Attachment H - UDPS-Addendum (1) — San Marcos City Council, July 12, 2022

Attachment H

University District Specific Plan EIR Addendum

Addendum to Final Environmental Impact Report
SCH No. 2008101083

University District Specific Plan Amendment
SP21-0002 / SP22-0002 / GPA21-0005 / SM21-0002 / SDP21-0003

City of San Marcos
May 2022

Prepared by:

Sophia Mitchell & Associates

University District Specific Plan Amendment i City of San Marcos FEIR Addendum May 2022
Table of Contents

1.0 Introduction ................................ ................................ ................................ ........................... 1

1.1 Purpose and Scope .................................................................................................................... 1

1.2 Findings of This Initial Study/Addendum .................................................................................. 1

1.2.1 Use of an Addendum to a Previously Certified EIR ................................ ........................... 1

1.3 Existing Documents to be Incorporated by Reference ............................................................. 2

1.4 Contact Person ........................................................................................................................... 3

2.0 Project Description ................................ ................................ ................................ ................ 4

2.1 Project Site Setting ..................................................................................................................... 4

2.2 Proposed Discretionary Actions, Permits & Consultation ......................................................... 4

2.3 Project Background .................................................................................................................... 4

2.4 Project Description ..................................................................................................................... 4

2.5 Existing Conditions ..................................................................................................................... 8

2.6 Findings and Conclusions .......................................................................................................... 9

3.0 Initial Study ................................ ................................ ................................ ......................... 13

3.1 Environmental Checklist Form................................................................................................. 13

3.2 Environmental Analysis Checklist ............................................................................................ 16

ATTACHMENTS (Included in USB in back pocket)
Appendix A1 University District Specific Plan
Appendix A2 Heart of the City Specific Plan
Appendix B Air Quality Letter Report
Appendix C Energy Analysis Memorandum
Appendix D Climate Action Plan (CAP) Consistency Review Checklist and GHG Analysis Appendix E SDCRAA Correspondence
Appendix F Noise Letter Report
Appendix G Local Transportation Analysis
Appendix H Water System Analysis
Appendix I Sewer System Analysis

University District Specific Plan Amendment 1 City of San Marcos FEIR Addendum May 2022

1.0 INTRODUCTION

1.1 PURPOSE AND SCOPE
This document is an addendum to the Final Program Environmental Impact Report (FEIR) (State Clearinghouse No. 2008101083) certified by the City of San Ma rcos (City) in 2009 for the University District Specific Plan project. The purpose of this document is to determine if the proposed Specific Plan Amendment to the University District Specific Plan (UDSP) would result in any new impacts not previously identified in the FEIR. The attached checklist was used as a screening tool to determine that an Addendum was the appropriate document for California Environmental Quality Act (CEQA) compliance.

1.2 FINDINGS OF THIS INITIAL STUDY/ADDENDUM
Based upon the information provided in the attached Checklist/Addendum, the implementation of the proposed project will not result in any new significant impacts and the conclusions in the FEIR prepared for the University District Specific Plan project are valid for this project.

1.2.1 Use of an Addendum to a Previously Certified EIR
Section 15164 of the State CEQA Guidelines states that an Addendum to an EIR shall be prepared “if some changes or additions are necessary, but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.” Section 15162 of the State CEQA Guidelines identifies the conditions that require preparation of a subsequent EIR. A proposed change in a project will require preparation of a subsequent EIR if:

1. The change in the project is substantial.

Substantial changes in the project are those that would require major revisions of the previous EIR due to the involvement of new significant environmental effects, or if a substantial increase in the severity of previously identified significant effects has occurred.

2. The circumstances under which the project is undertaken have substantially changed.

Substantial changes in circumstances are defined as those that would require major revisions of the previous EIR in order to describe and analyze new significant environmental effects, or any changes that would cause a substantial increase in the severity of the previously identified significant effects.

3. New information of substantial importance, which was not known and could have not been known, with the exercise of reasonable diligence at the time the previous EIR was certified, shows:

A. The project will have one or more significant effects not discussed in the previous EIR; B. The significant effects previously examined will be substantially more severe than identified in the previous EIR;

C. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the

University District Specific Plan Amendment 2 City of San Marcos FEIR Addendum May 2022
project, but the project proponent declines to adopt the mitigation measures or alternatives; or

D. Mitigation measures or alternatives that are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the e nvironment, but the project proponent declines to adopt the mitigation measures or alternatives.

If none of the above conditions are met, the City is not required to prepare a subsequent EIR. Rather, the City may prepare a Mitigated Negative Declaration or an Addendum, or the City may decide that no further environmental documentation is necessary.

This Checklist/Addendum has evaluated each of the issues addressed in the FEIR. Additionally, new thresholds in Appendix G of the CEQA Guidelines related to energy, forestry resources, transportation (vehicle miles traveled) , tribal cultural resources , and wildfire that were adopted by the State of California after adoption of the FEIR have also been analyzed.

Based on this analysis and the information contained herein, there is no evidence that the proposed project requires major changes to the FEIR. Comparison of the previous project with the proposed project, as described in Section 2.4 of this document, indicates that there are no new significant environmental impacts or more severe significant environmental impacts associated with implementation of the proposed project.

This Checklist/Addendum relies on use of an Environmental Checklist Form (Form), as suggested in Section 15063 (d)(3) of the State CEQA Guidelines. The Form is used to evaluate whether or not there are any new or more severe significant environmental effects associated with implementation of the proposed project and proposed amendments; and to review whether there is new information or circumstances that would require preparation of additional environmental documentation in the form of a subsequent or supplemental EIR; or if an Addendum is appropriate.

Section 3.0 of this document contains this analysis and explains the basis for each response to the questions on the Form.

1.3 EXISTING DOCUMENTS TO BE INCORPORATED BY REFERENCE
Section 15150 of the State CEQA Guidelines permits an environmental document to incorporate by reference other documents that provide relevant data.

The documents outlined in this section are hereby incorporated by reference, and the pertinent material is summarized throughout this Checklist/Addendum, where that information is relevant to the analysis of impacts of the project. Any document incorporated by reference is availabl e for review at the City of San Marcos, Planning Division.
• University District Specific Plan Final Environmental Impact Report. 2009 (SCH No. 2008101083).
• University District Rock Crusher Conditional Use Permit Mitigated Negative Declaration. 2011 (SCH No. 2011081083).
• University District Specific Plan Amendment Initial Study and Final EIR Addendum. 2014. • University District Specific Plan Amendment Traffic Impact Assessment Report. 2014. RBF Consulting.

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• University District Specific Plan Block 3 (AASP 17-001 and CUP 17-005) Final EIR Addendum.

August 2017.
• Heart of the City Final Environmental Impact Report No 06 -87. City of San Marcos. SCH No. 87072926.Negative Declaration No. 06 -748 for GPA 06 -97/RC06-134/SPA 87 -29 (06M #21)/TA 06-59/SDP 06-319/ TPM 651. City of San Marcos.

1.4 CONTACT PERSON
The Lead Agency for the Checklist/Addendum for the proposed project is the City of San Marcos. Any questions should be referred to:

Art Piñon, Senior Planner
City of San Marcos
1 Civic Center Drive
San Marcos, CA 92069
Tel: (760) 744-1050 ext. 3234
Email: [email protected]

University District Specific Plan Amendment 4 City of San Marcos FEIR Addendum May 2022

2.0 PROJECT DESCRIPTION

2.1 PROJECT SITE AND SETTING
The project site is located in the City of San Marcos, in the northern portion of San Diego County. The project area is in the University District Specific Plan (UDSP) planning area (Figure 1). The approximate 203-acre project area is situated in the heart of San Marcos, with parcels located east and west of Twin Oaks Valley Road. The site is bounded by State Route 78 (SR -78) and San Marcos Creek on the north and Barham Drive and Discovery Hills on the south . California State Univer sity San Marcos (CSUSM) is located adjacent to the southeast section of the UDSP planning area. All figures referenced in this document are located at the end of the document.

2.2 PROPOSED DISCRETIONARY ACTIONS, PERMITS & CONSULTATION The proposed project requires approval of the discretionary permits and approvals by the City of San Marcos:
• General Plan Amendment (Mobility Element and Land Use and Community Design Element) • Specific Plan Amendment – University District Specific Plan • Specific Plan Amendment – Heart of the City Specific Plan • Tentative Subdivision Map
• Site Development Plan
• Street Vacations
• Easement Dedications and Abandonments
Each of these requested approvals is discussed in more detail in Section 2.4, below.

2.3 PROJECT BACKGROUND
University District Specific Plan Area
In 2009, the City of San Marcos approved the UDSP and certified the Final Environmental Impact Report (FEIR) (SCH No. 2008101083). In 2011 a Conditional Use Permit (CUP) for use of a rock crusher and modified grading operations at the site was approved and a Mitigated Negative Declaration (MND) was adopted for the CUP (SCH No. SCH No. 2011081083). In 2014, an Addendum to the certified FEIR was prepared to refine land uses , development intensities, and the circulation network within the specific plan area. In 2017 an Addendum to the certified FEIR was prepared for an Administrative Amendment and CUP for construction of the Extended Learning Building within the Block 3 area of the UDSP.

