currently being used as a guide for open space design and preservation within the City. The intent of the City’s Draft Subarea Plan is to identify a citywide preserve system that meets local and regional biological goals while minimizing fiscal and economic impacts to the City and adverse impacts on private property owners. To help achieve this goal, certain areas, known as focused planning areas (FPAs), have been designated with parcel-level preserve goals which would contribute to achieving local and regional conservation goals while minimizing adverse effects on property rights and property values.

The project site is located within the MHCP. However, the project site is not located within a FPA as defined in the MHCP and the City’s Draft Subarea Plan.

Local
San Marcos General Plan
The Conservation and Open Space Element of the City’s General Plan contains several policies pertaining to the protection of biological resources. The following goals and policies apply to the project:
• Goal COS -1: Identify, protect, and enhance significant ecological and biologica l resources within San Marcos and its adaptive Sphere of Influence. o Policy COS-1.1: Support the protection of biological resources through the establishment, restoration, and conservation of high quality habitat areas. o Policy COS -1.2: Ensure that new devel opment, including Capital Improvement Projects, maintain the biotic habitat value of riparian areas, oak woodlands, habitat linkages, and other sensitive biological habitats.
• Goal COS -2: The City is committed to conserving, protecting, and maintaining open space, agricultural, and limited resources for future generations. By working with property owners, local organizations, and state and federal agencies, the City can limit the conversion of resource lands to urban uses.
o Policy COS -2.1: Provide and protect open space areas throughout the City for its recreational, agricultural, safety, and environmental value. o Policy COS-2.2: Limit, to the extent feasible, the conversion of open space to urban uses and place a high priority on acquiring and preserving open space lands for recreation, habitat protection and enhancement, flood hazard management, water and agricultural resources protection, and overall community benefit.
o Policy COS -2.6: Preserve healthy mature trees where feasible; where removal is necessary, trees shall be replaced at a ratio of 1:1.

The project’s consistency with applicable General Plan goals and policies is discussed in Section

3.10, Land Use and Planning. As shown in Table 3.10 -5 in Section 3.10, the project is consistent with the applicable goals and policies.

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3.3.3 Thresholds of Significance
CEQA Guidelines define “significant effect on the environment” as a “substantial or potentially substantial adverse change in the environment.” CEQA Guidelines further indicate that there may be a significant effect on biological resources if the project would:
• Threshold #1: Have a substantial adverse effect either directly or through habitat modifications, on any species identified as a candidate, sensitive or special status species in local or regional plans , policies, or regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.
• Threshold #2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service. • Threshold #3: Have a substantial adverse effect on state or federally protected wetlands (including but not limited to marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrologic interruption, or other means.
• Threshold #4: Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery site.
• Threshold #5: Conflict with any local policies or ordinances protecting biological resources, such as tree preservation policy or ordinance.
• Threshold #6: Conflict with the provision s of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

3.3.4 Project Impact Analysis
Impacts resulting from implementation of the proposed project could include both direct and indirect biological resource impacts . Direct impacts refer to any alteration, disturbance, or destruction of biological resources caused by and occurring at the same time and place as the project. Examples include direct losses to n ative habitats, potential jurisdictional waters, wetlands, and special -status species; the crushing of adult plants, bulbs, or seeds; the diversion of natural surface water flows; injury, death, and/or harassment of listed and/or special -status species; an d the destruction of habitats necessary for species breeding, feeding, or sheltering.

Indirect impacts may occur later in time or at a place that is farther removed in distance from the project than direct impacts, but indirect impacts are still reasonably foreseeable and attributable to project-related activities. Examples include habitat fragmentation; elevated noise, dust, and lighting levels; changes in hydrology, runoff, and sedimentation; decreased water quality; soil compaction; increased human activ ity; and the introduction of invasive wildlife (domestic cats and dogs) and plants. Indirect impacts may be both short-term and long-term in their duration.

A 150-foot fire fuel modification buffer is included in the southern end of the project. This area will be subject to ongoing vegetation management to reduced fire fuels. For the purposes of biological resource impacts, any areas subject to ongoing vegetation management are considered to be impacted.

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Threshold #1: Have a substantial adverse effect eithe r directly or through habitat modifications, on any species identified as a candidate, sensitive or special status species in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.

Direct and Indirect Impacts – Special - Status Plants Species No special -status plant species were documented during general biological surveys or during focused rare plant surveys, and none have a moderate or high potential to occur on the project site.

As such, no direct or indirect impacts on special -status plant species would occur with project implementation.

Direct and Indirect Impacts - Special - Status Wildlife Species No special -status wildlife species were documented during project biologi cal surveys or during focused coastal California gnatcatcher surveys. Two special status species, Coastal California Gnatcatcher and Cooper’s Hawk are discussed below. No additional federally - listed, state- listed, or CDFW Watch List species are anticipat ed to have a moderate or high potential to occur on the project site.

Coastal California Gnatcatcher
This species has been reported within one mile of the project site, with one report occurring approximately 0.15 mile west of the project site (RBC 2020a). This historical sighting is from 1997 and the area where the sighting occurred has been developed into a residential development, likely fragmenting gnatcatcher populations. Suitable gnatcatcher Diegan coastal sage scrub habitat occurs along the southern project boundary. However, this habitat is surrounded by residential developments and lacks connectivity to larger expanses of habitat.

Protocol 2020 breeding season coastal California gnatcatcher surveys for the project were negative (RBC 2020b). As such, the project site is not considered to be occupied and impacts on coastal California gnatcatcher are not anticipated with implementation of the project. A less than significant
impact is identified.

Cooper’s Hawk
Cooper’s hawk is a CDFW Watch List species when nesting. This species is found across a variety of habitats, including coastal sage scrub, riparian woodlands, and urban areas. Cooper’s hawk feed on small bird species and require large trees to nest. This species often nests in riparian woodlands and will occasionally nest in large ornamental trees.

Cooper’s hawk was observed flying over the project site during the 2020 general biological survey (RBC 2020a). Although Cooper’s hawk may use the project site as a hunting territory, suitable nesting habitat containing large trees is not present. As such, Cooper’s hawk is not anticipated to nest within the project site. Also, the project would be constructed in conformance with nesting bird regulations (see below, Direct and Indirect Impacts – Nesting Birds) which would further ensure direct impacts on Cooper’s hawk are avoided. A
less than significant impact is identified.

Direct and Indirect Impacts - Nesting Birds
The project site has the potential to impact active bird nests if vegetation is rem oved or ground disturbing activities occur during the nesting season (February 1 to August 31). Impacts on nesting

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birds are prohibited by the MBTA and CFGC. Clearing, grubbing and construction activities, if conducted during the breeding season, could dir ectly or indirectly impact species protected under the MBTA. This represents a significant impact (Impact BIO-1) and mitigation is required. • Impact BIO-1: Potential to impact avian species protected under the Migratory Bird Treaty Act if tree removal, vege tation removal, or other construction activities occur during the nesting season.

Threshold #2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or b y the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service.

Direct Impacts – Sensitive Habitats
The project will impact seven habitats or land uses. Table 3.3 -4 summarizes the impacts by vegetation community/land use and Figure 3.3 -2 presents the impacts . The project will result in direct and permanent impacts to three sensitive vegetation communities including 0.61 acre of Diegan coastal sage scrub, 0.03 acre of coastal sage scrub -Baccharis dominated and 9.50 acres of non-native grassland. This represents a significant impact (Impact BIO-2) and mitigation is required. • 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 acr es of non-native grassland.

Table 3.3-4. Project Vegetation Community/Land Use Impacts Vegetation
Community/Land
Use (Map Code)
Project Site
Impacts (Acres)(1)
Grading Off Site
(Acres)(1)
150-foot Brush
Management
Zone for Fire Fuel
Modification
(Acres)(1)
Total Project
Impacts
Developed 0.06 <0.01 0.06
Diegan Coastal
Sage Scrub 0.01 0.59 0.61
Diegan Coastal
Sage Scrub -
Baccharis
Dominated

0.03 0.03
Disturbed 0.17 0.17
Non-Native
Grassland 9.07 0.44 9.50
Ornamental 0.22 0.04 0.26
Ruderal <0.01 <0.01
TOTAL 9.56 0.05 1.03 10.63
Source: RBC 2020a

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Note: (1) Acreages rounded to the hundredths based on raw numbers provided during GIS analysis of the project, which are available upon request.

Indirect Impacts – Sensitive Habitats
The site occurs within a relatively developed area, with residential development to the east and west of the site. The northern project boundary borders E. Barham Drive, and the southern project boundary borders undeveloped lands that support Diegan coastal sage scrub and chaparral habitat.

Construction activities would occur adjacent to sensitive coastal sage scrub and other sensitive habitats. Construction activities could result in potentially significant indirect im pacts to these habitats through erosion, and intrusion of workers and/or equipment. This represents a significant
impact (Impact BIO-3) and mitigation is required.
• Impact BIO -3: Potential for indirect impacts to sensitive habitats during project construction.

The introduction of future residents to the project site also increases the potential for inadvertent access to sensitive habitats, however the project is adjacent to alread y developed or disturbed areas. Landscaping associated with the development could also introduce non -native invasive species to sensitive habitat areas. This represents a
significant impact (Impact BIO-4) and mitigation
is required.
• Impact BIO-4: Potential for indirect impacts to sensitive habitats during project operation.

Threshold #3: Have a substantial adverse effect on state or federally protected wetlands (including but not limited to marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrologic interruption, or other means.

Direct Impacts – Jurisdictional Wetlands and Waters
No vernal pools were documented on the project site. RBC documented curly dock ( Rumex crispus), a wetland indicator species with a facultative (FAC) rating within a low-lying area in the center of the site during the general biological survey conducted on March 11, 2020 (RBC 2020a). In addition, RBC documented two plant species commonly associated with depressional areas confined by clay soils, coastal plantain (Plantago elongata; FACW) and slender woolly marbles ( Psilocarphus tenellus; OBL), within another low -lying area in the southern portion of the site (RBC 2020a). No defined bed or bank or other regular flow indicators were observed during the initial aquatic resources assessment; thus, no potential non -wetland waters of the U.S./State or CDFW streambed were observed on site.

These two areas were further investigated by Helix on April 24, 2020 to determine their anticipated jurisdictional status per Corps, RWQCB, or CDFW regulations and protocols. Helix staff took four wetland delineation sampling points within and near the two areas noted during RBC’s initial aquatic resources assessment. None of the four sampling points met the required federal - or state- jurisdictional wetland parameters per Helix’s findings. As such, HELIX concluded that the on -site low- lying areas are not expected to be jurisdictional under the Corps, RWQCB, or CDFW, as they did not meet the required hydrophytic vegetation, hydric soils, and wetland hydrology parameters (Helix 2020). As such, impacts on potentially jurisdictional aquatic features would be less than significant.

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Indirect Impacts – Jurisdictional Wetlands and Waters
Water quality in jurisdictional areas can be adverse ly affected by surface water runoff and sedimentation during construction. The use of petroleum products (e.g., fuels, oils, and lubricants) and erosion of cleared land during construction could potentially contaminate surface water. Water quality in aquatic systems and terrestrial species that depend on these resources may be adversely affected. The project is adjacent to already developed or disturbed areas and will comply with stormwater regulations, including implementation of a stormwater pollution and prevention plan (SWPPP) during construction. During project operation, no impact is anticipated due to a comprehensive water quality management approach and implementation of site design, source control, low impact development (LID), and treatment control BMPs further described in Section 3.8, Hydrology/Water Quality. Indirect impacts to jurisdictional wetlands and waters would be less than significant.

Threshold #4: Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery site.

Direct and Indirect Impacts – Wildlife Movement Corridors and Habitat Linkages As discussed above in Section 3.3.1, a wildl ife corridor can be defined as a physical feature that links wildlife habitat, often consisting of native vegetation that joins two or more larger areas of similar wildlife habitat. Regional corridors are defined as those linking two or more large patches of habitat, and local corridors are defined as those allowing resident animals to access critical resources (food, cover, and water) in a smaller area that might otherwise be isolated by urban development. A viable wildlife migration corridor consists of m ore than an unobstructed path between habitat areas. Appropriate vegetation communities must be present to provide food and cover for both transient species and resident populations of less mobile animals. There must also be a sufficient lack of stressors and threats within and adjacent to the corridor for species to use it successfully.

The project area does not occur within a local movement corridor identified in Figure 4 -2 the City’s General Plan (San Marcos 2012). As such, impacts on wildlife movement and corridors would be less than significant and no mitigation is required.

Threshold #5: Conflict with any local policies or ordinances protecting biological resources, such as tree preservation policy or ordinance.

One coast live oak tree was documented o n the site survey area but would not be impacted by the proposed development. The project would be consistent with the applicable City of San Marcos Conservation and Open Space Element goals and policies, as detailed in Section 3.10, Land Use and Planning. Therefore, a
less than significant impact is identified and no mitigation is required.

Threshold #6: Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state hab itat conservation plan.

The project site is located within the MHCP. However, the project site is not located within FPA as defined in City’s Draft Subarea Plan. Additionally, the project would comply with habitat mitigation requirements outlined in the City’s Draft Subarea Plan. As such, no project conflicts with adopted NCCP or HCP plans would occur with project implementation. Therefore, a less than significant
impact is identified and no mitigation is required.

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3.3.5 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 signif icant 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 projects 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 biological resources the cumulative analysis is based upon a list approach. All of the cumulative projects within the City identified in Table 2 -3 are considered in this cumulative analysis.

The biological cumulative impact analysis focuses on those projects that would have a similar type of biological resource i mpact as the proposed project. Sensitive habitat impacts associated with the project include direct and indirect impacts to non -native grassland, Diegan coastal sage scrub and Diegan coastal sage scrub – Baccharis dominated lands. Additionally, the project has the potential to impact species protected under the MBTA.

The project will add to cumulative loss of sensitive habitats in the region, including non -native grassland (9.50 acre), Diegan coastal sage scrub (0.61 acre), and Diegan coastal sage scrub – Baccharis dominated (0.03 acre). These impacts would be significant prior to mitigation.

Implementation of mitigation measures MM -BIO-2 will require the preservation, off -site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank , or a combination thereof of consistent with the mitigation ratios of the MHCP and City’s Draft Subarea Plan. This includes 1:1 2:1 ratio for the upland habitat and 0.5:1 for the non -native grassland. Additionally, implementation of mitigation measures MM -BIO-3 and MM -BIO-4 will reduce indirect impacts to sensitive lands through construction monitoring and review and approval of landscape plans to ensure the exclusion of non-native, invasive plant materials.

Of the cumulative projects identified in Table 2 -3 in Chapter 2.0, Project Description, several of the identified projects were identified as having impacts to coastal sage scrub: San Marcos Highlands (77.36 acres), Murai (32.11 acres), Valiano (1.8 acres), Harmony Grove Village South (10.4 acres), and Sunrise (4.59 acres). These projects have mitigated or are required to mitigate their individual impacts to coastal sage scrub to below a level of significance through either onsite preservation/restoration or offsite habitat acquisition, either at a 1:1 or 2:1 ratio, depending on whether they are within an FPA or not.

The cumulative projects which remove trees or vegetation during the nesting season could also have the potential for impacts to species protected under the MBTA. These impacts are avoided thr ough restrictions on construction timing, or the performance of pre -construction surveys to ensure that nesting birds would not be impacted. This is similar to the mitigation identified for the proposed project and would ensure that cumulative impacts are less than significant.

It is presumed that all reasonably foreseeable cumulative projects, including those described in Table 2-3, and discussed above, would be required to conform to existing regulations with respect to avoidance, minimization, and mitiga tion of impacts to sensitive habitat, achieving no- net-loss of wetlands and like/kind replacement for impacts to sensitive habitat that cannot be avoided.

Therefore, it is assumed that impacts on a regional basis would be assessed and mitigated pursuant to CEQA, and those projects within the City’s jurisdiction would be reviewed by the City during the

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project review and approval process. Thus, project impacts to biological resources would not be cumulatively considerable.

3.3.6 Mitigation Measures
Implementation of the following mitigation measures would be required as a condition of project approval:

Nesting Birds (Impact BIO-1)
MM-BIO-1 To avoid direct impacts on raptors and/or native/migratory birds, removal of habitat that supports active nests in the proposed area of disturbance should occur outside of the breeding season for these species (February 1 to September 15). If removal of ha bitat in the proposed area of disturbance must occur during the breeding season, a qualified biologist shall conduct a preconstruction survey to determine the presence or absence of nesting birds in the proposed area of disturbance. The pre -construction (precon) survey shall be conducted within ten (10) calendar days prior to the start of construction activities (including removal of vegetation). If nesting birds are observed, a letter report or mitigation plan in conformance with applicable State and Feder al Law (i.e., appropriate follow up surveys, monitoring schedules, construction, and noise barriers/buffers, etc.) shall be prepared and include proposed measures to be implemented to ensure that take of birds or eggs or disturbance of breeding activities is avoided. The report or mitigation plan shall be submitted to the CDFW and/or USFWS as applicable for review and approval and implemented to the satisfaction of those agencies. The project biologist shall verify and approve that all measures identified in the report or mitigation plan are in place prior to and/or during construction. If nesting birds are not detected during the preconstruction survey, no further mitigation is required.

Direct Impact to Sensitive Habitats (Impact BIO-2)
MM-BIO-2 Direct impact to 0.61 acre of Diegan coastal sage scrub and 0.03 acre of Diegan coastal sage scrub – Baccharis dominated shall be mitigated at a 1:1 2:1 ratio for a total of 1.28 0.64 acre. Direct Impact to 9.50 acres of non -native grassland shall be mitig ated at a 0.5:1 ratio for a total of 4.75 acres. These mitigation ratios are consistent with Tables 4 -6 and 4 -7 of the MHCP (SANDAG 2003) and Table 4 in Section 5.2.1 of the City’s Draft Subarea Plan (City of San Marcos 2001).

This mitigation shal l be accomplished by the project applicant through on -site preservation, off-site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the Planning Manager. Proof of onsite preservation, off-site acquisition, payment of in lieu fees, purchase of credits from an approved mitigation bank or a combination thereof shall be provided to the Planning Manager prior to issuance of a grading permit.

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Indirect Impact to Sensitive Habitats During Project Construction (Impact BIO-3) MM-BIO-3 A biologist shall be contracted to perform regular random checks (at minimum once a month) to ensure implementation of the following monitoring requirements and BMPs. Monitoring reports and a post -construction monitoring report will be prepared to document compliance with these requirements and shall be submitted to the Planning Manager.
• To prevent inadvertent disturbance to areas outside the limits of work, the construction limits shall be clearly demarcated (e.g., installation of flagging or temporary visibility construction fence) prior to ground disturbance activities and all construction activities, including equipment staging and maintenance shall be conducted within the marked disturbance limits. The work limit delineation will be maintained throughout project construction. • Spoils, trash, and any excavation -generated debris will be removed to an approved offsite disposal facility. Trash and food items will be contained in closed containers and removed daily to reduce the attraction of opportunistic predators to the site, such as common ravens, coyotes, and feral cats and dogs that may prey on listed species.
• Raw cement/concrete or washings thereof, asphalt, paint or other coating material, oil, or other petroleum products, or any other substances that could be hazardous to vegetation or wildlife resources, resulting from project - related activities, will be prevented from contaminating the soil. • Construction activities will be limited to dayl ight hours to the extent feasible.

If nighttime work is necessary, lighting will be shielded away from surrounding natural areas. Fixtures will be shielded to downcast below the horizontal plane of the fixture height and mounted as low as possible.

Indirect Impact to Sensitive Habitats During Project Operation (Impact BIO-4) MM-BIO-4 To avoid indirect impacts on adjacent sensitive habitats, final landscape plans will be reviewed and approved by a qualified biologist to ensure that no invasive plant materials are included in planting plans.

3.3.7 Conclusion
Based on the presence of suitable avian nesting habitat, pre -construction clearance survey for nesting birds would be conducted to ensure that no impacts on nesting birds that are afforded protection under the M BTA occur (see MM -BIO-1). Mitigation measure MM -BIO-1 requires a preconstruction survey if construction is proposed during the nesting season. If nesting birds are found, avoidance measures would be implemented to minimize impacts. With the implementation of MM-BIO-1, direct impacts on nesting birds would be less than significant.

The project would result in a direct impact to sensitive habitats, including Diegan coastal sage scrub, Diegan coastal sage scrub – Baccharis dominated and non -native grassland. T his impact would be mitigated to below a level of significance through on -site preservation, off -site acquisition, in lieu fees, a purchase of credits from an approved mitigation bank, or a combination thereof as approved by the Planning Manager at a 1:1 2:1 ratio for the Diegan coastal sage scrub and Diegan coastal

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sage scrub – Baccharis dominated habitats and at a 0.5:1 ratio for non -native grassland. Proof of onsite preservation, off-site acquisition, payment of in lieu fees, purchase of credits from an approved mitigation bank or a combination thereof shall be provided to the Planning Manager prior to issuance of a grading permit.

The project could indirectly impact sensitive species during project construction and could introduce non-native invasive spe cies through landscape plans . Implementation of mitigation measures MM - BIO-3 and BIO -4 would ensure impacts on adjacent habitats are avoided through construction monitoring and review and approval of landscape plans to ensure the exclusion of non -native, invasive plant materials.

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Figure 3.3-1. Existing Biological Resources

Source: RBC 2020a

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Figure 3.3-2. Impacts to Biological Resources

Source: RBC 2020a

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3.4 Cultural Resources
Introduction
This section identifies the cultural resources on the project site and analyzes the potential impacts of the proposed project on cultural resources. Cultural resources considered in this analysis include archaeological (prehistoric) resources and historical resources. Tribal Cultural Resour ces are analyzed in Section 3.16 of the Environmental Impact Report (EIR) 4.

The analysis in this section is based upon the following reports prepared by ASM Affiliates (ASM):
• Cultural Resources Inventory for the Barham Residential Project, San Marcos, California, November 3, 2020 (ASM 2020)
• Archaeological Significance Evaluation for the Barham Residential Project, San Marcos, San Diego County, California, April 2021 (ASM 2021).

The cultural resources report included a record search, literature review, correspondence with Native American contacts, and field survey. The archaeological significance evaluation analyzed the potential significance of a historic site discovered during the cultural resources study. 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 and significance evaluation are included as Appendix F.1 and F.2 of the EIR a nd the General Plan is available on the City’s web site.5
Table 3.4-1 summarizes the project- and cumulative-level cultural resources impacts, by threshold.

Table 3.4-1. 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 an
archaeological resource pursuant to
Section 15064.5.

Potentially
Significant
Less than
Significant
Mitigated to Less
Than Significant
#2 – Cause a substantial adverse
change in the significance of a
historical resource as defined in
Section 15064.5.

Potentially
Significant
Less than
Significant
Mitigated to Less
Than Significant
#3 – Disturb any human remains,
including those interred outside of
dedicated cemeteries.

Potentially
Significant
Less than
Significant
Mitigated to Less
Than Significant

4 Full references for documents cited in this section are included in Chapter 7, References, of this EIR. 5 http://www.san-marcos.net/work/economic-development/general-plan

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

Historical Context
The Archaeological Evaluation Report (Appendix F.2) provides a detailed summary of the cultural history including prehistoric archaeology, ethnohistory and history of San Marcos and specifically occupation of the project site. A brief summary is provided below.

Prehistoric Archaeology. Archaeological investigations in coastal southern California have documented a dive rse range of human adaptations extending from the late Pleistocene up to the time of European contact. The prehistory of San Diego County is most frequently divided chronologically into three or four major periods. An Early Man stage, perhaps dating back t ens of thousands of years, has been proposed. More generally accepted divisions include a Terminal Pleistocene/Early Holocene period (ca. 12,000 -6000 B.C.) (Paleo -Indian stage; Clovis and San Dieguito patterns), a Middle/Late Holocene period (ca. 6000 B.C. -A.D. 800) (Archaic stage; La Jolla, Millingstone, or Encinitas pattern), and a Late Prehistoric period (ca. A.D. 800 -1769) (Archaic stage; San Luis Rey pattern, Palomar tradition).

Ethnohistory. 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 extending inland from the coastal plain s. 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 as the Late Prehistoric period. Late Prehistoric sites are generally characterized by small, pressure -flaked projectile points, ceramics, an emphasis on collecting, 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.

History. European exploration of the San Diego area began in 1542 with the arrival of a maritime expedition under Juan Rodriguez Cabrillo, followed by a similar reconnaissance in 1602 by Sebastián Vizcaíno. The historic period proper did not begin until 1769, when multiple seaborne and overland expeditions under the leadership of the soldier Gaspar de Portolá and the Franciscan missionary Junípero Serra reached the region from Baja California and passed northward along the coastal plain to seek Monterey. To the south, a royal presidio and a mission were established that year in San Diego. Additional missions were foun ded among the Luiseño/Juaneño at San Juan Capistrano in 1776 and San Luis Rey de Francia in 1798.

As Spanish attention was consumed by the Napoleonic wars in Europe, California and its government and missions were increasingly left to their own devices. In 1821, Mexico consummated its

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independence from Spain, and the region became more open to outside visitors and influences. The missions were secularized by act of the Mexican Congress in 1833. Native Americans released from the missions at San Diego, San L uis Rey, and San Juan Capistrano returned to their native villages, moved east to areas lying beyond Mexican control, or sought work on ranchos or in the towns of San Diego and Los Angeles. Numerous large land grants were issued to private owners during th e Mexican period, including Agua Hedionda, Los Vallecitos de San Marcos, Buena Vista, and Santa Margarita y Las Flores in northern coastal San Diego County.

The region experienced cycles of economic and demographic booms and busts, with notable periods of growth in the mid -1880s, during World Wars I and II, and on a more sustained basis throughout the postwar decades. Aspects of development included the creation of transportation networks based on port facilities, railroads, highways, and airport s; more elaborate systems of water supply and flood control; grazing livestock and growing a changing array of crops; supporting military facilities, including the extensive Camp Pendleton facility established in 1942; limited amounts of manufacturing; and accommodating visitors and retirees. After some false starts, San Diego converted itself to a substantial city, and then into a metropolis. Other cities were incorporated in the north coastal region, including Oceanside (1888), Carlsbad (1952), San Marcos (1963), and Vista (1963).

Rancho Los Vallecitos de San Marcos. The project area is within the original boundaries of Rancho Los Vallecitos de San Marcos. Before secularization of the missions, this land was one of the cattle - grazing tracts claimed by Mission San Luis Rey.

City of San Marcos. San Marcos was typical of the small agricultural communities that grew up in the hinterland of San Diego, characterized generally by widely dispersed settlements that were united by a common school district, post offic e, church, and general store. San Marcos remained a quiet rural town through the first half of the twentieth century. While agriculture had dominated in the late 1800s and early 1900s, by the mid -1900s, dairies and poultry production became a big part of t he business in the town. San Marcos was chosen as the site of the future Palomar College in 1946.

Classes initially took place in Vista, but Quonset huts were moved onto the San Marcos site in 1950, and the first permanent buildings were constructed in 195 6. Population growth in San Marcos had been constrained by the lack of water resources in the region. The arrival of Colorado River water at San Marcos in 1956, supplementing the existing local water supply, was a boon to the city. After the arrival of wat er, several small businesses started, and the population rapidly increased to 2,500.

San Marcos, with a population of 3,200 residents, became incorporated on January 28, 1963.

Through the 1960s, the city grew by a few thousand new residents, but in the 197 0s, San Marcos was flourishing as the third fastest growing city in the state with a population of 17,479 by 1980.

During the 1980s, San Marcos almost doubled its population to 33,800. Growth has continued to boom in San Marcos, and the 2019 population of the city is estimated at 96,664 (USCB 2019).