2.4 PROJECT DESCRIPTION
The proposed project is the approval of a General Plan Amendment, a Specific Plan Amendment to the UDSP, a Specific Plan Amendment to the Heart of the City Specific Plan (HOCSP), a Site Development Plan and a Tentative Subdivision Map . Each of these requested approvals is discussed in greater detail, below.

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General Plan Amendment
The General Plan Amendment (GPA) proposes changes to the Land Use and Community Design Element and the Mobility Element, as described below.

Land Use and Community Design Element
Remove approximately 8 acres from the Heart of the City Specific Plan and ad d it to the UDSP (APN - 220-201-90-00 (6.3 acres) and APN 220-202-18-00 (1.7 acres).

Mobility Element
Proposed changes to Figure 3-7 of the Mobility Element include removing the symbols that represent the following mobility improvements: 1) the Johnston Lane SR-78 flyover bridge; and 2) the pedestrian bridge from Discovery Street.

Specific Plan Amendment - University District Specific Plan Appendix A1 includes a track -changes version of the UDSP presenting the proposed r evisions to the document. These changes are briefly summarized below:
• Expanding the geographic area covered by the University District Specific Plan boundary, including two parcels located east of the North County Transit District ( NCTD) SPRINTER Rail Line, APNs 220-202-18-00 and 220-201-90-00 (described in further detail, below); • Removing the Johnston Lane SR-78 flyover bridge and Discovery Street pedestrian bridge. • Modifying building development standards to allow for greater height (up to 12, 1 5, and 16 stories in some areas);
• Increasing the amount of urban plaza space;
• Transforming the public right-of-way for Mid-City Lane from a public vehicular route to a pedestrian paseo with emergency access and public utilities; • Replacing the previously planned public right-of-way for June Way (North of the North City Drive roundabout) with pedestrian/limited vehicular and driveway access to an underground and street-level structured parking, drop off and pickup zones, short term parking, loading zones for delivery vehicles and other vehicular/pedestrian purposes to serve proposed private development;
• Modifying the Transportation/Circulation chapter to remove mitigation measures consistent with the latest transportation analysis;
• Allowing additional building types in certain areas (these building types are not new – they are part of the established building types in the UDSP);
• Modifying development standards to allow for more flexibility and architectural variation; • Modifying land uses (e.g. , reducing the number of hotel rooms, increasing general office square footage, decreasing medical office square footage, and decreasing mixed -use retail/commercial square footage);
• Making revisions to reflect current conditions (e.g., metal structures that had no practical reuse were removed and the adaptive reuse boundary was modified as a result);

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• Updating figures throughout the document as appropriate; and • General clean -up and modifications to terminology to correspond to the City’s current nomenclature (e.g., Major and Minor Use Permits to Conditional Use Permits and Director’s Permits).

With implementation of these changes, the overall development yield would decrease within the UDSP area. Table 1 presents the currently approved UDSP development yield compared with the proposed project.

Table 1. Land Use Statistical Summary
Land Use Description Current UDSP
Approx. 194 acres
Proposed Project
(Amended UDSP)
Approx. 203 acres
Change
Mixed-Use Residential 2,600 units 2,600 units No change Student Housing 800 units 800 units No change
Hotel 450 rooms 250 rooms -200 rooms
General Office 638,000 s.f. 920,000 s.f. +282,000 s.f.

Medical Office 300,000 s.f. 200,000 s.f. -100,000 s.f.

Mixed Use Retail/Commercial
700,000 s.f. 345,000 s.f.
-355,000 s.f.

Community/Civic 5,000s.f. 5,000 s.f. No change
K-6 Elementary School 850 students 850 students No change Parks and Urban Opens Space 25.00 acres 27.13 acres to

31.13 acres(1)
+2.13 acres to
+6.13 acres
Urban Trails/Paths 1.38 acres 1.38 acres No change
Preserved Open Space (Habitat) 15.10 acres 15.10 acres No change Public Streets 25.00 acres 22.00 acres - 3.00 acres

Note: (1) The Park and Urban Space land use will be a minimum of 27.13 acres under the amended UDSP. This amount could increase to 31.13 acres under one of the scenarios if a K-6 elementary school is not constructed within the UDSP planning area. Therefore, the total increase in park and urban space could range from 2.13 acres to 6.13 acres compared to the currently adopted UDSP.

The UDSP also allows for a K-6 elementary school on an 8-acre site in the Residential Neighborhood.

If the school is constructed, there will be no decrease in the allowed number of Mixed-Use Residential dwelling units within the UDSP. Should San Marcos Unified School District decide that the school is not needed, there are two alternatives for the 8-acre site. The first alternative is that four acres would be Parks and Urban Open Space as an extension of Knoll Park and the remaining four acres would be Mixed-Use Residential. The second alternative is that th e entire 8 -acres would revert to Mixed -Use Residential.

APN 220-201-90-00 (Zirpolo) and APN 220-202-18-00 (NCTD) As noted above, the project applicant is proposing to remove two parcels, totaling approximately 8 acres, from the Heart of the City Specific Plan (HOCSP) and add them to the UDSP.

The 6.3-acre parcel (APN 220-201-90-00), known as the Zirpolo property, is currently designated as Business Park in the HOCSP. As part of the proposed project this parcel would be removed from the

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HOCSP and be added to the UDSP . It would be designated as Office/Commercial within the UDSP.

Grading has commenced on this parcel consistent with a prior entitlement that was subject to CEQA review (ND 06-748).

APN 220-202-18-00 is 1.7 acres and located just east of the SPRINTER rail line. This property is owned by the North County Transit District (NCTD) and is currently designated as Business Park in the HOCSP.

As part of the project this parcel would be removed from the HOCSP and added to the UDSP for connectivity purposes. This parcel serves as an emergency access and maintenance access point for the SPRINTER rail line. It would be designated as Office/Commercial within the UDSP with a Railroad ROW overlay. No development is proposed within this parcel. Removal of the Railroad ROW overlay would require an Administrative Amendment and subsequent CEQA review prior to any development on the site.

Specific Plan Amendment - Heart of the City Specific Plan (HOCSP) Appendix A2 includes a track-changes version of the HOCSP presenting the proposed revisions to the document. Revisions to the HOCSP include:
• Page 3, Section 1.5. Removed outdated acreages.
• Figure 2, Land Use Plan, Changed designation s of APN 220-201-90-00 and 220-202-18-00 from Business Park (BP) to University District Specific Plan (SP). • Table 1, Land Use Statistical Summary. Changed acreage for Business Park and University District Specific Plan based on land use change for APNs 220-201-90-00 and 220-202-18-00 • Figure 3, Urban Design Concept Plan and Figure 10, Landscape Concept Plan. Moved APNs 220-201-90-00 and 220-202-18-00 into University District Specific Plan designation.

Tentative Subdivision Map
A Tentative Subdivision Map (TSM 21-0002) is proposed that covers 10.96 gross acres and proposes five lots (9.22 acres total gross) and 1.74 acres of public street right-of-way.

Site Development Plan
A Site Development Plan (SDP21-0003) for Blocks 2 and J is proposed . The SDP covers 9.46 acres and covers Block 2 and Block J within the UDSP (APNs 220-202-49,50,51,52,57,65,67,68,69 and 221- 110-46,55,56,57,81,82,83,70). The SDP includes two phases, described below. Phase A (Block 2) is located at the northwest corner of North City Drive and Campus Way. Phase B (Block J) is located at the southwest corner of East Carmel Street and Campus Way.

The two SDP phases include the following:
• Phase A (Block 2) - proposes construction of a ne w 839,000 s.f. (gross floor area)/786,000 s.f. (occupiable space) 12-story mixed use development with ground floor retail, residential, amenity support spaces with residential units and amenity spaces on floors above. Phase A includes 482 units. The building height would be 150’ 2”.

• Phase B (Block J) – proposes construction of a new 350,000 s.f. 5 -story mixed use development with ground floor retail, residential, amenity support spaces with residential units

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and amenity spaces on floors above. Phase B includes 56 units. The building height would be 72 feet.

Street Vacations and Abandonments
The proposed street vacations include the following:
• Portion of Mid -City public street and utility easement stub-out at Campus Way dedicated on Map 15997. This allows for transforming the public right-of-way for Mid-City Lane from a public vehicular route to a pedestrian paseo.
• Portion of public street and utility easement located at the northerly portion of June Way roundabout at North City Drive, dedicated per separate instrument. • Portion of public street and utility easement at the intersection of North City Drive and Campus Way dedicated on Map 15997.
• Portion of general utility and access easement along Mid-City and northerly leg of June Way at North City Drive, dedicated per separate instrument
• Vallecitos Water District utility and access easement along the northerly leg of June Way at North City Drive, dedicated per separate instrument.
• Public street easement on County of San Diego property easterly of the Campus Way roundabout (APN 220-202-01-00), to allow for transforming the area into a pedestrian paseo.