Occupational History of 943 Barham Drive. According to the chain of title, the original owner of the parcel at 943 Barham Drive was Thomas J. Biggs. Biggs was born in Illinois in 1826 and came to California in 1850. He was issued the land in 1889 under the Homestead Act of 1862 . The land was later sold to Horace G. Parsons in 1896. The 1901 topographic map of the Barham property indicates a building near the location of the house that appears on the first availab le aerial photograph in 1928. After Horace died, his wife Hattie took over the property and made some improvements, including moving the house to face the street. The property was sold in 1910 to Emilia Lau and later to Nellie J. Whitehead in 1916. The Whiteheads were the owners of the property at the time of the earliest available aerial photo in 1928. There are multiple structures on the parcel, but the image is not clear enough to determine the exact number. Jim Ferrero and his wife Margarita

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purchased the ranch from the Whiteheads in 1932. The 1938 aerial photo shows several buildings and active fields with an orchard at the front of the property. From 1946 to 1947 the home was owned by Walter Lesley Williford and his wife Lenore. The next owners, Donald and Lillian James, lived in the home for 30 years, from 1947 to 1977. The aerial photo from 1953 shows a drive leading west to the adjacent parcel which was being developed. The 1964 aerial photos, when the James were still the owners, illustrates that th e drive to the west was gone and the adjacent parcel was used for farming. There was a larger road leading to the west of 943 Barham and more outbuildings had been added. By 2005 the house on the adjacent parcel had been demolished, and by 2009 a developme nt was located on the adjacent site. The buildings at 943 Barham Drive were demolished sometime between 2005 and 2009 (ASM 2021).

Records Search
A records search was undertaken at the South Coastal Information Center (SCIC) of the California Historical Res ources Information System (CHRIS) 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 conducted within a mile radius of the project ar ea. Six of these reports address areas that intersect or overlap with the project area. 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 fea tures. 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 SLF was negative.

A consultation 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 by ASM to each of the Native American contacts provided by the NAHC on October 7, 2020.

Three responses were received, including from the Viejas Band of Kumeyaa y 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 significance or ties to the Kumeyaay Nation. 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 Repatriati on Act laws. They also requested that the 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.

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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 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 standard cultural resources mitigation measure s 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 L uis 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.

Archaeological (Prehistoric) Resources
The project site was surveyed by ASM Associate Archaeologist Holly Drake and Mario Herrera, a qualified Native American monitor from Saving Sacred Sites on October 6, 2020.

Soils on the project site are sandy silt and appear to have been previously disturbed. Small, angular gravels and concrete fragments are distributed throughout the project site. The presence of these materials and the disturbed nature of the ground surface suggest that the majority of the project site has been mechanically graded at some point in the past.

No prehistoric cultural material was identified on the ground surface of the project site. All rodent burrows and back dirt, and other portions of expose d 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.

Historical Resources
Several historic features were identified 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. ASM Associate Archaeologist Holly Drake and Archaeological Technician Joakim Lamoy returned to the project site on October 13, 2020 to record and document these features as a historic site on the appropriate Department of Parks and Recreation (D PR) forms. A total of six historic features were identified at the site, including the remains of what appear to be a formed concrete retaining wall (Feature 1), a cinder block house

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foundation and associated septic tank and concrete stairs (Feature 2), a cinder block garage foundation (Feature 3), a concrete and cinder block water storage cistern (Feature 4), a concrete shed foundation (Feature 5), and a small concrete pad (Feature 6).

One of the features (Feature 1) is comprised of formed concrete with a large amount of angular cobbles mixed in as aggregate. Two of the features, the house foundation and associated septic enclosure (Feature 2) and the garage foundation (Feature 3) are constructed of concrete mortared cinderblock and iron rebar. A four -step concrete staircase located directly adjacent to Feature 2 is also comprised of poured concrete mixed with angular cobble aggregate. Feature 4, the possible water storage or cistern remains is comprised of both poured concrete with angular cobble aggregate and concrete mortared cinder block. Fragmented concrete and historic debris comprised of potentially diagnostic glass and ceramic fragments is distributed on the ground surface between the site features. The remains of what appear to be chicken or rabbit cages were also identified. Two segments of steel T -post and wire fencing are located to the north and west of the site features and concrete debris scatters. A DPR Primary Record (DPR 523A) and Archaeological Site Record (DPR 523C) were prepared for the historic site and are included in Appendix D of the cultural resources report (Appendix F.1 of this EIR).

The cultural materials identified in association with the historic site appears to represent the remains of an early twentieth -century agricultural home stead. Although limited, the historic debris includes material that appears to be associated with domestic kitchen use, including fragments of plates, bottle fragments, and ceramic fragments. In addition to typical residential housing foundation remains, i ncluding what appears to be a septic system, the surrounding property appears to have been graded and tiered for the purposes of agricultural cultivation. The remains of what appear to be animal cages also suggest that animals were raised either for person al use or for sale during the time that the site was occupied. The intentional demolition and grading of the historic site location and surrounding area have severely damaged the features and redeposited much of the historic material, but additional histor ic cultural material may be present below the ground surface of the site.

A review of historic aerial photos indicates that the homestead and what appears to be an orchard surrounding it were in existence as early as 1947. Based on this information, the fe atures comprising the historic site are well over 50 years old and are therefore potentially eligible for listing in the California Register of Historical Resources (CRHR). In accordance with CEQA and the cultural resource management requirements of the City of San Marcos, the historic site required evaluation for eligibility for listing in the CRHR prior to any further demolition that may be associated with the implementation project. This evaluation was conducted by ASM as described further below.

Archaeological Evaluation of Barham-2020-ASM-HD-01
ASM prepared an archaeological significance evaluation (ASM April 2021) for a historic site, Barham- 2020-ASM-HD-01, discovered during the cultural resources inventory for the proposed project. This cultural resou rce consisted of a historic site with the ruins of a residential building, various foundations for outbuildings, and a scatter of historic artifacts . The testing program included excavation of ten shovel test pits, surface mapping, subsurface testing to de termine the presence or absence, horizontal and vertical extent and structure of subsurface cultural deposits within Barham - 2020-ASM-HD-01. Laboratory work included standard processing, cataloging of the materials recovered in the field, and analysis.

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Excavations revealed that the subsurface component of the site was comprised of fragmented nondiagnostic artifacts in a highly disturbed context, likely as a result of demolition activities at the site and bioturbation . The testing program within Barham -2020-ASM-HD-01 resulted in the recovery of 483g of historic artifacts/ecofacts. Artifacts included 47.3g of ceramic fragments, 202.1g of glass fragments, 163.8g of metal fragments, 2.5g of leather, 0.4g of rubber, and 7.6g of miscellaneous artifacts. Ecofacts re covered from the site include 0.8g of faunal bone and 0.2g of Oyster ( Ostrea sp.) shell fragment. The recovered assemblage is dominated by metal and glass items that are intermixed with a small number of ceramic fragments and various other materials.

Historic artifacts were identified to their most -specific diagnostic level based on their morphological characteristics. Ceramic artifacts included building tile fragments and dishware including plate and mug fragments. Glass artifacts included window glass fra gments, safety glass, and highly fragmented glass from bottles or other household items. Metal artifacts were comprised of nails of varying sizes, likely associated with construction at the site, mechanical -related artifacts such as bolts and washers, and agricultural-related artifacts such as barbed -wire fencing fragments.

Miscellaneous artifacts included a small section of twine and a broken wooden stake.

Barham-2020-ASM-HD-01 was evaluated for eligibility for listing in the CRHR. ASM determined that the site is not eligible for listing on the CRHR under Criterion 1, 2, 3, or 4 (ASM 2021). More information is provided below in Section 3.4.4 under Threshold #2.

3.4.2 Regulatory Setting
The following section provides a general description of the applicable regulat ory requirements pertaining to cultural resources, including federal, state and local guidelines.

Federal
National Historic Preservation Act
The National Historic Preservation Act (NHPA) established the National Register of Historic Places (NRHP) program under the Secretary of the Interior. The NHPA authorized funding for state programs with provision for pass- through funding and participation by local governments, created an Advisory Council on Historic Preservation, and established the Section 106 review process for protecting historic resources. The goal of the Section 106 review process is to offer protection to sites that are determined eligible for listing in the NRHP. The NHPA provides the legal framework for most state and local preservation laws.

Traditional Cultural Properties (Native American Heritage Values) Federal and state laws mandate that consideration be given to the concerns of contemporary Native Americans with regard to potentially ancestral human remains, associated funerary objects, and items of cultural patrimony. Consequently, an important element in assessing the significance of the study site has been to evaluate the likelihood that these classes of items are present in areas that would be affected by the proposed project. Also, pote ntially relevant to prehistoric archaeological sites is the category termed Traditional Cultural Properties in discussions of cultural resource management performed under federal auspices. According to Patricia L. Parker and Thomas F. King (1998), “Traditi onal” in this context refers to those beliefs, customs, and practices of a living community of people that have been passed down through the generations, usually orally or through practice. The traditional cultural significance of a historic property, then , is significance derived from the role the property plays in a community’s historically rooted beliefs, customs, and practices.

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State
California Points of Historic Interest
California Points of Historical Interest are buildings, structures, site or featur es of local (city and county) significance and have anthropological, cultural, military, political, architectural, economic, scientific/technical, religious, experimental, or other value. Points of Historical Interest designated after December 1997 are rec ommended by the State Historical Resources Commission are also listed in the California Register of Historical Resources. The criteria for designation of Points of Historical Interest are the same as those that govern the California Historic Landmarks program.

Health and Safety Code 7050.5
This code establishes that any person who knowingly mutilates, disinters, wantonly disturbs, or willfully removes any human remain in or from any location without authority of the law is guilty of a misdemeanor. It furthe r defines procedures for the discovery and treatment of Native American remains.

Health and Safety Code 8010-8011
This code is intended to provide consistent state policy to ensure that all California Indian human remains and cultural material are treated with dignity and respect. The code extends policy coverage to non-federally recognized tribes and federally recognized groups.

Assembly Bill 2461
The section provides procedures for private land owners to follow upon discovering Native American human remains. Land owners are encouraged to consider culturally appropriate measures if they discover Native American human remains as set forth in California PRC 5097.98.

Senate Bill 18
SB 18, approved in 2004, amends the California Civil Code a nd 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 designating land as open space in order to preserve or mitigate impacts to specified Native American places, features and objects that are located within a city’s or county’s jurisdiction. SB 18 also requires cities and counties to hold in strict confidence any information about the specific identity, location, char acter 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 American Heritage Commission (NAHC) maintains a list of Cali fornia 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 California 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.

Tribal Cultural Resources are discussed in Section 3.16 of the EIR.

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Local
San Marcos General Plan Conservation and Open Space Element The Conservation and Open Space Element of the City’s General Plan contains several policies pertaining to the protection of ar chaeological, and historic resources. The following goals 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 Trib al 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. o Policy COS -11.2: Prohibit the demolition or removal of a historic str ucture without evaluation of the condition of the structure, the cost of rehabilitation, and the feasibility of alternatives to preservation in place including but not limited to relocation, or reconstruction offsite, and/or photo-preservation.

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.

3.4.3 Thresholds of Significance
The determination of significance for cultural resources is based on CEQA Guidelines Appendix G .

Impacts to cultural resources would be significant if the proposed project would:
• Threshold #1: Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5;
• Threshold #2: Cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5,6
• Threshold #3: Disturb any human remains, including those interred outside of dedicated cemeteries.

6 Section 15064.5 of the CEQA Guidelines defines a historical resource as one that meets one or more of the following criteria: 1) Is listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the CRHR; or 2) Is included in a local register of historical resources or identified as significant in a historical resource survey meeting the requirements of Section 5024.1(g) of the Public Resources Code; or 3) Is determined to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military or cultural annals of California.

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3.4.4 Project Impact Analysis
The project site is vacant but covered in vegetation. Ground disturbing activities can result in impacts to archeological and historical resources if they are present on the project site. The following analysis discusses the potential for the project to have cultural resources.

Threshold #1: Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.

No cultural resources were obser ved during the archaeological survey 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. The majorit y 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 p resent on the ground surface within the project site that were not visible during the survey. Therefore, there is a potential for grading activities to impact unidentified archaeological resources. This represents a
potentially significant impact (Impact C R-1a) and
mitigation is required.
• Impact CR-1a Due to grading and ground disturbing activities, the project has the potential to impact unidentified archeological resources on the project site.

Threshold #2: Cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5.

Based upon the cultural resources study prepared for the project (ASM 2020), several historic features were identified 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. ASM recorded and documented these features as a historic site on the appropriate DPR forms. A total of six historic features were identified at the site, including the remains of what appear to be a formed concrete retaining wall (Feature 1), a cinder block house foundation and associated septic tank and concrete stairs (Feature 2), a cinder block garage fo undation (Feature 3), a concrete and cinder block water storage cistern (Feature 4), a concrete shed foundation (Feature 5), and a small concrete pad (Feature 6). A DPR Primary Record (DPR 523A) and Archaeological Site Record (DPR 523C) were prepared for t he historic site and are included in Appendix D of the cultural resources report (Appendix F.1 of this EIR).

The cultural materials identified in association with the historic site appears to represent the remains of an early twentieth -century agricultural homestead. Although limited, the historic debris includes material that appears to be associated with domestic kitchen use, including fragments of plates, bottle fragments, and ceramic fragments. In addition to typical residential housing foundation remains, including what appears to be a septic system, the surrounding property appears to have been graded and tiered for the purposes of agricultural cultivation. The remains of what appear to be animal cages also suggest that animals were raised either for p ersonal use or for sale during the time that the site was occupied. The intentional demolition and grading of the historic site location and surrounding area have severely damaged the features and redeposited much of the historic material, but additional h istoric cultural material may be present below the ground surface of the site.

A review of historic aerial photos indicates that the homestead, and what appears to be an orchard surrounding it, were in existence as early as 1947. Based on this information, the features

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comprising the historic site are well over 50 years old, and are therefore potentially eligible for listing in the CRHR. ASM prepared an archaeological significance evaluation (ASM 2021) for a historic site, Barham-2020-ASM-HD-01. Excavations revealed that the subsurface component of the site was comprised of fragmented nondiagnostic artifacts in a highly disturbed context, likely as a result of demolition activities at the site and bioturbation.

CEQA requires that all private and public activ ities not specifically exempted be evaluated for the potential to impact the environment, including effects to historical resources. CEQA defines historical resources as “any object, building, structure, site, area, or place which is historically significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California” (Division I, PRC §5021.1(b)).

Lead agencies have a responsibility to evaluate historical resources against the California Register criteria prior to making a finding as to a proposed project’s impacts to historical resources. Mitigation of adverse impacts is required if the proposed pr oject will cause substantial adverse change.

Substantial adverse change includes demolition, destruction, relocation, or alteration such that the significance of an historical resource would be impaired. While demolition and destruction are fairly obvious significant impacts, it is more difficult to assess when change, alteration, or relocation crosses the threshold of substantial adverse change. The CEQA Guidelines provide that a project that demolishes or alters those physical characteristics of an histor ical resource that convey its historical significance (i.e., its character -defining features) can be considered to materially impair the resource’s significance.

The California Register is used in the consideration of historic resources relative to signifi cance for purposes of CEQA. A resource shall be considered by the lead agency to be “historically significant” if the resource meets the criteria for listing on the California Register of Historical Resources (PRC §5024.1, Title 14 CCR, Section 4852) consisting of the following:
1) It is associated with events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States; or 2) It is associated with the lives of persons important to local, California, or national history; or 3) It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, or possesses high artistic values; or 4) It has yielded, or has the pot ential to yield, information important to the prehistory or history of the local area, California, or the nation.

Barham-2020-ASM-HD-01 consists of the remains of a historical residence with modern and historic refuse. The historic building remains and his toric refuse at Barham -2020-ASM-HD-01 is determined as not eligible for listing in the CRHR under Criterion 1, 2, 3, or 4. For Criterion 1, there are no indications of significant historical events that occurred in association with the resource. Under Criterion 2 there is no record of important contributions to local, California, or national history by any of the prior owners. For Criterion 3, the structures were previously demolished and nothing remains to examine distinctive characteristics, the work of a master, or artistic value. Under Criterion 4, the site does not have any substantial research potential as the resource contains a low -density artifact scatter that is situated within a highly disturbed context. Only building foundations remain of the structures, and no features such as privies, cisterns, and trash pits appear to remain at the site.

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Although this investigation found Barham- 2020-ASM-HD-01 to be ineligible for listing in the CRHR under any of the four criteria, the possibility remains that f eatures or other intact deposits may be encountered during future earth moving activities. Such a discovery could potentially yield important information about this site and the period of its occupation in San Marcos. Therefore, there is a potential for gr ading activities to impact unidentified historical resources. This represents a potentially significant impact (Impact CR-1b) and mitigation is required. • Impact CR-1b Due to grading and ground disturbing activities, the project has the potential to impact unidentified historical resources underneath the project site.

Threshold #3: Disturb any human remains, including those interred outside of dedicated cemeteries.

The cultural resources field survey conducted for the project did not identify any human remai ns or find any indications that they would be expected to be found on the project site. If human remains are encountered during project construction, there is a potential for a significant impact (Impact CR- 2).
• Impact CR-2 There is a potential for project construction activities to disturb previously unidentified human remains on the project site.

State Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. Adherence to State Health and Safety Code Section 7050.5 is mandated and is reiterated as a mitigation measure in Section 3.4.6.

3.4.5 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 c ombination 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 pla nning document that describes conditions contributing to the cumulative effect. For purposes of assessing the proposed project’s cumulative impact with respect to cultural resources, the cumulative analysis is based upon a list approach to determine the proposed project’s contributing effect on potential cumulative impacts on cultural resources. All of the cumulative projects identified in Table 2 -3 are considered in this cumulative analysis.

Historical Resources
As identified in Section 3.4.4, while histor ical resources were identified on the project site, the site was determined to be ineligible for listing in the CRHR under any of the four criteria . However, the possibility remains that features or other intact deposits may be encountered during future ea rth moving activities. Thus, the potential remains for the project site to impact historic resources. It is expected that cultural resources studies would be prepared for all cumulative projects to assess potential impacts and that these projects would avo id or mitigate impacts to historical resources, as required by local jurisdictions and state law. As such, cumulative impacts to historical resources would
be less than significant.

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Archaeological 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 assess the potential for im pact 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 required to consult with trib es 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.

3.4.6 Mitigation Measures
Archaeological Resources (Impact CR-1a) and Historical Resources (Impact CR-1b) The following cultural resources mitigation measures shall apply for ground disturbing activities during the project construction phase.

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 Agreem ent) 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 lo cated 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 project 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 recipient 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. Additionally, all non -tribal artifacts collected by the archaeologist will also be subject to curation
MM-CR-1b Construction Monitoring. Prior to the issuance of a Grading Permit or ground disturbing activities, the Applicant/Owner or Grading Contractor shall provide

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written documentation (either as signed letters, contracts, or emails) to the City’s Planning Divisio n stating that a Qualified Archaeologist and Traditionally 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 pr ogram, as described in the Pre - Excavation Agreement.

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 Archaeologist 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 natu ral 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 resources. 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 Archae ologist 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 construction docume nts, 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 Q ualified 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 report shall be ret ained 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 consultation process. A fina l 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 Archaeologist and the TCA N ative American monitor may temporarily halt or divert ground disturbing

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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 or tribal cultural resources will be collected, temporarily stored in a secure location (or as otherwise agreed upon by the Qualified Ar chaeologist 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 archaeological 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 Qualifie d 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 will be presented t o 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 California 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 require 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 invent oried 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

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previously identified for sites in the area wi ll 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 Ar chaeologist 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 resources for later reburial or storage at a local curation 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 project 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 curation facility, whichever is most applicable, that the repatriation and/or curation have been completed.

Human Remains (Impact CR-2)
MM-CR-2 Human Remains . As specified by California Health and Safety Code Section 7050.5, if human remains, or remains that are potentially 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 Of fice 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 are a 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 wor king 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 Commission 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 cultu rally 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

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notifications, and until after the Most Likely Descendent is identif ied, 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 pu blic. According to California Health and Safety Code, six or more human burials at one location constitute a cemetery (Section 8100), and disturbance of Native American cemeteries is a felony (Section 7052). In the event that the Applicant/Owner and the Mo st 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 location free from future disturbance (see Public Resources Code Section 5097.98(e) and 5097.94(k)).

3.4.7 Conclusion
Based upon the analysis presented in Section 3.4.4, the potential exists for impacts to previously unidentified cultural and historical resources during project grading. These potentially significant impacts to archaeological and historical resources would be mitigated to below a level of significance through implementation of MM-CR-1a through MM-CR-1c and MM-CR-2.

Specifically, implementation of these mitigation measures provide for the presence of archaeological and Native American monitors during ground disturbing activities that would be able to identify any previously unidentified cultural and/ or historical resources, to prevent inadvertent disturban ce 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 a dditional archaeological work is necessary.

To further ensure impacts to Native American archaeological resources are protected, implementation of MM -CR-1a through MM -CR-1c provides additional protections for significant resources, and describes the proces s for proper treatment and handling to ensure impacts are minimized.

Potential impacts to human remains would be mitigated through implementation of MM -CR-2, which specifies that remains shall not be further disturbed until the San Diego County Coroner has determined origins of the remains and final treatment has been agreed to with input of Native American Tribes as necessary. Therefore, with incorporation of these measures, potential impacts to cultural resources would be reduced to below a level of significance.

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3.5 Energy
This section describes the existing setting of the project site with respect to energy use and conservation, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the proposed project.

Appendix G and Appendix F of the California Environmental Quality Act (CEQA) Guidelines requires that an environmental impact report (EIR) discusses the potentia l energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy to ensure that energy implications are considered in project -related decision- making processes. As such, th is section analyzes the energy impacts of the proposed project.

Specifically, this section summarizes the existing conditions in the project area, discusses the regulatory framework, and discloses estimated energy use during the construction and operationa l phases of the proposed project. This analysis considers the electricity, natural gas, and transportation fuel (petroleum) demand of the proposed project.

Information in this section is based on the proposed project’s Greenhouse Gas Assessment (November 2021), prepared by LDN, which is included as Appendix H.1 of this EIR.

Table 3.5-1 summarizes the project- and cumulative-level energy impacts, by threshold.

Table 3.5-1. Energy Summary of Impacts
Threshold of Significance Project-Level Impact Cumulative-Level Impact
Impact After
Mitigation
Threshold #1: Result in
potentially significant
environmental impact due to
wasteful, inefficient, or
unnecessary consumption of
energy resources, during project
construction or operation.

Less than
Significant
Less than
Significant
Less than
Significant
Threshold #2: Conflict with or
obstruct a state or local plan for
renewable energy or energy
efficiency.

Less than
Significant
Less than
Significant
Less than
Significant

3.5.1 Existing Conditions
The environmental setting for the proposed project related to electricity, natural gas, and petroleum, including associated service providers, supply sources, and estimated consumption, is discussed below.

Electricity
Electricity usage in California for different land uses varies by the types of uses in a building, types of construction materials used in a building, and the efficiency of all electricity -consuming devices within a building. Due to the state’s energy efficiency building standards a nd efficiency and

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conservation programs, California’s electricity use per capita has remained stable for more than 30 years, and the national average has steadily increased (CEC 2014).

San Diego Gas & Electric (SDG&E) provides electric services to 3.6 mill ion customers through 1.4 million electric meters located in a 4,100 -square-mile service area that includes San Diego County (County) and southern Orange County (SDG&E 2021). SDG&E is a subsidiary of Sempra Energy and would provide electricity to the propo sed project. According to the California Public Utilities Commission (CPUC), SDG&E customers consumed approximately 19,169 million kilowatt -hours (kWh) of electricity in 2015 (CPUC 2016). SDG&E is forecasted to reach 49% renewable energy in 2021, 98% of which will be from long-term contracts (SDG&E 2018).

Based on recent energy supply and demand projections in California, statewide annual peak electricity demand is projected to grow an average of 890 megawatts per year for the next decade, or 1.4% annually, and consumption per capita is expected to remain relatively constant at 7,200 – 7,800 kWh per person (CEC 2014).

In San Diego County, the California Energy Commission (CEC) reported an annual electrical consumption of approximately 19 billion kWh total with 6.6 billion kWh for residential use and 12.4 billion kWh for non-residential use in 2019 (CEC 2019).

Natural Gas
The CPUC regulates natural gas utility rates and services provided by Pacific Gas and Electric Company (PG&E), Southern California G as Company (SoCal Gas), San Diego Gas & Electric Company (SDG&E), Southwest Gas and several smaller natural gas utilities. SDG&E provides natural gas service to the Counties of San Diego and Orange and would provide natural gas to the proposed project. SDG &E is a wholesale customer of SoCalGas and currently receives all of its natural gas from the SoCalGas system (CPUC 2021).

California's natural gas utilities provide service to over 11 million gas meters . SoCalGas and PG&E provide service to about 5.9 mill ion and 4.3 million customers, respectively, while SDG&E provides service to over 800, 000 customers. In 2018, California gas utilities forecasted that they would deliver about 4,740 million cubic feet per day (MMCFD) of gas to their customers, on average, under normal weather conditions (CPUC 2021).

The majority of natural gas utility customers in California are residential and small commercials customers, referred to as "core" customers . Larger volume gas customers, like electric generators and industrial customers, are called "noncore" customers . Although very small in number relative to core customers, noncore customers consume about 65% of the natural gas delivered by the state's natural gas utilities, while core customers consume about 35% (CPUC 2021).

Most of the natural gas used in California comes from out -of-state natural gas basins. In 2017, for example, California utility customers received 38% of their natural gas supply from basins located in the U.S. Southwest, 27% from Canada, 27% from the U.S . Rocky Mountain area, and 8% from production located in California . The state does not receive liquefied natural gas (LNG) supplies.

Biogas (e.g. from wastewater treatment facilities or dairy farms) is just beginning to be delivered into the gas utility pipeline systems, and the State has been encouraging its development (CPUC 2021).

California’s regulated utilities do not own any natural gas production facilities. All natural gas sold by these utilities must be purchased from suppliers and/or marketers. T he price of natural gas sold by suppliers and marketers was deregulated by the Federal Energy Regulatory Commission in the mid -

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1980s and is determined by market forces. However, CPUC decides whether California’s utilities have taken reasonable steps to mi nimize the cost of natural gas purchased on behalf of its core customers (CPUC 2021).

Natural gas from out -of-state production basins is delivered into California via the interstate natural gas pipeline system . The major interstate pipelines that deliver out -of-state natural gas to California gas utilities are Gas Transmission Northwest Pipeline, Kern River Pipeline, Transwestern Pipeline, El Paso Pipeline, Ruby Pipeline, Mojave Pipeline, and Tuscarora . Another pipeline, the North Baja - Baja Norte Pipeline takes gas off the El Paso Pipeline at the California/Arizona border, and delivers that gas through California into Mexico. While the Federal Energy Regulatory Commission (FERC) regulates the transportation of natural gas on the interstate pipelines, and a uthorizes rates for that service, the CPUC may participate in FERC regulatory proceedings to represent the interests of California natural gas consumers (CPUC 2021).

The gas transported to California gas utilities via the interstate pipelines, as well as s ome of the California-produced gas, is delivered into the PG&E and SoCalGas intrastate natural gas transmission pipelines systems (commonly referred to as California's "backbone" pipeline system).

Natural gas on the utilities' backbone pipeline systems is then delivered to the local transmission and distribution pipeline systems, or to natural gas storage fields . Some large volume noncore customers take natural gas delivery directly off the high -pressure backbone and local transmission pipeline systems, while core customers and other noncore customers take delivery off the utilities' distribution pipeline systems . The state's natural gas utilities operate over 100,000 miles of transmission and distribution pipelines, and thousands more miles of service lines (CPUC 2021).

PG&E and SoCalGas own and operate several natural gas storage fields that are located within their service territories in northern and southern California, respectively . These storage fields, and four independently owned storage utilities - Lodi Gas Storage, Wild Goose Storage, Central Valley Storage, and Gill Ranch Storage - help meet peak seasonal and daily natural gas demand and allow California natural gas customers to secure natural gas supplies more efficiently (CPUC 2021).

In order to p roperly operate their natural gas transmission pipeline and storage systems, PG&E and SoCalGas must balance the amount of gas received into the pipeline system and delivered to customers or to storage fields . Some of these utilities’ storage capacity is de dicated to this service, and under most circumstances, customers do not need to precisely match their deliveries with their consumption. However, when too much or too little gas is expected to be delivered into the utilities’ systems, relative to the amoun t being consumed, the utilities require customers to more precisely match up their deliveries with their consumption . And, if customers do not meet certain delivery requirements, they could face financial penalties . The utilities do not profit from these f inancial penalties - the amounts are then returned to customers as a whole . If the utilities find that they are unable to deliver all the gas that is expected to be consumed, they may even call for a curtailment of some gas deliveries . These curtailments a re typically required for just the largest, noncore customers. It has been many years since there has been a significant curtailment of core customers in California (CPUC 2021).