Public Easement Dedications
The proposed public easement dedications include the following:
• Vallecitos Water District sewer for sewer facilities relocation from June Way to North City Drive • Public drainage for storm drain facilities relocation from June Way to North City Drive • Paseo and public pedestrian access easement
• Public street and utility
• Emergency access easement - Under the proposed project, Mid-City Lane would change from a public vehicular route to a public pedestrian paseo. The paseo would be designed in a manner that would still accommodate emergency access.

Project Feature - Transportation Network Improvement
The project applicant will implement the following tra nsportation network improvement unless subsequent monitoring indicates it is not required:
• Discovery Street/Craven Road – construct an eastbound right turn lane and add overlap traffic signal phasing.

This improvement would take place within the existing right-of-way and would not result in any offsite environmental impacts. This improvement was analyzed as part of the 2009 UDSP FEIR. Additional information on the improvement and associated monitoring is included in the Transportation section of this document.

Grading
The 2009 FEIR included an analysis of the proposed grading and assumed up to 2,316,000 cubic yards (cy) of cut and fill, with approximately 587,500 cy of this being import fill material.

In 2011, a CUP for a rock crusher was issued. This CUP also permitted a change in the grading plans in the central portion of the project site which resulted in a total earthwork amount of approximately

University District Specific Plan Amendment 9 City of San Marcos FEIR Addendum May 2022
2,772,700 cy of cut and 1,703,500 cy of fill, leaving an export volume of approximately 1,069,200 cy for the overall UDPS area.

The 2014 UDSP Amendment and FEIR addendum noted that the grading quantities would balance onsite and include approximately 1,473,000 cubic yards of cut and fill, with no import or export. The 2014 UDSP, which is the current plan for the project area, reduced the amount of earthwork activity by approximately 36 percent. Compared to the grading plan considered as part of the CUP process, this represented a 46 percent reduction and eliminated a large amount of materials export.

An Administrative Amendment to the UDSP was approved in 2022 for the area west of Twin Oaks Valley Road. This Administrative Amendment included a refinement to the conceptual grading plan for the area west of Twin Oaks Valley Road.

The proposed project will not result in any changes to the overall grading quantities as contemplated in the 2014 Addendum and as refined by the 2022 Administrative Amendment. The grading quantities will still be the same within the overall UDSP area and the project grading will continue to balance on site within the UDSP area.

2.5 EXISTING CONDITIONS
The UDSP FEIR included a summary of existing on -site conditions. Currently, there are six completed projects within the UDSP area that have been designed in accordance with the development standards of the UDSP. They include the CSUSM Extended Learning Building (288 Campus Way), The Quad (200 E. Barham Drive), Block C (250 North City Drive), PIMA (111 Campus Way), Draft Republic (255 Redel Road), and Mesa Rim Rock Climbing Gym (285 Industrial Street). In addition, there are two projects under construction, the grading of the land area on the west side of Twin Oaks Valley R oad, and The Cube, a student housing building (190 E. Barham Drive).

APN 220-201-90-00, the 6.3-acre Zirpolo parcel is proposed to be included in the UDSP planning area.

Grading has commenced on this parcel consistent with a prior entitlement that was subject to CEQA review (ND 06-748).

APN 220 -202-18-00, the 1.7 -acre NCTD parcel that is also proposed to be included in the UDSP planning area, includes the elevated SPRINTER rail line, a linear drainage channel running north/south adjacent to the elevated rail line, and open areas with disturbed vegetation.

2.6 FINDINGS AND CONCLUSIONS

2.6.1 Section 15162 Findings
Based on the project description contained in Section 2.4, each of the issues addressed in the UDSP FEIR, as well as each of the issues analyzed in Section 3.0 of this document, have been evaluated, leading to the following findings and conclusions:
• The proposed project does not result in any new significant effects or a substantial increase in the severity of significant effects previously identified in the UDSP FEIR. • The FEIR adequately addressed the impacts of the proposed project as the proposed project is consistent in scope with the project analyzed in the UDSP FEIR in terms of geographic location, allowable land uses, the maximum number of residential units and the overall intensity of development.

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• There are no new significant effects or a substantial increase in the severity of significant effects related to aesthetics. The proposed project will not impact views to primary and secondary ridgelines.

• The traffic study concluded the project would not result in any deficiencies at intersections in the 2035 and 2050 analysis scenarios with the implementation of the identified network improvement. The proposed project does not result in any new traffic impacts or mitigation beyond that which is identified in the UDSP FEIR. (USA 2022).

• The proposed project would reduce trip generation by 37% compared to the currently adopted UDSP (2014 FEIR Addendum) and 49% compared to trip generation assumed in the UDSP FEIR, This reduction in trip generation eliminates the need for some infrastructure improvements contemplated by the UDSP FEIR.

• The greenhouse gas analysis identified a 19% reduction in greenhouse gas emissions for the proposed project compared to the current UDSP (LDN 2022c). The significant and unmitigated greenhouse gas impact identified in the UDSP FEIR would be eliminated under the proposed project.

• The proposed project would reduce construction and operational emissions for all analyzed criteria pollutants (ROG, NOx, CO, SOx, PM10, PM2.5) compared to the emissions anticipated in the UDSP FEIR and under the currently approved UDSP (LDN 2022a).

• The noise analysis did not identify any new noise impacts or increase in severity of noise impacts due to the redistribution of traffic due to the removal of the planned Johnston Lane SR-78 flyover bridge improvements (LDN 2022d).

• The proposed project would decrease wastewater generation by 33% and water demand by 19% compared to the assumptions in the UDSP FEIR (DWE 2021a and DWE 2021b).

• The project applicant would continue to pay all applicable fees in effect at the time that future development is proposed , including Public Facilit ies Fees (PFF) . PFF includes funding for circulation streets, SR -78 interchanges, National Pollutant Discharge Elimination System (NPDES) program, technology improvements, parks, and habitat conservation.

• The project applicant would continue to pay San Marcos Unified School District Residential and Commercial Development fees as future development projects come forward within the UDSP planning area.

• The proposed project would not have effects that were not examined in the UDSP FEIR and feasible and still necessary mitigation measures developed in the UDSP FEIR are incorporated into this Addendum for the proposed project.
•
Thus, none of the conditions described in CEQA Guidelines Section 15162 calling for preparation of a subsequent EIR have occurred.

1. The change in the project analyzed in the FEIR for the UDSP is not substantial. Substantial changes in the project are those that would require “major revisions of the previous EIR … due to the involvement of new significant environmental effects, or a substantial increase in the

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severity of previously identified significant effects.” As noted above, the proposed project will not result in new significant effects or a substantial increase in the severity of previously identified significant effects.

2. The circumstances under which the project is undertaken have not substantially changed.

Substantial changes in the circumstances und er which the project is being undertaken are defined as those that would “require major revisions of the previous EIR … due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects. The circumstances under which the project is being undertaken have changed, but those changes are not substantial changes that will result in the proposed project having new significant effects or a substantial increase in the severity of previously identified significant effects.

3. No new information of substantial importance, which was not known and could have not been known, with the exercise of reasonable diligence at the time the previous EIR was certified, shows:
• “The project will have one or more significant effects not discussed in the previous EIR…;
• Significant effects previously examined will be substantially more severe than shown in the previous EIR;
• Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or
• Mitigation measures or alternatives that are considerably different f rom those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.”
Section 15164 of the State CEQA Guidelines states that an Addendum to an EIR shall be prepared “if some changes or additions are necessary, but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.” Since none of the conditions of Section 15162 of the State CEQA Guidelines occur, an Addendum to the UDSP FEIR is the appropriate form of environmental documentation under CEQA for the proposed project.

2.6.2 Program EIR Findings
Section 15168 of the CEQA Guidelines addresses Program EIRs and their use for subsequent project approvals. The University District Specific Plan Final EIR was a Program EIR, as described on page 2 - 32 of the certified FEIR.

Section 15168(c) discusses the use of a Program EIR with later activities and Section 15168(c)(2) states that “if the agency finds that pursuant to Section 15162, no subsequent EIR would be required, the agency can approve the activity as being within the scope of the project covered by the program EIR, and no new environmental document would be required. Whether a later activity is within the scope of a program EIR is a factual question that the lead agency determines based on substantial evidence in the record. Factors that an agency may consider in making that determination include, but are not limited to, consistency of the later activity with the type of allowable land use, overall planned

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density and building intensity, geographic area analyzed for environmental impacts, and covered infrastructure, as described in the program EIR.”
As detailed in Section 2.6.1, above, and elsewhere in this Addendum and the project materials, the City finds that, pursuant to Section 15162, no subsequent EIR would be required. Since none of the conditions of Section 15162 of the State CEQA Gui delines occur and as the Addendum and the proposed project satisfy the requirements of Section 15168 , an Addendum to the UDSP FEIR is the appropriate form of environmental documentation under CEQA for the proposed project.

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3.0 INITIAL STUDY

3.1 ENVIRONMENTAL CHECKLIST FORM
The following pages contain the Environmental Checklist Form (Form) for the proposed project. The Form is marked with findings as to the environmental effects of the project. As explained in Section

1.0, this analysis has been undertaken, pursuant to the provisions of CEQA, to provide the City of San Marcos with the factual basis for determining, based on the information available, the form of environmental documentation the project warrants. The basis for each of the findings is provided directly below each checklist item.

ENVIRONMENTAL CHECKLIST FORM

1. Project Title: University District Specific Plan Amendment

2. Lead Agency Name and Address: City of San Marcos
1 Civic Center Drive
San Marcos, CA 92069

3. Contact Person: Art Piñon, Senior Planner
(760) 744-1050 ext. 3234

4. Project Location: The approximate 203-acre project area is situated in the heart of San Marcos, with parcels located
east and west of Twin Oaks Valley Road. The site
is bounded by State Route 78 (SR -78) and San
Marcos Creek on the north and Barham Drive and
Discovery Hills on the south. California State
University San Marcos (CSUSM) is located
adjacent to the southeast section of the UDSP
planning area.

5. Project Applicant: Urban Villages San Marcos, LLC
3525 Del Mar Heights Road #246
San Diego, CA 92130

6. Existing and Proposed General Plan
Designations:

Existing: Specific Plan
Proposed: Specific Plan

7. Existing and Proposed Zoning: Existing: Specific Plan Proposed: Specific Plan

8. Project Description: The proposed project is the approval of a General Plan Amendment, a Specific Plan Amendment for
the University District Specific Plan, a Specific
Plan Amendment for the Heart of the City
Specific Plan, a Site Development Plan and a
Tentative Subdivision Map.

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9. Existing and Proposed Surrounding Land
Use and Setting:

The UDSP area is located near existing
residential and commercial uses and is adjacent
to CSUSM. The UDSP planning area is adjacent
to the San Marcos Creek Specific Plan (Creek
District) area which proposes a mix of residential,
commercial and office uses.

10. Public Agencies Whose Approval is
Required (e.g., permits, financing approval,
or participation agreement):

City of San Marcos

University District Specific Plan Amendment 15 City of San Marcos FEIR Addendum May 2022
DDetermination
On the basis of this initial evaluation:
o The City finds that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. o The City finds that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because the mitigation measures described on an attached sheet have been added to the project. A NEGATIVE DECLARATION will be prepared.
o The City finds the proposed project may have a significant effect(s) on the environment, but at least one effect: (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. If the effect is a potentially significant impact or potentially significant unless mitigated an ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to addressed. o The City finds that changes to the project or the circumstances under which the project would be undertaken require major revisions to the previous EIR in order to make the previous EIR adequately apply to the proposed project in accordance with Public Resources Code Section 21166 and CEQA Guidelines Section 15163. Thus, a SUBSEQUENT EIR shall be prepared. o The City finds that changes to the project or the circumstances under which the project would be undertaken require only minor revision to the previous EIR in order to make the previous EIR adequately apply to the proposed project in accordance with Public Resources Code Section 21166 and CEQA Guidelines Section 15163. Thus, a SUPPLEMENTAL EIR shall be prepared.

X The City finds that the significant effects that would result from the proposed project have been addressed in an earlier EIR, and that none of the determinations set forth in Public Resources Code Section 21166 and State CEQA Guidelines Section 15162 can be established. Thus, an ADDENDUM to the University District Specific Plan FEIR shall be prepared.

Art Piñon, Senior Planner

Date

Art Pinon
Digitally signed by Art Pinon
DN: cn=Art Pinon, o=City of San
Marcos, ou=Signature,
[email protected], c=US
Date: 2022.05.23 08:14:32 -07'00'

University District Specific Plan Amendment 16 City of San Marcos FEIR Addendum May 2022

3.2 ENVIRONMENTAL ANALYSIS CHECKLIST

1. AESTHETICS – Would the project:
a) Have a substantial adverse effect on a scenic vista? FEIR Conclusion: Less than Significant. The FEIR identified San Marcos Creek as the primary visual amenity within the UDSP site and that the project site did not support any primary or secondary ridgelines. The FEIR concluded (page 3.1 -33) that the UDSP project would not impact views of San Mar cos Creek or impact views of primary or secondary ridgelines. Impacts to scenic vistas were considered less than significant and no mitigation measures were proposed.

Discussion of the Proposed Project: The proposed project is in an urbanized location and is surrounding by existing development or areas that are approved for development. The project site is situated in a lower elevation portion of the City adjacent to SR -78. Under the proposed project, the appearance of the buildout of the UDSP would change. As part of the project, the building development standards within the UDSP would be modified to allow for greater building height (up to 12, 15, and 16 stories in some areas). Currently the maximum height allowed within the UDSP is 7 stories. The propose d Height Regulating Plan is shown in Figure 2 at the end of this document.

The City’s General Plan does not specifically define scenic vistas nor does it identify scenic vistas ; however, the City has identified resources in the General Plan such as the San Marcos, Merriam, and Double Peak Mountains, creek corridors, mature trees, rock outcroppings, and ocean views. Other lead agencies have defined a scenic vista, The City of San Luis Obispo defined a scenic vista as a view of natural environmental, historic, an d/or architectural features possessing visual and aesthetic qualities of value to the community. The term “vista” generally implies an expansive view, usually from an elevat ed point or open area (City of San Luis Obispo 2017 ). The Cambria Community Services District (CCDS) defines a scenic vista as a view that possess visual and aesthetic qualities of high value to the community (CCDS 2017).

Ridgeline Protection and Management Overlay Zone

The City adopted a Ridgeline Protection and Management Overlay Zone in November 2008, set forth in Ordinance 2008 -1314, to preserve primary ridgelines in their natural state and minimize visual impacts to secondary ridgelines. These guiding principles are in place to protect natural viewsheds and unique natural resources, 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). The Ordinance does not specifically call for the preservation of views to primary and secondary ridgelines, but rather establishes guidelines for development within primary and secondary ridgelines.

No primary or secondary ridgelines are located within or adjacent to the project site. The nearest ridgeline is a secondary ridgeline located approximately 1.5

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miles southwest of the project site near South Lake. The nearest primary ridgeline is located approximately 1.7 miles southwest of the project site. For development that is proposed within ridgeline overlay zones, special attention is given to any features that would disrupt the ridgeline silhouette.

Viewing Platforms
Table 20.260 -2 (Viewing Platform Locations) of the City’s Municipal Code identifies viewing platforms throughout the City. Viewing platforms are those portions of major thoroughfares and other selected public vantage points located within the City and its sphere of influence lands that were used to assess the visual significance of the primary and secondary ridgelines covered by the Ordinance. There are 19 viewing platforms identified in Table 20.260 -2. They include:
• Twin Oaks Valley Road at the following intersections: Village Drive, Craven Drive, San Marcos Boulevard, Borden Road, Del Roy Drive, La Cienega, north of the fork on Deer Springs Road , and North Twin Oaks Valley Road;
• SR-78 eastbound and westbound;
• Borden Road west of Avenida Amiga ;
• City Parks: Walnut Grove Park, Hollandia Park, Cerros de Las Posas Park, Bradley Park, Discovery Park, Simmons Park and Jack’s Pond Park ; and • Cesar Chavez Plaza at CSUSM
The closest viewing platforms to the p roject site that include public views that were selected for the preparation of visual simulations include:
• Twin Oaks Valley Road at Craven Drive
• Twin Oaks Valley Road on North Twin Oaks Valley Road (at Mission Road and at San Marcos Boulevard)
• SR-78 Eastbound
• SR-78 Westbound
The other viewing platforms were screened out because building s associated with project development would not be visible , or the viewing platform distanc e and relative elevation to the project site would not result in the potential to affect views to primary and secondary ridgelines.

Viewing platforms screened out due to the fact that project buildings would not be visible included: Twin Oaks Valley Road north of the fork on Deer Springs Road, Twin Oaks Valley Road at La Cienega, Borden Road west of Avenida Amiga, Walnut Grove Park, Cerro de Las Posas Park, and Simmons Park. Viewing platforms screened out due to the fact that there would not be a pote ntial for project buildings to affect views to primary or secondary ridgelines included:

Twin Oaks Valley at Del Roy Drive, Twin Oaks Valley Road at Borden Road, Twin Oaks Valley Road at Village Drive, Hollandia Park, Cerros de Las Posas Park, Discovery Park, Jack’s Pond Park, Double Peak Park, and Cesar Chavez Plaza at CSUSM.