Petroleum
There are more than 35 million registered vehicles in California, an d those vehicles consume an estimated 18 billion gallons of fuel each year (CEC 2017). Gasoline and other vehicle fuels are commercially provided commodities and would be available to the proposed project through commercial outlets.

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Petroleum currently acc ounts for approximately 92% of California’s transportation energy consumption. However, technological advances, market trends, consumer behavior, and government policies could result in significant changes in fuel consumption by type and in total. At the f ederal and state levels, various policies, rules, and regulations have been enacted to improve vehicle fuel efficiency, promote the development and use of alternative fuels, reduce transportation ‐source air pollutants and greenhouse gas (GHG) emissions, an d reduce vehicle miles traveled (VMT). Market forces have driven the price of petroleum products steadily upward over time, and technological advances have made use of other energy resources or alternative transportation modes increasingly feasible.

Largely as a result of and in response to these multiple factors, gasoline consumption within the state has declined in recent years, and availability of other alternative fuels/energy sources has increased. The quantity, availability, and reliability of transportation energy resources have increased in recent years, and this trend may likely continue and accelerate. Increasingly available and diversified transportation energy resources act to promote continuing reliable and affordable means to support vehicular transportation within the state.

Existing Infrastructure
The proposed project is within the SDG&E service area and would connect to the existing underground 69-kilovolt (kV) line at the project frontage with E. Barham Drive. SDG&E also maintains a gas dist ribution 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.

3.5.2 Regulatory Setting
Federal, state, and local agencies regulate energy use and consumption through various means and programs. On the federal level, the U.S. Department of Transportation, the U.S. Department of Energy, and the U.S. Environmental Protection Agency are three federal agencies with s ubstantial influence over energy policies and programs. On the state level, CPUC and CEC are two agencies with authority over different aspects of energy. Relevant federal, state, and local energy -related regulations are summarized below. This information helps to place the impact analysis within its proper regulatory context.

Federal
Federal Energy Policy and Conservation Act
In 1975, Congress enacted the Federal Energy Policy and Conservation Act, which established the first fuel economy standards for on-road motor vehicles in the United States. Pursuant to the act, the National Highway Traffic Safety Administration is responsible for establishing additional vehicle standards. In 2012, new fuel economy standards for passenger cars and light trucks were app roved for model years 2017 through 2021 (77 FR 62624 –63200). Fuel economy is determined based on each manufacturer’s average fuel economy for the fleet of vehicles available for sale in the United States.

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Energy Independence and Security Act of 2007
On December 19, 2007, the Energy Independence and Security Act of 2007 (EISA) was signed into law. In addition to setting increased CAFE standards for motor vehicles, the EISA includes the following other provisions related to energy efficiency:
• Renewable Fuel Standard (RFS) (Section 202)
• Appliance and Lighting Efficiency Standards (Sections 301–325) • Building Energy Efficiency (Sections 411–441)
This federal legislation requires ever -increasing levels of renewable fuels (the RFS) to replace petroleum. The U.S. Environmental Protection Agency (EPA) is responsible for developing and implementing regulations to ensure that transportation fuel sold in the United States contains a minimum volume of renewable fuel. The RFS program regulations were developed in co llaboration with refiners, renewable fuel producers, and many other stakeholders.

The RFS program was created under the Energy Policy Act of 2005 and established the first renewable fuel volume mandate in the United States. As required under the act, the original RFS program (RFS1) required 7.5 billion gallons of renewable fuel to be blended into gasoline by 2012.

Under the EISA, the RFS program was expanded in several key ways that lay the foundation for achieving significant reductions in GHG emissions f rom the use of renewable fuels, reducing imported petroleum, and encouraging the development and expansion of the renewable fuels sector in the United States. The updated program is referred to as “RFS2” and includes the following:
• EISA expanded the RFS program to include diesel, in addition to gasoline. • EISA increased the volume of renewable fuel required to be blended into transportation fuel from 9 billion gallons in 2008 to 36 billion gallons by 2022. • EISA established new categories of renewable fuel, a nd set separate volume requirements for each one.
• EISA required the U.S. Environmental Protection Agency to apply lifecycle GHG performance threshold standards to ensure that each category of renewable fuel emits fewer GHGs than the petroleum fuel it replaces.

Additional provisions of the EISA address energy savings in government and public institutions, research for alternative energy, additional research in carbon capture, international energy programs, and the creation of “green” jobs.

State
The discussion below focuses primarily on those policies, regulations, and laws that directly pertain to energy -related resources. Refer to Section 3.7, Greenhouse Gas Emissions, of this EIR, which addresses various policies, regulations, and laws targeted to the redu ction of GHG emissions that are expected to achieve co-benefits in the form of reduced demand for energy -related resources and enhanced efficiencies in the consumption of energy-related resources.

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State of California Energy Action Plan
The CEC and CPUC app roved the first State of California Energy Action Plan in 2003. The plan established shared goals and specific actions to ensure that adequate, reliable, and reasonably priced electrical power and natural gas supplies are provided, and identified policies, strategies, and actions that are cost -effective and environmentally sound for California's consumers and taxpayers.

In 2005, a second Energy Action Plan was adopted by the CEC and CPUC to reflect various policy changes and actions of the prior 2 years.

At the beginning of 2008, the CEC and CPUC determined that it was not necessary or productive to prepare a new energy action plan. This determination was based in part on a finding that the state’s energy policies have been significantly influenced by the pa ssage of Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006 (discussed below). Rather than produce a new energy action plan, the CEC and CPUC prepared an “update” that examines the state’s ongoing actions in the context of global climate change.

Senate Bill 1078 (2002)
This bill established the California RPS Program and required that a retail seller of electricity purchase a specified minimum percentage of electricity generated by eligible renewable energy resources as defined in an y given year, culminating in a 20% standard by December 31, 2017.

These retail sellers include electrical corporations, community choice aggregators, and electric service providers. The bill relatedly required the CEC to certify eligible renewable energy r esources, design and implement an accounting system to verify compliance with the RPS by retail sellers, and allocate and award supplemental energy payments to cover above -market costs of renewable energy.

Senate Bills 107 (2006), X1-2 (2011), 350 (2015), and 100 (2018) Senate Bill (SB) 107 (2006) accelerated the RPS established by SB 1078 by requiring that 20% of electricity retail sales be served by renewable energy resources by 2010 (not 2017). Additionally, SB X1-2 (2011) requires all California utilities to generate 33% of their electricity from eligible renewable energy resources by 2020. Specifically, SB X1 -2 sets a three-stage compliance period: by December 31, 2013, 20% shall come from renewables; by December 31, 2016, 25% shall come from renewables; and by December 31, 2020, 33% shall come from renewables.

SB 350 (2015) requires retail seller and publicly owned utilities to procure 50% of their electricity from eligible renewable energy resources by 2030, with interim goals of 40% by 2024 and 45% by 2027.

SB 100 (2018) accelerated and expanded the standards set forth in SB 350 by establishing that 44% of the total electricity sold to retail customers in California per year by December 31, 2024, 52% by December 31, 2027, and 60% by December 31, 2030 be secured from qualifying renewable energy sources. SB 100 also states that it is the policy of the state that eligible renewable energy resources and zero-carbon resources supply 100% of the retail sales of electricity to California. This bill requires th at the achievement of 100% zero- carbon electricity resources does not increase the carbon emissions elsewhere in the western grid and that the achievement not be achieved through resource shuffling.

Consequently, utility energy generation from non -renewable resources is expected to be reduced based on implementation of the 60% RPS in 2030. Therefore, any project’s reliance on nonrenewable energy sources would also be reduced.

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Assembly Bill 1007 (2005)
AB 1007 (2005) required the CEC to prepare a statewide p lan to increase the use of alternative fuels in California (State Alternative Fuels Plan). The CEC prepared the plan in partnership with the California Air Resources Board (CARB) and in consultation with the other state, federal, and local agencies. The pl an assessed various alternative fuels and developed fuel portfolios to meet California’s goals to reduce petroleum consumption, increase alternative fuels use, reduce GHG emissions, and increase in -state production of biofuels without causing a significant degradation of public health and environmental quality.

Assembly Bill 32 (2006) and Senate Bill 32 (2016)
In 2006, the Legislature enacted AB 32, the California Global Warming Solutions Act of 2006. AB 32 requires California to reduce its GHG emissions to 1990 levels by 2020. In 2016, the Legislature enacted SB 32, which extended the horizon year of the state’s codified GHG reduction planning targets from 2020 to 2030, requiring California to reduce its GHG emissions to 40% below 1990 levels by 2030. In ac cordance with AB 32 and SB 32, CARB prepares scoping plans to guide the development of statewide policies and regulations for the reduction of GHG emissions. Many of the policy and regulatory concepts identified in the scoping plans focused on increasing e nergy efficiencies and the use of renewable resources and reducing the consumption of petroleum -based fuels (such as gasoline and diesel). As such, the state’s GHG emissions reduction planning framework creates co-benefits for energy-related resources. Additional information on AB 32 and SB 32 is provided in Section 3.7 of this EIR.

California Building Standards
Part 6 of Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and regulate California’s building standards. Part 6 establishes energy efficiency standards for residential and non -residential buildings constructed in California to reduce energy demand and consumption. Part 6 is updated periodically to incorporate and consider new energy efficiency technologies and methodologies. The 2016 Title 24 building energy efficiency standards, which became effective on January 1, 2017, further reduce energy used in the state. In general, single family homes built to the 2016 standards are anticipated to use approximately 28% less energy for lighting, heating, cooling, ventilation, and water heating than those built to the 2013 standards (CEC 2015).

The 2019 Title 24 standards were approved and adopted by the California Building Standards Commission in December 201 8. The 2019 standards became effective January 1, 2020. The standards require that all low -rise residential buildings shall have a photovoltaic system meeting the minimum qualification requirements such that annual electrical output is equal to or greater than the dwelling’s annual electrical usage. Notably, net energy metering rules limit residential rooftop solar generation to produce no more electricity than the home is expected to consume on an annual basis. Single -family homes built with the 2019 stand ards will use about 7% less energy due to energy efficiency measures versus those built under the 2016 standards, while new nonresidential buildings will use about 30% less energy mainly to lighting upgrades (CEC 2018).

The 2022 Building Energy Efficiency Standards (Energy Code) will improve upon the 2019 Energy Code for new construction of, and additions and alterations to, residential and nonresidential buildings. Workshops will be held to present revisions and obtain public comment. Proposed standards will be adopted in 2021 with an effective date of January 1, 2023. The California Energy Commission (CEC) updates the standards every three years.

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Title 24, Part 11. In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as CALGreen, and establishes minimum mandatory standards as well as voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material 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 2016 standards became effective on January 1, 2017. The mandatory standards require mandatory reduction in indoor and outdoor water use, diversion of demolition waste, mandatory inspections of energy systems, inclusion of electric vehicle charging stations for designated parking spaces and use of low -pollutant-emitting exterior and interior finish materials. The CALGreen 2019 standards will continue to improve upon the 2016 CALGreen standards and will go into effect on January 1, 2020.

Integrated Energy Policy Report
Senate Bill 1389 (SB 1389, Bowen and Sher, Chapter 568, Statutes of 2002) requires the California Energy Commission to conduct assessments and forecasts of all aspects of energy industry supply, production, transportatio n, delivery and distribution, demand, and prices. The Energy Commission shall use these assessments and forecasts to develop energy policies that conserve resources, protect the environment, ensure energy reliability, enhance the state's economy, and prote ct public health and safety. (Pub. Res. Code § 25301(a)).

The California Energy Commission adopts an Integrated Energy Policy Report (IEPR, pronounced eye'- per) every two years and an update every other year. The most current report is the 2021 Integrated Energy Policy Report Update.

State Vehicle Standards
In a response to the transportation sector accounting for more than half of California’s carbon dioxide (CO
2) emissions, AB 1493 was enacted in 2002. AB 1493 required CARB to set GHG emission standards f or passenger vehicles, light -duty trucks, and other vehicles determined by the state board to be vehicles whose primary use is noncommercial personal transportation in the state.

The bill required that CARB set GHG emission standards for motor vehicles man ufactured in 2009 and all subsequent model years. The 2009–2012 standards resulted in a reduction in approximately 22% GHG emissions compared to emissions from the 2002 fleet, and the 2013 –2016 standards resulted in a reduction of approximately 30%.

In 2012, CARB approved a new emissions -control program for model years 2017 through 2025. The program combines the control of smog, soot, and global warming gases and requirements for greater numbers of zero -emission vehicles into a single package of standards called Advanced Clean Cars.

By 2025, when the rules would be fully implemented, new automobiles would emit 34% fewer global warming gases and 75% fewer smog-forming emissions (CARB 2012).

Although the focus of the state’s vehicle standards is on the reducti on of air pollutants and GHG emissions, one co-benefit of implementation of these standards is a reduced demand for petroleum - based fuels.

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Sustainable Communities Strategy
The Sustainable Communities and Climate Protection Act of 2008, or SB 375, coordinat es land use planning, regional transportation plans, and funding priorities to help California meet its GHG emissions reduction mandates. As codified in California Government Code, Section 65080, SB 375 requires metropolitan planning organizations (San Die go Association of Governments) to include a Sustainable Communities Strategy in its regional transportation plan. The main focus of the Sustainable Communities Strategy is to plan for growth in a fashion that will ultimately reduce GHG emissions, but the s trategy is also a part of a bigger effort to address other development issues within the general vicinity, including transit and VMT, which influence the consumption of petroleum - based fuels.