For the purposes of this analysis the views from Twin Oaks Valley Road at Craven Drive, Twin Oaks Valley Road on North Twin Oaks Valley Road, SR -78 eastbound and SR-78 westbound are considered scenic vistas since they provide views to primary and secondary ridgelines. For each of the viewing platform s that were

University District Specific Plan Amendment 18 City of San Marcos FEIR Addendum May 2022
analyzed, two renderings were prepared . The first rendering shows potential building bulk and scale if the project area was built out per the building height regulations of the currently adopted UDSP . Under the current plan, building heights up to 7 stories are permitted in some locations. The second rendering shows what the buildout of the project area could look like unde r the proposed project, which include s a higher building height allowance (12, 15 and 16 stories in some areas). By comparing these renderings, it can be determined if the proposed project could result in a substantial adverse effect to a scenic vista.

Twin Oaks Valley Road at Craven Drive (Figures 3a and 3 b) – These renderings depict the view on Twin Oaks Valley Road just north of Craven Drive, looking north.

This is an urbanized location in the City with CSUSM located to the east and Palomar Health and commercial uses to the west.

Figure 3a represents what the view could look like if the project area was built out under the building height regulations of the current UDSP. Street trees provide visual shielding to existing and future development along Twin Oaks Valley Road.

In the distance 7-story buildings at the intersection of Twin Oaks Valley Road and North City Drive are visible. Ridgelines are visible in the distance down the corridor of Twin Oaks Valley Road.

Figure 3b represents the view with buildout of the project area under the proposed plan. The primary difference is an increase in building heights . The buildings at the intersection of Twin Oaks Valley Road and North City Drive would be up to 16 stories high. The views to distant ridgelines to the north are still visible down the corridor of Twin Oaks Valley Road. Due to the set back of the buildings under the proposed plan, the views of the ridgelines are somewhat opened up since the buildings would have a more stair-step design with the building height pulled back from Twin Oaks Valley Road compared to what could be built out under the current plan. The increased building heights do not cause any disruption to the views to distant ridgelines and the ridgeline silhouette remains unbroken. Implementation of the proposed project would not result in a substantial effect on a scenic vista from this viewing platform.

Twin Oaks Valley Road on North Twin Oaks Valley Road – North Twin Oaks Valley Road extends for approximately 4 miles from SR-78 to Deer Springs Road. Three locations were selected along North Twin Oaks Valley Road to depict the visual change between buildout of the current UDSP and the proposed UDSP. The locations are North Twin Oaks Valley Road at Mission Road, North Twin Oaks Valley Road at San Marcos Boulevard, and North Twin Oaks Valley Road at the SR-78 Overcrossing.

North Twin Oaks Valley Road/Mission Road
Figures 4a and 4b presents the views on North Twin Oaks Valley Road at the Twin Oaks Valley overpass at Mission Road. This is an urbanized location in the City.

Figure 4a represents what the view could look like if the project site was built out under the current ly approved UDSP. The ridgelines to the south form a visual backdrop to the development in the foreground. Mature trees along Mission Road punctuate the views. The buildings within UDSP appear as part of the urban fabric and a continuation of urban development that is in the foreground. The buildings within the UDSP do not block any views to the ridgelines and the ridgelines appear

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uninterrupted with the exception of the existing intervening landscaping and trees.

Figure 4b represents the buildout of the project site under the proposed project.

Buildings at the intersection of Twin Oaks Valley Road and Campus Way would be more visible due to the increase in building height. The taller buildings still appear as part of the urban landscape. In some locations the taller buildings will punctuate the ridgeline silhouette, however the majority of the ridgeline silhouette remains intact. The increased buildi ng heights would cause some disruption to ridgeline views from this location; however, the visual change would be less than significant as the majority of the ridgeline silhouette is maintained.

Implementation of the proposed project would not result in a substantial effect on a scenic vista from this viewing platform.

North Twin Oaks Valley Road/San Marcos Boulevard
Figures 5a and 5b present the views on North Twin Oaks Valley Road, just north of San Marcos Boulevard, looking south. This is an urbanized location in the City.

Figure 5a represents what the view could look like if the project site was built out under the current ly approved UDSP. The ridgelines to the south are a dominant feature and form a visual backdrop to the development in the foreground. The buildings within UDSP appear as part of the urban fabric and a continuation of urban development that is in the foreground. The buildings within the UDSP do not block any views to the ridgelines and the ridgelines appear uninterrupted with the exception of the existing intervening street light poles along Twin Oaks Valley Road.

Figure 5b represents the buildout of the project area under the proposed project.

There is a change in building height and form, which provides for more visual variety. The taller buildings still appear as part of the urban landscape and are not of a height which dis rupts the view of the ridgelines. Future buildings within the UDSP would sit, visually, below the ridgeline. The increased buildi ng heights do not cause any disruption in the views to distant ridgelines and the ridgeline silhouette remains unbroken. Implementation of the proposed project would not result in a substantial effect on a scenic vista from this viewing platform.

North Twin Oaks Valley Road/SR -78 Overcrossing
Figures 6a and 6b present the views on Twin Oaks Valley Road at the SR -78 overcrossing. This is an elevated area just north of the project site. This is an urbanized location in the City with a lot of vehicular activity due to the SR -78 interchange at Twin Oaks Valley Road.

Figure 6a represents what the view could look like if the project site was built out under the current approved UDSP. The tops of ridgelines to the south are visible, however blocky style buildings dominate the foreground and obscure large portions of the lower elevations of the hills to the south. The top of the ridgelines are visible and form a visual backdrop to the development in the foreground.

Figure 6b represents the buildout of the project area under the proposed project.

There is a change in building height and form, which provides for more visual variety. In seve ral locations the taller buildings will punctuate the ridgeline silhouette, however more than 50% of the ridgeline silhouette remains intact. By reducing building footprints through taller buildings, some views to the lower elevations of the hills are open ed up under the proposed project. The increased

University District Specific Plan Amendment 20 City of San Marcos FEIR Addendum May 2022
building heights would cause some disruption to ridgeline views from this location; however, the visual change would be less than significant as the majority of the ridgeline silhouette is maintained.

Eastbound SR -78 – The project site is located in proximity to SR -78. Two locations were selected along eastbound SR -78 to depict the visual change between buildout of the current UDSP and the proposed UDSP. The locations are eastbound SR -78 looking southeast, just east of San Marcos Boulevard and eastbound SR-78, just east of Twin Oaks Valley Road looking east.

Eastbound SR-78 at San Marcos Boulevard Overcrossing
Figures 7a and 7b present the views from eastbound SR -78 where the freeway crosses over San Marcos Boulevard. This is an urbanized location in the City and SR-78 is elevated over San Marcos Boulevard with development located on both sides of SR-78.

Figure 7a represents what the view could look like if the UDSP was built out under the current plan. The ridgelines to the east and northeast are visible in the distance from this location, however, SR-78 and vehicles traveling on the freeway are a dominant feature in the foregrou nd. Trees located adjacent to SR -78 occasionally punctuate views to the ridgelines and nearby development. To the northeast, and at a lower elevation, development along San Marcos Boulevard is visible. The UDSP project site would be visible in the distance on the elevated knoll which sits, visually, below the ridgeline.

Figure 7b presents the same view with buildout of the UDSP under the proposed plan. Dominant features in this view continue to be SR -78 and the vehicles traveling on the roadway. Buildings within the UDSP planning area would be visible in the distance on the knoll. The prominent ridgeline views to the southeast are still visible and their silhouette is not disrupted. As the ridgeline decrease in elevations, proposed buildings would be at or just above the ridgeline silhouette.

However, the majority of the ridgeline silhouette is maintained. Implementation of the proposed project would not result in a substantial effect on a scenic vista from this viewing platform.

Eastbound SR-78 at Twin Oaks Valley Road
Figures 8a and 8b present the views on Eastbound SR-78 just east of Twin Oaks Valley Road. This is an urbanized location in the City.

Figure 8a represents what the view could look like if the UDSP was built out under the current plan. This figure presents a view from eastbound SR -78 just east of Twin Oaks Valley Road. It depicts the existing PIMA and Scripps buildings with new buildings to the west and east which would be built out under the UDSP.

Under the current plan, the portions of the UDSP closest to SR -78 would have a 3-story minimum and a 5 -story (70 foot) maximum with a very small area where 6 stories would be allowed. Views to ridgelines to the south and southeast are already limited in this location due to existing development.

Figure 8b presents what the view could look like if the UDSP was built out under the proposed project and proposed height regulating plan. The proposed project allows for up to 20 feet greater building heights in this area. This c hange in building height would not be considered significant from a visual perspective

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since this is already a built up portion of the SR -78 corridor and views to area ridgelines would already be impeded by development under the current UDSP.

Westbound SR-78
Figures 9a and 9b presents the views on West bound SR-78 near the Twin Oaks Valley Road exit. This is an urbanized location in the City.

Figure 9a represents what the view could look like if the UDSP was built out under the current plan. This figure presents views from West bound SR-78 just east of the Twin Oaks Valley Road exit. It depicts the existing PIMA and Scripps buildings with new buildings to the west and east which would be built out under the UDSP. There are no views to ridgelines t o the south due to development adjacent to SR -78. Under the current plan, the portions of the UDSP closest to SR-78 would have a 3-stories minimum and a 5 -stories (70 foot) maximum with a very small area where 6 stories would be allowed. Figure 8b represen ts buildout under the proposed project.

Figure 9b presents what the view could look like if the UDSP was built out under the proposed project and proposed height regulating plan . Under the proposed project, the area closest to SR -78 would have a minimum o f 2 to 3 stories and a maximum of 5 or 6 stories (90 feet). Thus, the proposed project allows for up to 20 feet greater building heights in this area. This change in building height would not be considered significant from a visual perspective since this i s already a built up portion of the SR -78 corridor.

General Plan Policy Consistency

The Conservation and Open Space Element of the General Plan identifies a goal (Goal COS -3) to “protect natural topography and preserve and enhance the natural beauty of San Marcos”. Four policies are identified to support that goal.

Policy COS -3.1 is discusse d below and other applicable policies related to aesthetics topics are addressed in section 1.b and 1.d, below.

Policy COS-3.1: Preserve scenic resources, including prominent landforms such as Double Peak, Owens Peak, San Marcos Mountains, Merriam Mountains, Cerro de Las Posas, Franks Peak, and canyon areas through conservation and management policies.

The project site is located approximately 1.5 miles southeast of the Double Peak area. The proposed project would not result in any impact to scenic resour ces, including the prominent landforms identified in Policy COS -3.1. No development is proposed within primary or secondary ridgelines. As demonstrated in the analysis above and through renderings comparing the buildout of the UDSP under the current plan and the proposed plan, the project would not result in an impact to scenic resources or significantly impede views to these resources. The project does not conflict with Policy COS-3.1.

Based upon the analysis in this section, the proposed project will result in the loss of some views of ridgelines depending on the viewing platform. This includes minor disruption of views from SR -78 eastbound at San Marcos Boulevard Overcrossing and on North Twin Oaks Valley Road at Mission Road. The proposed project results in the most disruption of views from the viewing platform of North Twin Oaks Valley Road and the SR -78 overcrossing. However, more than 50% of

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the ridgelines silhouette is maintained from this viewing platform and by reducing building footprints by build ing vertical instead of horizontal , views to lower portions of the hillsides are opened up in this location. The project is consistent with the applicable General Plan policy (COS -3.1) related to scenic vistas. When the visual change is considered, in tota lity, from all modeled viewing platforms locations considered in this analysis , the level of change to views of ridgelines would be less than significant and there are no new impacts related to scenic vistas.

Finding: There are no significant impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway? FEIR Conclusion: Less than Significant. The FEIR concluded that the portion of SR-78 adjacent to the project site is not identified as State scenic highway per the Caltrans State Scenic Highway Program and impacts would be less than significant (page 3.10-34).

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint of the Specific Plan analyzed in the UDSP FEIR plus an additional 8 acres (APNs 220-201-90-00 and 220-202-18-00) which are proposed to be removed from the Heart of the City Specific Plan and added to the UDSP.

According to Caltrans’ 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). 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. 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 the state scenic highway designation (Caltrans 2011). The project site is located approximately 25 miles west of the closest point of this eligible state scenic highway. Therefore, the project does not have the potential to impact scenic resources within a state scenic highway including trees, rock outcroppings, or historic buildings, and no new impacts are identified.

Finding: There are no significant impacts for this issue area and no changes in information that would require the preparation of an EIR. c) 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 points). If the project is in an urbanized area, would the project conflict with the applicable zoning and other regulations governing scenic quality?
FEIR Conclusion: Less than Significant. The FEIR (page 3.1 -34) concluded that the UDSP proposed urban development and new roadways that would alter the existing visual character of the project site. The FEIR also noted that the Specific Plan would introduce new visual amenities to the project s ite and surroundings.

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The FEIR concluded that implementation of the UDSP would result in a change in the visual character to the site and surrounding, although this change was not characterized as a degradation. Therefore, a less than significant impact wa s identified in the FEIR.

The City (which includes the project site) is considered an urbanized area per the Public Resources Code (PRC). Per PRC Section 21071, one definition of an “urbanized area” is defined a s a city having a population of less than 100,000 persons if the population of that city and no more than two contiguous incorporated cities combined equals at least 100,000 persons. As of April 1, 2020, the US Census Bureau estimated the population of Sa n Marcos to be 94,833 persons (USCB 2020). The City is contiguous with the City of Escondido, which has an estimated population of 151,038 persons as of April 1, 2020 (USCB 2020). The combined estimated population of these two contiguous cities is 245,871 persons, which is over the 100,000 persons threshold. Thus, the City would be considered an urbanized area and 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 proposed project is c urrently inconsistent with the height requirements of the UDSP, but pursuant to the analysis contained in the Addendum has been deemed to be an impact that is less than significant, and the project would be consistent if the proposed UDSP plan amendment is approved. Further, the project’s consistency with policies related to scenic vistas was discussed in Section 1.a, above and was determined to have a less than significant impact . An analysis of the proposed project’s consistency with other applicable Gene ral Plan polices is provided below.

Consistency with Applicable General Plan Policies
Conservation and Open Space Element

Policy COS -3.1 was discussed in S ection 1.a . Policies COS -3.2 and 3 -3 are discussed below and Policy COS-3-4 relates to lighting and is addressed in Section

1.d.

Policy COS -3.2: Encourage and maintain high -quality architectural and landscaping designs that enhance or complement the hillsides, ridgelines, canyons, and view corridors that comprise the visual character in San Marcos.

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The UDSP serves as the guiding document for visual character and scenic quality within the project area. This is done through the Form -Based Code which is detailed in Section VI of the UDSP. The Form -Based Code provides standards related to blocks, street types, public parks and gathering spaces, building types, frontage requirements, architectural standards, landscaping standards and signage. Section VII of the UDSP addresses community identity, signage and public art. These regulations contribute to the overall visual character and scenic quality of the project site and ensure high -quality architectural and landscaping design. The project does not propose any development on hillside, ridgelines or canyons. Views from multiple viewing platforms were analyzed in Section 1.a, and impacts were determined to be less than significant. The project would be consistent with Policy COS-3.2.

Policy COS -3.3: Continue to work with new development and redevelopment project applicants in designing land use plans that respect the topography, landforms, view corridors, wildlife corridors, and open space that exists.

The UDSP considers the existing topography and landforms both on the site and in the surrounding area as it relates to land use types, the height regulating plan and the building types. Overall, the project site is located in a lower portion of the City, and the east side of the UDSP planning area is relatively flat. The west side of the UDSP planning area is more topographically diverse and the layout of the land use types and future roadways takes this into consideration. Changes to the building height regulating plan which are proposed as part of the project, were analyzed in Section 1.a and no significant impact to visual resources , view corridors, or views to primary and secondary ridgelines were identified. The 15.10 acres of p reserved open space/habitat identified in the FEIR and current UDSP will still remain. There are no changes in the UDSP which would result in a greater impact to wildlife corridors or preserved open space /habitat. This is analyzed further in Section 4 of this checklist. By increasing building height, building footprints can be reduced which allows for more area for parks and urban open space. The proposed project increases the amoun t of parks and urban open space from 25 acres under the current UDSP to up to 31 acres. The project would be consistent with Policy COS-3.3.

Land Use Element
The Land Use Element of the General Plan identifies a goal (Goal LU -5) to “Promote community design that produces a distinctive, high -quality built environment with forms and character that create memorable places and enrich community life.” Several policies support this goal with two of them specifically relating to visual character and quality (Policy LU-5.4 and LU-5.6). These policies are analyzed below.

Policy LU -5.4: Require building and site design that respects the natural topography and iconic ridgelines that serve as the visual backdrop for San Marcos.

Section 1.a discusses the proposed project in light of the area ridgelines and the

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City’s ROZ and includes renderings to show the change between buildout under the current ly approved UDSP and the proposed UDSP. No development is proposed on primary or secondary ridgelines and the analysis in Section 1.a determined that changes in building heights would not result in a significant change to scenic vistas in the City. Taller buildings would not disrupt views to the ridgelines and would not change the ridgeline silhouette. The project would be consistent with Policy LU-5.4.

Policy LU-5.6: Require a specific plan for strategic areas/properties that require high-quality design, orientation and development due to their location or visibility within the community.