Local
SDG&E Long-Term Procurement Plan
SDG&E’s Conforming Portfolio identifies a need for approximately 700 gigawatt -hours of incremental renewable power in addition to the assumed increases in energy efficiency and behind -the-meter solar, to meet the 2030 planning target (approximately 4% of the total energy in the portfolio) (SDG&E 2018). SDG&E’s Conforming Portfolio demonstrates that SDG&E has reduced its GHG emissions in the early years of the planning period, reflecting SDG&E’s current position in relation to its RPS targets, with approximately 45% of its current e nergy mix coming from delivering renewable resources in 2018 as compared to an RPS requirement of 29%, its aggressive adoption of energy storage, and no coal resources. SDG&E is fully compliant with RPS and long -term contracting requirements. SDG&E continu es to procure to meet resource -specific renewable procurement mandates, as required, but does not expect to procure additional resources for RPS compliance purposes until after 2030. SDG&E is forecasted to reach 49% renewable energy in 2021, 98% of which will be from long-term contracts (SDG&E 2018).

City of San Marcos General Plan
The City’s General Plan (City of San Marcos 2012) includes various policies related to reducing GHG emissions and the co -benefit of reducing energy consumption. Applicable policies include the following:

Land Use and Community Design Element
• Policy LU -2.1: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use. • Policy LU -2.3: Promote landscaping ( e.g., native, drought tolerant plants) that minimizes demands on water supply.
• Policy LU -2.7: Promote the instillation of trees to reduce the urban heat -island effect and green infrastructure to reduce storm water runoff.
• Policy LU -3.1: Require that new de velopment and redevelopment incorporate connections and reduce barriers between neighborhoods, transit corridors, and activity centers within the City.

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Conservation and Open Space Element
• Policy COS -4.5: Encourage energy conservation and the use of alterna tive energy sources within the community.
• Policy COS -4.6: Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure, and equipment.

The project’s consistency with applicable General Plan goals and policies is discussed in Table 3.10 - 5 of Section 3.10, Land Use. As detailed in Section 3.10.4, the project is consistent with the applicable General Plan goals and policies pertaining to energy.

City of San Marcos Climate Action Plan
Consistent with AB 32, the City adopted a CAP in September 2013 as a long -range plan to reduce GHG emissions and mitigate climate change impacts associated with City government operations and with implementation of t he City’s General Plan. An updated CAP was adopted on December 8, 2020. The 2020 CAP builds on the efforts and strategies identified in the City’s 2013 CAP, and establishes GHG emission targets and identifies achievable, locally -based actions to reduce GHG emissions from municipal and community activities. Section 3.7, Greenhouse Gas Emissions provides more details on the CAP as it pertains to specific GHG reduction targets.

According to the CAP, energy use in the City includes electricity and natural gas c onsumption, which accounted for 39 percent of the City’s total emissions in 2012. Two strategies would reduce emissions from electricity and natural gas consumption by increasing building energy efficiency and the use of renewable energy sources. Legislative reductions from State energy efficiency and renewable energy programs will contribute to reducing transportation emissions by increasing the amount of renewable energy available statewide and improving energy efficiency requirements for new developments . At the local level, GHG emissions reductions would be achieved by improving energy efficiency of new developments beyond State requirements, both increasing the amount of renewable energy generated locally, and reducing the amount of non -renewable energy consumed locally. The success of these strategies relies on coordination with local utilities, organizations, and agencies, participation from the community, and administration of new or revised local policies and programs.

The CAP outlines strategies and measures that the City will undertake to achieve its proportional share of State GHG emissions reduction targets . Strategies and measures related to energy include the following:
• Strategy 4: Increase Building Energy Efficiency Electricity and natural gas consumption in buildings accounts for a majority of GHG emissions from the energy sector. Although legislative reductions related to State actions will help reduce emissions associated with building energy, additional reductions are achievable by increasin g building efficiency in the City. This strategy aims to reduce emissions by reducing energy used by residential consumers through increased energy efficiency. This strategy includes one measure that would reduce the City’s emissions by approximately 1,280 MTCO2e in 2030. o Measure E -1: Require New Residential Developments to Install Alternatively -Fueled Water Heaters. Starting in 2022, require all new single-family and multi-family residential projects to install non -natural gas water heaters. Non -natural gas water heater options

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include electric HPWH, instantaneous electric, electric tank solar water heater with HPWH backup, or solar water heater with electric tank backup • Strategy 5: Increase Renewable and Zero -Carbon Energy: Over a quarter of the City’s GHG emissions in 2012 were generated through the consumption of fossil fuels for the purpose of electricity generation (i.e., natural gas —fired or coal power plants). Transitioning from fossil fuels to renewable energy electricity generation will reduce emiss ions and provide a more sustainable source of electricity. The City would reduce emissions by increasing renewable energy generated locally and participating in a community choice aggregation (CCA) or similar program to increase the amount of grid supplied renewable energy. This strategy includes two measures that would reduce the City’s emissions by approximately 35,100 MTCO2e in 2030. Additional activities that would support this strategy would occur through partnerships with local and regional agencies.
o Measure E-2: Require Installation of PV systems at New Non -Residential Developments.

Starting in 2022, require all new non -residential developments to install PV systems with a minimum of two watts per square foot of gross floor area. o Measure E -3: Increase Grid-Supply Renewable and Zero- Carbon Electricity . Join a program to increase grid -supply renewables and zero- carbon electricity to 95 percent by 2030 with a maximum customer opt-out rate of three percent.

3.5.3 Thresholds of Significance
According to Appendix G of the State CEQA Guidelines, the proposed project would have a significant impact related to energy if it would:
• Threshold #1: Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation.
• Threshold #2: Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

3.5.4 Project Impact Analysis
Threshold #1: Would the project result in potentially significant environmenta l impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Electricity
Construction Use
Temporary electric power for as -necessary lighting and electronic equipment (such as computers inside temporary construction trailers and heating, ventilation, and air conditioning) would be provided by SDG&E. The amount of electricity used during construction would be minimal because typical demand stems from the use of electronic equipment in addition to electrically powered hand tools. The majority of the energy used during construction would be from petroleum. The electricity used for construction activities would be temporary and minimal; therefore, impacts would be less than significant.

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Operational Use
At full build- out, the proposed project’s operational phase would require electricity for operating the residences. The California Emissions Estimator Model (CalEEMod), version 2016.3.2, default values for electricity consumption for the residential land use were applied . Per the GHG report, electrical energy-intensity factors were updated to reflect SDG&E emissions rate variations from 2009 which are default in CalEEMod. In 2009, SDG&E achieved 10.5 percent procurement of renewable energy and in 202 0 will have at least a 33% portfolio by law. In accordance with SB 100, SDG&E will achieve an RPS of 60% in 2030. Emission factors used in the model are included in the GHG report in Appendix H.1 (LDN 2021b).

The proposed project is estimated to have a total electrical demand of approximately 767,483 kWh per year, which is based on CalEEMod. The proposed project includes various on -site features and measures to reduce the proposed project’s energy consumption. Further, the proposed project would be required to be consistent with appropriate mandatory project design feature in the CAP Consistency Worksheet that would reduce operational electricity consumption (details are provided in Appendix H.1 of this EIR) and would-be built-in compliance with Title 24 requirements applicable at that time. Based on the 2019 standards, homes built under the 2019 Title 24 standards would use about 53% less energy than those under the 2016 Title 24 standards (CEC 2018) because 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.

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 efficient lighting in all buildings and light control systems, where practical, which would reduce lighting energy by 20%. Thus, environmental impacts related to operational electricity use would be less than significant.

Natural Gas
Construction Use
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; therefore, impacts would be
less than significant.

Operational Use
No hearths or woodstoves would be included in the project design. Any minor amounts of natural gas that may be consumed during operation would be negligible and would not have an adverse effect on the environment; therefore, impacts would be less than significant. Further, the proposed proje ct 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 would meet Title 24 requirements applicable at that time, as required by state regulations through their plan review process. The proposed project would implement energy efficiency design features and would not result in a wasteful use of energy. Therefore, environmental impacts from natural gas consumption would be
less than significant

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Petroleum
Construction Use
Petroleum would be consumed throughout construction of the proposed project. Fuel consumed by construction equipment would be the primary energy resource expended over the course of construction, and VMT associated with the transportation of construction materials and construction worker commutes would also result in petroleum consumption. Heavy -duty construction equipment associated with construction activities, as well as haul trucks involved in moving dirt around the project site, would rely on diesel fuel. Construction workers would travel to and from the project site throughout the duration of construction. It is assumed that construction workers would travel to and from the project site in gasoline-powered vehicles.

Heavy-duty construction equipment of various types would be used during each phase of construction. CalEEMod was used to estimate construction equipment usage, and results are included in Appendix H.1. Based on that analysis, ov er all phases of construction, diesel -fueled construction equipment would operate for an estimated 24,365 hours, as summarized in Table 3.5-

2. Table 3.5-2 Hours of Operation for Construction Equipment Phase Hours of
Equipment Use Number of Days Total
Rock Drilling 3 5 15
Site Preparation 56 10 560
Grading 72 30 2,160
Paving 48 20 960
Building Construction 68 300 20,400
Architectural Coating 6 45 270
Total 410 24,365
Source: LDN 2021, GHG Assessment, Attachment A- CalEEMod Emission Model (App H.1) Fuel consumption from construction equipment was estimated by converting the total CO 2 emissions from each construction phase to gallons using conversion factors for CO 2 to gallons of g asoline or diesel. Construction is estimated to occur over an 18 -month period (2022 –2024) based on the construction phasing schedule. The conversion factor for gasoline is 8.78 kilograms per metric ton CO2 per gallon, and the conversion factor for diesel i s 10.21 kilograms per metric ton CO 2 per gallon (The Climate Registry 2018). The estimated diesel fuel use from construction equipment is shown in Table 3.5-3.

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Table 3.5-3 Construction Equipment Diesel Demand
Phase Equipment CO2 (MT) Kg CO2/ Gallon Gallons
Rock Drilling 0.777 10.21 76.10
Site Preparation 16.7197 10.21 1,637.58
Grading 90.8452 10.21 8,897.67
Paving 20.0269 10.21 1,961.50
Building Construction 347.7245 10.21 34,057.25
Architectural Coating 5.7448 10.21 562.66
Total 47,192.76
Source: LDN 2021, GHG Assessment, Attachment A- CalEEMod Emission Model (App H.1) Notes: CO2 = carbon dioxide;
kg = kilogram;
MT = metric ton
1 MT = 1,000 kg
Fuel consumption from worker and vendor trips is estimated by converting the total CO 2 emissions from each construction phase to gallons using the conversion factors for CO 2 to gallons of gasoline or diesel. Worker vehicles are assumed to be gasoline fueled, and vendor/hauling vehicles are assumed to be diesel fueled. Calculations for total worker, vendor, and hauler fuel consumption are provided in Tables 3.5-4, 3.5-5, and 3.5-6.

Table 3.5-4 Construction Worker Vehicle Gasoline Demand Phase Vehicle CO2 (MT) Kg CO2/ Gallon Gallons
Rock Drilling 0.506 8.78 57.63
Site Preparation 0.6074 8.78 69.18
Grading 2.2749 8.78 259.10
Paving 0.9736 8.78 110.89
Building Construction 115.6359 8.78 13,170.38
Architectural Coating 3.3670 8.78 383.49
Total 14,050.66
Source: LDN 2021, GHG Assessment, Attachment A- CalEEMod Emission Model (App H.1) Notes: CO2 = carbon dioxide;
kg = kilogram;
MT = metric ton

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1 MT = 1,000 kg
Table 3.5-5 Construction Vendor Truck Diesel Demand
Phase Vehicle CO2 (MT/YR) Kg CO2/ Gallon Gallons
Building Construction 75.6084 10.21 7,405.33
Total 7,405.33
Source: LDN 2021, GHG Assessment, Attachment A- CalEEMod Emission Model (App H.1) Notes: CO2 = carbon dioxide;
kg = kilogram;
MT = metric ton
1 MT = 1,000 kg
Table 3.5-6 Construction Haul Truck Diesel Demand
Phase Vehicle CO2 (MT) Kg CO2/ Gallon Gallons
Site Preparation 54.4180 10.21 5,329.87
Grading 159.9327 10.21 15,664.32
Total 20,994.19
Source: LDN 2021, GHG Assessment, Attachment A- CalEEMod Emission Model (App H.1) Notes: CO2 = carbon dioxide;
kg = kilogram;
MT = metric ton
1 MT = 1,000 kg
As shown in Tables 3.5 -4 through 3.5 -6, the proposed project is estimated to consume a total of 42,450.18 gallons of petroleum from worker vehicle, vendor truck, and haul truck trips per year during the construction phase. By comparison, California’s estim ated gasoline use was approximately 16 billion gallons of gasoline in 2016 (CARB 2018). The proposed project would be required to comply with CARB’s Airborne Toxics Control Measure, which restricts heavy -duty diesel vehicle idling time to 5 minutes. Furthe rmore, the project’s construction practices would be typical (i.e., not require specialized construction equipment or otherwise present unusual circumstances in which substantial amounts of fuels would be required). Therefore, because petroleum use during construction, including construction of the proposed project, would be temporary and minimal and would not be wasteful or inefficient, impacts would be less than significant.

Operational Use
The majority of fuel consumption resulting from the proposed proj ect’s operational phase would be attributable to the use of resident motor vehicles traveling to and from the project site, as well as fuels used for alternative modes of transportation that may be used by residents, visitors, and employees. Petroleum fuel consumption associated with motor vehicles traveling to and from the project site is a function of VMT as a result of project operation. As reported in the greenhouse gas study (Appendix H.1), the annual VMT attributable to the proposed project is expecte d to be approximately 2,108,639 VMT per year. Similar to construction worker and vendor trips, fuel consumption was estimated by converting the total CO
2 emissions from each land use type
(687.2716 MT/yr) to gallons using the conversion factors for CO 2 to gallons of gasoline or diesel.

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Based on the annual fleet mix provided in CalEEMod, 93% of the fleet range from light -duty to medium-duty vehicles and motorcycles were assumed to run on gasoline. The remaining 7% of vehicles represent medium-heavy duty to heavy-duty vehicles and buses/recreational vehicles, which were assumed to run on diesel.

Calculations for annual mobile-source fuel consumption are provided in Table 3.5-7.