The project site is visible from SR-78, Twin Oaks Valley Road, and other locations in the City . The UDSP serves as the guiding document for visual character and scenic quality within the project area. This is done through the Form -Based Code which is detailed in Section VI of the UDSP. The Form -Based Code provides standards related to blocks, street types, public parks and gathering spaces, building types, frontage requirements, architectural standards, landscaping standards and signage. Section VII of the UDSP addresses comm unity identity, signage and public art. These regulations ensure that future development within the UDSP planning area will be of a high -quality design. The proposed project would amend the currently adopted UDSP to allow for greater building heights but this change was determined to be less than significant in section 1.a. The project would be consistent with Policy LU-5.6.

An additional policy, LU -6.9, addresses aesthetics and design related to the SR - 78 corridor:

Policy LU -6.9: Ensure high quality archit ectural standards and aesthetic design quality particularly for redevelopment along the State Route 78 corridor and within the commercial core of the community.

The project site is visible from SR -78. Figures 7a, 7b, 8a, 8b, 9a and 9b, which were discussed in Section 1.a present renderings from three locations on SR-78.

The proposed project allows for a greater height (up to 20 feet higher) along SR - 78 within the UDSP area. However, any future development within the UDSP, including that which is visible from SR-78 would be subject to design regulations in the UDSP which will ensure high quality architectural standards and aesthetic design. As individual development project come forward within the UDSP planning area, they will be reviewe d by the City to ensure consistency with the design guidelines and architectural standards within the UDSP. The project would be consistent with Policy LU-6.9.

In conclusion, the project is consistent with the applicable General Plan policies related to visual character and quality.

Visual Character and Quality
This section discusses the visual character and quality of the project site and surrounding areas and discuss es the change with implementation of the proposed project.

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Visual character considers topics like pattern elements (form, line, color, texture) and pattern character (dominance, scale, diversity, and continuity) in the landscape.

Visual quality considers topics like vividness (the memorability of a landscape), intactness (the visual integrity of the landscape) and unity (the visual coherence and compositional harmony of a landscape). These definitions are from the County of San Diego Report Format & Content Requirements for Visual Resources (County of San Diego 2007).

The visual character of the project site and vicinity is influenced by the urbanized and developed nature of the project vicinity. Topographically, the UDSP planning area sits within lower portions of the City and primary and secondary ridgelines provide a visual backdrop to this urbanized area. The project site is located near the Twin Oaks Valley Road interchange with SR-78, and the project site is part of the visual gateway to this portion of the City. Motorists, cyclists and pedestrians pass through the project site on Twin Oaks Valley Road to access areas of the City south of SR-78.

The UDSP serves as the guiding document for visual character and quality within the project area. This is done through the Form-Based Code which contains three Regulating P lans. These are the Street Type Regulating Plan, the Building and Public Space Regulating Plan, and the Height Regulating Plan. These regulations provide an urban design and regulatory framework to ensure the vision for the planning area is implemented. The UDSP’s stated vision is to create a sustainable and vibrant urban center that strengthens the emerging downtown core of San Marcos.

The project site is adjacent to CSUSM, which is developed with several multi-story buildings including the Student Union building which is approximately 60 feet high. Other development in the project vicinity including the new Kaiser Permanente Medical Center (125 feet high), Palomar Health office building, and the Campus Marketplace shopping center.

Currently, there are six completed projects within the UDSP project area: CSUSM Extended Learning Building (6 stories), The Quad (5 stories), Block C (5 stories), PIMA (3 stories), Draft Republic (1 story), and the Mesa Rim Rock Climbing Gym (65 feet). Two additional projects are currently under construction: grading of the land area on the west side of Twin Oaks Valley Road, and The Cube, a student housing building (8 stories). These developments vary in heights, from a single story to up to seven stori es and feature a range of architectural styles and treatments. General Plan Policy LU -5.2 calls for the establishment of a “downtown” as a focal point for the San Marcos community and as an attraction for North County. The UDSP planning area is intended to be the “downtown” for San Marcos . The UDSP planning area is served by key transportation infrastructure including SR -78, Twin Oaks Valley Road, Barham Drive and the SPRINTER light rail. The project vicinity is active and vibrant due to vehicular traffic, pedestrian movement and the mix of land uses. Due the project site’s proximity to SR-78, Twin Oaks Valley Road and CSUSM, the project site is highly visible.

Figures 3a, 4a, 5a, 6a, 7a, 8a and 9a present renderings of what the project site would look like with buildout of the currently approved UDSP, which has a maximum height of 7 stories (90 foot maximum) . These renderings show that

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future development under the current UDSP would blend in with the existing urban landscape and would appear as an extension of existing development. The height, bulk and scale of buildings under the current UDSP would be of a similar scale to existing development on the project site and in the project vicinity. There would be visual continuity and coherence with exist ing development. For the renderings that represent views from Twin Oaks Valley Road (Figures 3a, 4a , 5a and 6a), views to area ridgelines are maintained and the ridgeline silhouettes are not interrupted.

The proposed project includes changes to the Form-Based Code in the UDSP. The proposed project would modify the Height Regulating Plan to allow for greater building heights within several areas of the UDSP with a maximum of 16 -stories (185 feet maximum) compared to the 7 -stories (90 foot maximum) under t he current UDSP. Other changes include adding new building types and providing for more flexibility and architectural variation in the building standards. These changes allow for more public open space and enhanced street-level experiences for pedestrians . An example of this is demonstrated in Figures 10a and 10b.

These figures present the view looking southeast at Twin Oaks Valley Road and North City Drive. Figure 10a shows what the development could look like under buildout of the current UDSP and Figure 10b presents an example of what the buildout could look like under the proposed project. Increasing the building height allows for a smaller building footprint at ground level which, in turn, opens up additional area for public use such as urban plazas, paseos, and other pedestrian amenities. This provides for an enhanced pedestrian experience and a sense of spaciousness and buildings are stair stepped back. Under the proposed project, there would be up to approximately 6 acres of parks and urban open space added to the UDSP planning area for a total of up to 31 acres.

Figures 3b, 4b, 5b, and 6b are renderings of what the project site would look like with buildout of the UDSP under the proposed project from several locations on Twin Oaks Valley Road. Buil dings along Twin Oaks Valley Road within the UDSP planning area could be up to 16 stories tall and would be more visually prominent that buildout under the current UDSP. From the viewing platform of Twin Oaks Valley Road and Craven Road (Figure 3b) the skyline is punctuated from the taller buildings. This represents a visual change, however this changes is still within the overall visual character of this urbanized and developed portion of the City. Taller buildings would reinforce the urbanized nature of the project site and vicinity and further establish the identity of the UDSP as the “downtown” and as a focal point for the San Marcos community and as an attraction for North County , as contemplated in General Plan Policy LU-5.2.

Implementation of the proposed project would change the visual character of the project site and surrounding by allowing taller buildings to be constructed within the UDSP. However, when considered in conte xt of the already urban nature of the site and surrounding, this change would not be significant because the proposed increase in building height would fit into the urbanized character that is planned for the project site and the existing urbanized charact er of the project vicinity. Analysis in Section 1.a concluded proposed project will result in the loss of some views of ridgelines depending on the viewing platform. This includes minor disruption of views from SR -78 eastbound at San Marcos Boulevard Overcrossing and on North Twin Oaks Valley Road at Mission Road. The proposed project results in the most disruption of views from the viewing platform of North

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Twin Oaks Valley Road and the SR -78 overcrossing. However, more than 50% of the ridgelines silhouette is maintained from this viewing platform and by reducing building footprints by building vertical instead of horizontal, views to lower portions of the hillsides are opened up in this location. When the visual change is considered, in totality, from all modeled viewing platforms locations considered in this analysis, the level of change to views of ridgelines would be less than significant and there are no new impacts related to scenic vistas.

Building Height Diagram and Cross Sections
A building height diagram and cross sections were prepared for the project. These figures depict how future buildings within the UDSP would relate to other prominent buildings in the project vicinity.

The building height diagram is included as Figure 11 and shows the relative height of future buildings under the proposed project and compares them to the relative height and existing topography of the new Kaiser Permanente building on Craven Road and Markstein Hall at CSUSM, the highest building on the CSUSM campus.

As shown on Figure 11, the Block 2 building would be approximately 150 feet in height. However, visually, it would sit below the Kaiser Permanent building and Markstein Hall when viewed from offsite. This is because the Block 2 building would sit at a lower elevation that the other two buildings, so visually, it would be less prominent from distant views. The Block 1 building would sit, visually, between the Kaiser Permanente building and Markstein Hall. When the other buildings in the project vicinity and their re lative height are considered, future development within the UDSP under the proposed height regulating plan would visually blend with other buildings in the project vicinity.

Figures 12a and 12b present cross sections of the project site. These cross sections provide an overview of how the UDSP buildings relate to the area topography and other development in the area. As shown in Figure 12a , Section AA under the proposed project (amended UDSP) , the UDSP buildings will sit, visually, below Markstein Hall at CSUSM. Thus, within the overall development of the area, the building fit in with the current visual character of the project vicinity and would not be visually prominent.