Table 3.5-7 Mobile Source Fuel Consumption - Operation
Fuel Vehicle CO2 (MT) Kg CO2/ Gallon Gallons
Gasoline 639.1626 8.78 72,797.56
Diesel 48.10901 10.21 4,711.95
Total 687.2716 77,509.51
Source: LDN 2021, GHG Assessment, Attachment A- CalEEMod Emission Model (App H.1) Notes: CO2 = carbon dioxide;
kg = kilogram;
MT = metric ton
1 MT = 1,000 kg
As shown in Table 3.5 -7, mobile sources from the proposed project would result in approximately 72,798 gallons of gasoline per year and 4.712 gallons of diesel consumed per year. By comparison, California as a whole consumed approximately 16 billion gallon s of petroleum in 2016 (CARB 2018) and the County is expected to use 2.0 billion gallons of petroleum per year for transportation in 2020 (Caltrans 2009).

Over the lifetime of the proposed project, the fuel efficiency of the vehicles being used by residents is expected to increase. As such, the amount of petroleum consumed as a result of vehicular trips to and from the project site during operation would decrease over time. There are numerous regulations in place that require and encourage increased fuel ef ficiency. For example, CARB has adopted an approach to passenger vehicles by combining the control of smog-causing pollutants and GHG emissions into a single, coordinated package of standards. The approach also includes efforts to support and accelerate th e numbers of plug -in hybrids and zero- emissions vehicles in California (CARB 2013).

The California Air Pollution Control Officers Association (CAPCOA) has developed methodologies for quantifying the emission reductions associated with numerous mitigation m easures (CAPCOA 2010).

Several of the measures would also reduce air pollutant emissions that are related to land use and transportation planning. These measures would reduce vehicle trips and/or trip lengths, enhance walking and bicycles as alternative modes of transportation, enhance availability of transit, and incorporate other approaches. Regarding mobile source emission reduction features relating to land use, it was assumed that the project would involve an increase in access to transit. The project is located approximately 0.7 mile from the bus service and one mile from the SPRINTER station, which provides light rail access into the nearby cities of Escondido, Vista, and Oceanside. Additionally, the SPRINTER connects to the Pacific Surfliner and COAS TER routes, which provide north –south access to Los Angeles County, Orange County, and the City of San Diego. The project will provide three Level 2 electric charging station in the guest parking area and each residential garage would be pre -wired for electric vehicle charging stations.

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In summary, although the proposed project would increase petroleum use during operation, the use would be a small fraction of the statewide use and, due to efficiency increases, diminish over time.

Additionally, the increased access to transit would help reduce petroleum -based fuels consumption.

Given these considerations, petroleum consumption associated with the proposed project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, and impacts would be less than significant.

Threshold #2: Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
The proposed project would follow applicable energy standards and regulations during the construction phases. Furthermore, the proposed project would be built and operated in accordance with all existing, applicable building regulations at the time of construction. Furthermore, the proposed pro ject would be consistent with all actions in the CAP Consistency Worksheet as discussed in detail in Appendix H.2 of this EIR. For the reasons stated, the proposed project would not obstruct a state or local plan for renewable energy or energy efficiency, and impacts would be less than significant.

3.5.5 Cumulative Impact Analysis
Potential cumulative impacts on energy would result if the proposed project, in combination with past, present, and future projects, would result in the wasteful or inefficient use of e nergy. This could result from development that would not incorporate sufficient building energy efficiency features, would not achieve building energy efficiency standards, or would result in the unnecessary use of energy during construction and/or operation. The cumulative projects within the areas serviced by the energy service providers would be applicable to this analysis; this includes existing aging structures that are energy inefficient. Projects that include development of large buildings or other structures that would have the potential to consume energy in an inefficient manner would have the potential to contribute to a cumulative impact. Projects that would mostly include construction, such as transportation infrastructure, could also contribute to a cumulative impact; however, the impact of these projects would be limited because they would typically not involve substantial ongoing energy use.

As described previously, the proposed project would not result in significant environmental impacts due to wasteful, inefficient, or unnecessary use of energy due to various design features and adherence to applicable requirements. Similar to the proposed project, the cumulative projects would be subject to CALGreen, which provides energy efficiency standards for commercial and residential buildings. CALGreen would implement increasingly stringent energy efficiency standards that would require the proposed project and the cumulative projects to minimize the wasteful and inefficient use of energy. In addition, cumulative projects would be required to meet or exceed the Title 24 building standards, further reducing the inefficient use of energy. Future develop ment would also be required to meet even more stringent requirements, including the objectives set in the AB 32 Scoping Plan. Furthermore, various federal and state regulations, including the Low Carbon Fuel Standard, Pavley Clean Car Standards, and Low Em ission Vehicle Program, would serve to reduce the transportation fuel demand of cumulative projects. In consideration of cumulative energy use, the proposed project would not conflict with or obstruct a state or local plan for renewable energy or energy ef ficiency. Thus, the proposed project would not contribute to a cumulative impact to the wasteful or inefficient use of energy. As such, the proposed project would not result in a cumulatively considerable contribution to a potential cumulative impact.

Impacts are less than significant.

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3.5.6 Mitigation Measures
Impacts would be less than significant, and no mitigation measures are required.

3.5.7 Conclusion
The proposed project would comply with regulatory requirements and building standards. As such, the proposed proj ect would not result in the wasteful or inefficient use of electricity, and impacts would be less than significant.

Additionally, the proposed project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing ene rgy consumption, including the City’s General Plan policies.

As a result, impacts would be less than significant.

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3.6 Geology and Soils
This section analyzes the potential for impacts related to geology and soils for the pr oposed project, including seismic activity, liquefaction, landslides, loss of topsoil, soil erosion, soil stability and soil expansion.

The following report has been prepared to analyze the geological and geotechnical impacts of the proposed project and is included in its entirety in
Appendix G of this Draft Environmental Impact
Report (EIR):
• Geotechnical Investigation – 943 Barham Drive San Marcos, California . Prepared by GEOCON. Dated June 17, 2020
During the Initial Study checklist prepared for the proposed project, it was also determined that there would be no impact associated with the ability of soils to support the use of septic or alternative wastewater systems as no septic or alternative wastewater systems are included as part of the project. Since the proposed project would be served by Vallecitos Water District for sewer service, no septic or alternative wastewater systems are proposed. Section 5. 2, Environmental Effects Found Not to be Significant – Geology and Soils, of this EIR provides additional information on these topics.

The Initial Study is included as Appendix B.1 of this document.

A summary of the project - and cumulative-level geology and soils analysis, by threshold, is provided in Table 3.6-1.

Table 3.6-1. Geology and Soils Summary of Impacts
Threshold of Significance Project-Level
Impact
Cumulative-
Level Impact
Impact After
Mitigation
#1 - Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving:

Rupture of a known earthquake fault, as
delineated on the most recent Alquist-
Priolo Earthquake Fault Zoning map,
issued by the State Geologist for the area
or based on other substantial evidence of
a known fault?
Less than
Significant
Less than
Significant
Less than
Significant
#2 - Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving
strong seismic ground shaking?
Less than
Significant
Less than
Significant
Less than
Significant
#3 - Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving
seismic-related ground failure, including
liquefaction?
Less than
Significant
Less than
Significant
Less than
Significant
#4 - Directly or indirectly cause potential
substantial adverse effects, including the
Less than
Significant
Less than
Significant
Less than
Significant

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Threshold of Significance Project-Level
Impact
Cumulative-
Level Impact
Impact After
Mitigation
risk of loss, injury, or death involving
landslides?
#5 - Result in substantial soil erosion or
the loss of topsoil?
Less than
Significant
Less than
Significant
Less than
Significant
#6 - Be located on a geologic unit or soil
that is unstable, or that would become
unstable as a result of the project, and
potentially result in on- or off-site landslide,
lateral spreading, subsidence, liquefaction,
or collapse?
Less than
Significant
Less than
Significant
Less than
Significant
#7 - Be located on expansive soil, as
defined in Table 18-1-B of the Uniform
Building Code (1994), creating substantial
risks to life or property?
Less than
Significant
Less than
Significant
Less than
Significant
#8 - Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
Potentially
Significant
Less than
Significant
Mitigated to Less
than Significant

3.6.1 Existing Conditions
This section details the existing conditions on the project site including topography, soils, groundwater, and the project site’s location to major faults.

Topography
The site consists of a northwest trending drainage with moderate to steep slopes along the flanks.

Elevations range from 710 feet Above Mean Sea Level (AMSL) in the southeast portion of the site to 650 feet AMSL in the northwest portion.

Soils
Regionally, the subject property lies within the Peninsular Ranges Geomorphic Province of southern California. This province consists of a series of ranges separated by northwest trending valleys; sub parallel to branches of the San Andreas Fault (CGS 2002). The Peninsular Ranges geomorphic province, one of the largest geomorphic units in western North America, extends from the Transverse Ranges geomorphic province and the Los Angeles Basin, south to Baja California. It is bound on the west by the Pacific Ocean, on the south by the Gulf of California and on the east by the Colorado Desert Province.

The Peninsular Ranges are essen tially a series of northwest -southeast oriented fault blocks (CGS 2002). Major fault zones and subordinate fault zones found in the Peninsular Ranges Province typically trend in a northwest-southeast direction.

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Four surficial soil types and one geologic fo rmation were encountered during our field investigation.

The surficial soil types consist of undocumented fill, topsoil, alluvium, and colluvium. The formational unit is the Cretaceous-age granitic rock.

As part of the geotechnical investigation, GEOCON used the following methods:
• Review of aerial photographs, readily available published and unpublished geologic literature, and project plans;
• Excavation of 14 exploratory trenches using a rubber tire backhoe to evaluate the general extent and condition of surficial deposits;
• Performance of laboratory tests on selected soil samples to evaluate the physical characteristics for engineering analysis;
• Performance of Eight (8) seismic traverses by Southwest Geophysics to evaluate the rippability characteristics in areas of granitic rock; and • Performance of one infiltration test in the proposed basin location to be utilized during storm water management design and providing storm water management guidelines in accordance with the City of San Marcos Storm Water Standards.

Undocumented Fill
Undocumented fill was observed in one exploratory trench (T -4), and is estimated to be approximately one-foot thick. The Qudf consists of loose, moist, silty sand, with some minor trash debris. This material is unsuitable for support of settlement -sensitive structures and/or improvements, and will require complete removal and compaction. It is estimated that the undocumented fill is confined to a relatively small area in the north-central portion of the property.

Topsoil (Unmapped)
Topsoil was encountered in five exploratory trenches ( Trench Nos. T -1, T-2, T -12, T -13, and T -14).

This deposit is estimated to blanket the property beyond the main northwest -trending drainage and varies in thickness from approximately one to five feet. This surficial soil is characterized as loose, damp to moist, silty fine - to medium-grained sand. Topsoil is unsuitable in its present condition and will require removal and compaction for support of structural fill and settlement-sensitive structures.

Alluvium/ Colluvium (Qal/Qcol)
Alluvial and colluvial soils were encountered in eight exploratory trenches ( Trench Nos. T -3 and T -5 through T-11). These deposits are present along the entire length of the northwest -trending drainage and adjacent hillsides, and vary in thickness from approximately 3 to 11 -feet-thick. These deposits generally consisted of loose to dense, damp to moist, silty to clayey fine - to coarse-grained sand. A firm, silty clay deposit was encountered in T -3 and T -4. The upper portions of the a lluvial/colluvial deposits are poorly consolidated and compressible, and will require removal and compaction during grading. Based on laboratory testing, the lower portion of these deposits are generally suitable in their present condition for support of structural fill and settlement-sensitive structures.

Granitic Rock (Kgr)
Cretaceous-age granitic rock underlies the surficial deposits throughout the property. The soils derived from excavations within the decomposed portion of this unit typically consist o f low -

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expansive, silty, fine- to coarse -grained sands and provide suitable foundation support in either a natural or properly compacted condition. Deeper excavations than what we encountered in the trenches may generate boulders and oversize material (rocks greater than 12 inches in dimension) that will require special handling and placement.

Groundwater
No groundwater or seepage was observed in the excavations performed during the geologic investigation.

Seismicity
The project site is located in tectonically active southern California, and will likely experience some effects from future earthquakes even though no Alquist -Priolo Fault Hazard Zones are located within the site. The type of severity of seismic hazards affecting the project site is chiefly dependent upon the distance to the causative faults, the intensity and duration of the seismic events, and the onsite soil characteristics. The seismic hazard may be primary, such as surface rupture and/or ground shaking, or secondary, such as liquefaction or land sliding.

Surface fault rupture is a break in the ground surface during, or as a consequence of, seismic activity. Fault rupture occurs most often along pre-existing fault traces. According to the geotechnical investigation, the United States Geological Survey maps (2016) indicates that there are no mapped Quaternary faults crossing or trending toward the property. In addition, the site is not located within a currently established Alquist-Priolo Earthquake Fault Zone. The nearest known act ive-fault zones are the Rose Canyon and Newport Inglewood Faults, located approximately 14 miles west of the subject site. The risk associated with ground rupture hazard is low (GEOCON 2020).

Liquefaction
Liquefaction occurs when loose, saturated, generall y fine sands and silts are subjected to strong ground shaking. The soils lose shear strength and become liquid; potentially resulting in large total and differential ground surface settlements as well as possible lateral spreading during an earthquake. Seismically induced settlement can occur in response to liquefaction of saturated loose granular soils, as well as the reorientation of soil particles during strong shaking of loose, unsaturated sands.

The project site is identified as having Zero Susceptibil ity to Low Susceptibility for liquefaction per Figure 6-1 of the Safety Element of the City’s General Plan . The risk associated with liquefaction and seismically induced settlement hazard is low due to the dense nature and age of the underlying formational materials and lack of shallow groundwater (GEOCON 2020).

Paleontological Resources
The proposed project site lies within the Peninsular Ranges Geomorphic Province of southern California. This province consists of a series of ranges separated by northwest trending valleys; subparallel to branches of the San Andreas Fault (CGS 2002). The Peninsular Ranges geomorphic province is one of the largest geomorphic units in western North America, extends from the Transverse Ranges geomorphic province and t he Los Angeles Basin, south to Baja California . It is bound on the west by the Pacific Ocean, on the south by the Gulf of California and on the east by the Colorado Desert Province . Peninsular Ranges are essentially a series of northwest -southeast

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oriented fault blocks (CGS 2002) . Major fault zones and subordinate fault zones found in the Peninsular Ranges Province typically trend in a northwest-southeast direction.

According to the Preliminary Geotechnical Evaluation prepared for the project (Geocon), the geologic conditions underlying the site consist of undocumented artificial soils (Qudf), and Quaternary -aged colluvial and alluvium deposits (Qcol and Qal)). Cretaceous -age granitic rock underlies the surficial deposits throughout the property. Colluvial d eposits were encountered along the entire length of the northwest trending drainage and adjacent hillsides, and vary in thickness from approximately 3 to 11 feet thick. The Quaternary Period is divided into two epochs: the Pleistocene (2.588 million years ago to 11.7 thousand years ago) and the Holocene (11.7 thousand years ago to today).

According to the San Marcos General Plan EIR (page 3.12 -1), older Pleistocene-age alluvial deposits have the potential to yield “Ice -age” fossils. In composition, these de posits consist of “moderately well consolidated, poorly sorted, permeable, commonly slightly desiccated gravel, sand, silt, and clay- bearing alluvium.” These Pleistocene alluvial deposits are locally capped by Holocene alluvium and artificial fill, and at depth, are underlain by Cretaceous and older igneous rocks. Pleistocene old alluvial flood plain deposits are found in northern San Diego County and include recorded fossil collecting localities in Vista, Carlsbad, and Oceanside. These localities have yiel ded fossils of terrestrial plants, freshwater and terrestrial invertebrates such as clams and snails, and terrestrial mammals such as ground sloth, rodents, horse, tapir, camel, llama, deer, mastodon, and mammoth.

Given that no fossils have been recovered from the sediments mapped as old alluvial flood plain deposits in the City, it is suggested that these deposits have an unproven and/or undetermined paleontological sensitivity. Due to the fact that the Pleistocene old alluvial floodplain deposits have an unproven/undetermined sensitivity there is a potential that the site could contain paleontological resources.

3.6.2 Regulatory Setting
This section describes the federal, state, and local regulations related to geology and soils.

Federal
Federal Disaster Mitigation Act of 2000
The Disaster Mitigation Act of 2000 provides a set of mitigation plan requirements that emphasize State and local jurisdictions to coordinate disaster mitigation planning and implementation. States are encouraged to complete a “Standard” or an “Enhanced” Natural Mitigation Plan. “Enhanced” plans demonstrate increased coordination of mitigation activities at the State level, and if completed and approved, will increase the amount of funding through the Hazard Mitigation Grant Program.

California’s updated State Hazard Mitigation Plan was adopted and approved by the Federal Emergency Management Agency (FEMA) Region IX in 2007. The City of San Marcos is one of the communities covered by the 2004 County of San Diego Multi- Jurisdictional Hazard Mitigation Plan, which is a countywide plan that identifies risks posed by natural and manmade disasters.

Federal Response Plan
The Federal Response Plan of 1999 is a signed agreement among 27 federal departments and agencies, including the American Red C ross, that (1) provides the mechanism for coordinating delivery of federal assistance and resources to augment efforts of state and local governments overwhelmed by a major disaster or emergency; (2) supports implementation of the Robert T.

Stafford Disaster Relief and Emergency Act, as well as individual agency statutory authorities; and (3)

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supplements other federal emergency operations plans developed to address specific hazards. The Federal Response Plan is implemented in anticipation of a significant e vent likely to result in a need for federal assistance or in response to an actual event requiring federal assistance under a presidential declaration of a major disaster or emergency.

USGS Landslide Hazard Identification Program
The United States Geologic al Survey (USGS), in fulfillment of the requirements of Public Law 106 - 113, created the National Landslide Hazards Program to reduce long -term losses from landslide hazards by improving understanding of the causes of ground failure and suggesting mitigatio n strategies. FEMA is the responsible agency for the long-term management of natural hazards.

International Building Code
The International Building Code (IBC) is a model building code developed by the International Code Council that provides the basis for the CBC. The purpose of the IBC is to provide minimum standards for building construction to ensure public safety, health, and welfare. Prior to the creation of the IBC, several different building codes were used; however, by the year 2000, the IBC had re placed these previous codes. The IBC is updated every 3 years.

State
Alquist-Priolo Earthquake Fault Zoning Act
The Alquist -Priolo Earthquake Fault Zoning Act is the State law that focuses on hazards from earthquake fault zones. The purpose of this law is to mitigate the hazard of surface fault rupture by regulating structures designated for human occupancy near active faults. As required by the act, the California Geological Survey has delineated Earthquake Fault Zones along known active faults in California.

California Geologic Survey
The California Geologic Survey provides guidance with regard to seismic hazards. The California Geologic Survey’s Special Publication 117A, Guidelines for Evaluating and Mitigating Seismic Hazards in California (2008), provid es guidance for evaluation and mitigation of earthquake -related hazards for projects within designated zones of required investigation.

California Surface Mining and Reclamation Act
Enacted to promote conservation and protection of significant mineral deposits, the California Surface Mining and Reclamation Act requires that all cities address in their General Plans the significant aggregate resources classified by the State Geologist and designated by the State Mining and Geology Board. The law also ensures that significant aggregate resources are recognized and considered before land use decisions are made that may compromise the availability of these resources.

Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act (SHMA) was enacted in 1997 to protect the public from the effects of strong ground shaking, liquefaction, landslides, or other ground failure, and from other hazards caused by earthquakes. This act requires the State Geologist to map areas subject to seismic hazards. A geotechnical investiga tion of the site must be conducted and appropriate mitigation measures incorporated into the project design before development permits will be granted.

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Additionally, the Act requires a Standardized Natural Hazards Disclosure Statement form be completed by real estate sellers if a property is within one of the designated natural hazards areas.

Natural Hazards Disclosure Act
The Natural Hazards Disclosure Act (effective June 1, 1998), requires “that sellers of real property and their agents provide prospectiv e buyers with a ‘Natural Hazard Disclosure Statement’ when the property being sold lies within one or more state -mapped hazard areas, including a Seismic Hazard Zone.” SHMA specifies two ways in which this disclosure can be made:
• The Local Option Real Estate Transfer Disclosure Statement as provided in Section 1102.6a of the Civil Code; or
• The Natural Hazard Disclosure Statement as provided in Section 1103.2 of the Civil Code.

The Local Option Real Estate Disclosure Statement can be substituted for the Natural Hazards Disclosure Statement if it contains substantially the same information and substantially the same warning as the Natural Hazards Disclosure Statement. Both the Alquist -Priolo Act and the SHMA require that real estate agents, or sellers of r eal estate acting without an agent, disclose to prospective buyers that the property is located in an Alquist -Priolo Earthquake Fault Zone or Seismic Hazard Mapping Zone.

California Uniform Building Code
The California Code of Regulations (CCR), also known as Title 24, California Building Standards Codes contain the laws regarding the construction of buildings. Title 24, Part 2 of the California Uniform Building Code (UBC) specifies standards for geologic and seismic hazards, other than surface faulting. Chapter 23 of the California UBC addresses seismic safety, and includes regulations for earthquake -resistant design and construction. The 2019 Triennial Edition of the California Building Standards Code went into effect January 1, 2020.

Local
County of San Diego Multi-Jurisdictional Hazard Mitigation Plan To comply with the Disaster Mitigation Act of 2000, the County of San Diego prepared the Multi - Jurisdictional Hazard Mitigation Plan in 2010. The plan serves as both a county -wide plan and a plan for local jurisdictions that identifies risks posed by natural and human -made disasters before a hazard event occurs. The plan includes overall goals and objectives shared by many jurisdictions, as well as specific goals, objectives, and mitigation action items for each of the participating jurisdictions, including the City of San Marcos, developed to help minimize the effects of the specified hazards that potentially affect their jurisdiction.

San Marcos General Plan Safety Element
The Safety Element of the San Marc os General Plan contains several policies pertaining to natural geologic hazards. The following goal and policies apply to the project:
• Goal S-1: Reduce risks to the community from earthquakes by regulating new development and redevelopment to prevent the creation of new geologic and seismic hazards.

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o Policy S-1.1: Reduce the risk of impacts from geologic and seismic hazards by applying current and proper land use planning, development engineering, building construction, and retrofitting requirements.
o Policy S-1.2: Investigate specific groundwater levels and geologic conditions underlying all new development or redevelopment proposals in areas where potential fault rupture, liquefaction, or other geologic hazards are suspected.

The project’s consistency with applicable General Plan goals and policies is discussed in Section

3.10, Land Use. As detailed in Table 3.10 -1 in Section 3.10, the project is consistent with the applicable goals and policies.

3.6.3 Thresholds of Significance
As defined in Appendix G of the CEQ A Guidelines , project impacts to geological resources are considered significant if the project would:
• Threshold #1: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning map, issued by the State Geologist for the area or based on other substantial evidence of a known fault; • Threshold #2: Directly or indirectly cause potential su bstantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking; • Threshold #3: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction; • Threshold #4: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides;
• Threshold #5: Result in substantial soil erosion or the loss of topsoil; • Threshold #6: Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on - or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse;
• Threshold #7: Be located on expansive soil, as defined in Table 18 -1-B of the Uniform Building Code (1994), creating substantial risks to life or property; • Threshold #8: Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

As noted above, it was determined that there would be no impact associated the ability of soils to support the use of septic or alternative wastewater systems. Section 5.0, Environmental Effects Found Not to Be Significant, provides additional information on this topic. The Initial Study is included in Appendix B.1.

3.6.4 Project Impact Analysis
This section provides a project -level impact analysis for the eight thresholds related to geology and soils. The proposed project will be graded to create multi- family residential building pads and associated infrastructure. Retaining walls up to approximately 11 -feet-high are planned along the

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perimeter of the property. Grading for the project will consist of approximately 39,711 cubic yards (cy) of cut material and 86,052 cy of fill material requiring an import of approximately 46,341 cy of material.

The import and export of earth material is guided by Section 17.32.080 of the City’s Municipal Code and prior to any import of soils, a haul route will be submitted for review and approval by the City Engineer. Additionally, grading and other earth moving activities are restricted to the hours of 7:00 AM and 4:30 PM, Monday through Friday, per Section 17.32.180 of the City’s Municipal Code.

A grading variance is requested for the project as it including slopes that exceed 20 feet in height without benching. Areas where slopes and/or retaining walls are proposed to be greater than 20 feet include the southern extent of development (31.6 -foot maximum slope height), a small area on the western edge of the project site (25.8 -foot maximum slope height) and a portion of the project frontage with E. Barham Drive (22.8-foot maximum slope height with 6 -foot retaining wall). Figure 2- 11 depicts the areas that are proposed to have manufactured slopes without benching in excess of 20 feet in height.

Threshold #1: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury , or death involving: Rupture of a known earthquake fault, as delineated on the most recent Alquist -Priolo Earthquake Fault Zoning map, issued by the State Geologist for the area or based on other substantial evidence of a known fault?
The project site is located within a seismically active region, as is all of southern California; however, the project site not located on or adjacent to any known active faults. According to the California Earthquake Hazard Zone Application, the City of San Marcos is not ide ntified as a jurisdiction affected by Alquist-Priolo Earthquake Fault Zones (California Department of Conservation 2020).

According to the geotechnical investigation, the United States Geological Survey maps (2016) indicates that there are no mapped Quater nary faults crossing or trending toward the property. In addition, the site is not located within a currently established Alquist -Priolo Earthquake Fault Zone.

The nearest known active -fault zones are the Rose Canyon and Newport Inglewood Faults, located approximately 14 miles west of the subject site. The risk associated with ground rupture hazard is low (GEOCON 2020).

Project structures will be designed in accordance with the California Building Code (CBC) (2019 or most current version at time of building ) for resistance to seismic shaking . The project would be constructed in accordance with other CBC criteria, current seismic design specifications of the Structural Engineers Association of California, other applicable regulations, and all applicable requirements of the State of California Occupational Safety and Health Administration (Cal/OSHA).

Additionally, the project would implement all recommendations from the preliminary geotechnical investigation (GEOCON 2020). These recommendations include general provisions related to the site as well as specific recommendations related to soil and excavation characteristics, corrosion, subdrains, toe drains, grading, slope stability, seismic design criteria, foundation and concrete slab - on-grade, retaining walls a nd lateral loads, slope maintenance, and site drainage and maintenance.

The detailed recommendations are included in Chapter 7 of the geotechnical report, which is included as Appendix G of this document.

With adherence to all regulations and recommendations, the project would not expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault. Impacts would be less than significant.

3.6 Geology and Soils
Hallmark-Barham Specific Plan Draft EIR November 2021 City of San Marcos Page 3.6-10
Threshold #2: Directly or in directly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking? The proposed project is located in tectonically -active southern California. The type and magnitude of seismic hazard s affecting the site are dependent on the distance to causative faults, the intensity and the magnitude of the seismic event. Per the geotechnical engineering report (GEOCON 2020), the site is not located within a currently established Alquist -Priolo Earth quake Fault Zone. The nearest known active -fault zones are the Rose Canyon and Newport Inglewood Faults, located approximately 14 miles west of the subject site. The risk associated with ground rupture hazard is low.

As described in Threshold #1, the proje ct would be designed in accordance with the latest CBC, current design specification of the Structural Engineers Association of California, other applicable regulations, all applicable requirements of the State of California Occupational Safety and Health Administration (Cal/OSHA), and recommendations from the preliminary geotechnical investigation (GEOCON 2020). With adherence to all regulations and recommendations, impacts related seismic ground shaking would be less than significant.

Threshold #3: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: Seismic-related ground failure, including liquefaction? Seismic-related Ground Failure
The Preliminary Geotechnical Evaluation indicated t hat there are no active faults mapped on the project site and the site is not located within a mapped Alquist-Priolo Earthquake Fault Zone.

Liquefaction
Liquefaction occurs when loose, saturated, generally fine sands and silts are subjected to strong ground shaking. The soils lose shear strength and become liquid; potentially resulting in large total and differential ground surface settlements as well as possible lateral spreading during an earthquake. Seismically induced settlement can occur in respon se to liquefaction of saturated loose granular soils, as well as the reorientation of soil particles during strong shaking of loose, unsaturated sands.

The project site is identified as having Zero Susceptibility to Low Susceptibility for liquefaction per Figure 6-1 of the Safety Element of the City’s General Plan (San Marcos 2012). The risk associated with liquefaction and seismically induced settlement hazard is low due to the dense nature and age of the underlying formational materials and lack of shallo w groundwater (G EOCON 2020).