Section BB, shown in Figure 12b, shows the UDSP buildings in relationship to the Knoll Park which is located within the UDSP on the west side of Twin Oaks Valley Road. If buildout were to occur under the current plan, there would not be any buildings blocking views from Knoll Park. Under the amended condition, if building heights were ma ximized, they would intermittently block views to the east from Knoll Park, however, views to the south, north and west would remain unchanged.

The primary and secondary ridgelines are located in these southern and northern views, so views of the ridgelines would not be blocked.

While the proposed project would allow for taller buildings in some areas of the UDSP, these building would not result in a significant impact on scenic vistas. The public views from Twin Oaks Valley Road may be changed, but there would still be views to area ridgelines to the north and south of the project site. The buildings will be a similar apparent height or lower than other prominent buildings in the area, including the new Kaiser Permanente Medical Office building on Craven Road and Markstein Hall at CSUSM. The taller buildings fit into the urban landscape that is evolving south of SR-78 in the vicinity of Twin Oaks Valley Road.

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The analysis in Section 1.a, above, determined that proposed building height changes would not significantly impacts views to primary ridgelines in the northern and southern portions of the City and would not conflict with any of the applicable General Plan policies related to visual character and quality (Policies COS-3.1, COS-3.2, COS-3.3, LU-5.4, LU-5.6 and LU-6.9).

In summary, the proposed project will not result in any new significant impacts related to visual character and visual quality and the conclusions in the FEIR are still applicable to the proposed project.

Finding: There are no significant impacts for this issue area and no changes in information that would require preparation of an EIR.
d) Create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area?
FEIR Conclusion: Less than Significant. The FEIR (page 3.1 -35) concluded that the UDSP project would adhere to the standards set by the City to use downward- directed low-pressure sodium vapor lighting for outdoor lighting to preserve dark- sky conditions. The FEIR analysis concluded that impacts due to substantial light or glare would be considered less than significant.

Discussion of the Proposed Project: The UDSP area is within an urbanized portion of the City and is adjacent to areas that are already incorpo rating nighttime lighting, including CSUSM and existing commercial uses on Twin Oaks Valley Road. This includes lighting for safety, security and way findings as well as lighting to enhance architectural features of existing buildings. There is also existi ng street lighting on Twin Oaks Valley Road.

The proposed project would modify the Height Regulating Plan to allow for greater building heights within several areas of the UDSP with a maximum of 16 -stories (185 feet maximum) in some areas compared to the 7-stories (90 foot maximum) under the current UDSP. The taller buildings would be more visible in both daytime and nighttime settings and add more lighting to the project area.

Lighting requirements are incorporated in to the UDSP to ensure that future development on the site does not create a new source of substantial sky -glow, light trespass or glare that would adversely affect nighttime views.

The development proposed under the project would still be required to adhere to the lighting requirements identified in the UDSP (Chapter 6, Form -Based Code).

Per the requirements:
“Proposed street, sidewalk, path and trail lighting shall provide safe levels per City of San Marcos stand ards and shall be configured so as not to create a new source of substantial sky -glow, light trespass or glare that would adversely affect nighttime views in San Marcos Creek and its environs. In addition to City ordinances, lighting and luminaries shall comply with all State of California and County light pollution and energy consumption regulations and standards. Safe levels of lighting shall be provided using energy efficient lamp technologies such as metal halide, induction lamps, high pressure sodium, LED, or other light sources as approved by the City of San Marcos, along with luminaries designed with shades and cut -offs to eliminate off-site lighting and nighttime sky pollution. Lighting should be directed from edges

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of view corridors onto paving sur faces, rather than placing fixtures or visible sources of light in the view.”
The UDSP also identifies lighting requirements for parking structures to minimize the potential for offsite lighting and glare concerns. Per Chapter 6, Form -Based Code: “Internal lights within the parking structures shall be located, directed and shielded to prevent off-site glare.

All future development within the UDSP will continue to be required to adhere to the lighting requirements in the UDSP which requires that lighting be configured so as not to create a new source of substantial sky -glow, light trespass or glare that would adversely affect nighttime views
Nighttime lighting and associated glare can come from two sources: mobile sources and stationary sources. Mobile s ources are primarily headlights from vehicles. The proposed project reduced overall trip generation by 37% compared to the currently adopted UDSP (2014 FEIR Addendum) and 49% compared to trip generation assumed in the UDSP FEIR. This corresponds to a reduction in project- generated trips and associated lighting from vehicular headlights.

Stationary sources include building lighting, and lighting for landscaping, signage and streetlights. For the buildings proposed under the SDP, proposed fixtures are full cutoff and downward facing optics and use warm color temperatures to comply with Int ernational Dark-Sky Association (IDA) requirements. Landscape up-lighting will be low wattage, low lumen output, warm color temperature, and mounted under tree canopies . Lighting would be turned off at 11 PM to comply with IDA recommendations. Architectural renderings were created to show what the nighttime skyline could look like with buildout under the UDSP. Figures 13 and 14 present two renderings of what nighttime views could look like from Twin Oaks Valley Road. Buildings proposed under the SDP hav e also been designed to minimize the potential for glare. The building design s incorporate non-reflective glass and use recessed window frames and segmented geometry at the base of the building. These features help to minimize glare. Additionally, the project will limit lighting fixtures to be as low glare as possible while still meeting code required light levels for egres s during those times of need. Photovoltaic solar panels would be incorporated into proposed buildings. Solar panels are typically treated with anti -reflective measures and tilted. In summary, through design features and adherence to lighting requirements in the UDSP Form -Based Code, lighting and glare impacts would be less than significant.

Consistency with Applicable General Plan Policy
General Plan Policy COS -3.4 also addresses potential impacts to visual and aesthetics resources related to new light sources:

Policy COS -3.4 Evaluate potential impacts to visual and aesthetics resources, including the potential to create new light sources, while still maintaining and being sensitive to rural lighting standards.

This policy addresses new sources of night lighting and sensitivity to rural lighting standards. The project site is located in an urbanized portion of the City where there is already lighting associated with existing development on the project site and in the vicinity. As discussed above, the projec t will adhere to the lighting requirements in the UDSP. These requirements focus on safety and security while minimizing sky -glow and light trespass that would adversely impact nighttime

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views. The potential for the project to impact visual and aesthetics resources is more broadly analyzed in Section 1.a and 1.c, above, and the analysis concluded that impacts would be less than significant. The proposed project is consistent with Policy COS-3.4.

The proposed project does not result in any changes in the FEIR conclusion related to lighting and glare. Thus , the previous conclusions in the FEIR are still applicable to the proposed project.

Finding: There are no significant impacts for this issue area and no changes in information that would require preparation of an EIR.

2. AGRICULTURE AND FORESTRY RESOURCES – In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1 997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resource Board. Would the project:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
FEIR Conclusion: No Impact. The Initial Study of the FEIR determined that the project would not impact agricultural resources. According to the California Department of Conservation’s San Diego County Important Farmland Map 2006, portions of the UDSP site are identified as Grazing L and and Farmland of Local Importance. The remaining part of the project area is either unmapped or identified as urban/built -up land. While historically the UDSP site supported agriculture, there are no existing agricultural operations today. Additionally, while the site contains areas mapped as Farmland of Local Importance and Grazing Land, impacts to these lands would be less than significant, as the viability and feasibility of new or ongoing grazing or agricultural operations at that location are unlikely due to the existing development in the area, including residential uses (page 5-1).

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two pa rcels. APN 220 -201-90-00 is 6.3 acres and is not identified as prime farmland, unique farmland or farmland of statewide importance. Grading has commenced on this parcel consistent with a prior entitlement that was subject to CEQA review (ND 06-748). APN 220-202-18-00 is 1.7 acres and owned by NCTD.

This parcel is not identified as prime farmland, unique farmland, or farmland of statewide importance. Within the UDSP this parcel would be designated as Office/Commercial with a Railroad ROW ove rlay. No development is proposed

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within this parcel. Removal of the Railroad ROW overlay would require an Administrative Amendment and subsequent CEQA review prior to any development on the site. Therefore, n o new impacts are identified for this issue area and the previous FEIR conclusions are still app licable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Conflict with existing zoning for agricultural use or a Williamson Act contract? FEIR Conclusion: No Impact. The FEIR prepared for the UDSP concluded that implementation of the Specific Plan would not have any impacts related to Williamson Act Contracts, since no contracts were associated with the project site (page 5-1).

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels. APN 220-201-90-00 is 6.3 acres and is not zoned for agricultural use nor subject to a Williamson Act contract. Grading has commenced on this parcel consistent with a prior entitlement that was subject to CEQA review (ND 06-748).

APN 220-202-18-00 is 1.7 acres and owned by NCTD. This parcel is currently designated as Business Park within the HOCSP and is not identified as being subject to a Williamson Act contract . Within the UDSP this parcel would be designated as Office/Commercial with a Railroad ROW overlay. No development is proposed within this parcel. Therefore, n o new impacts are identified for this issue area and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51140(g))?
FEIR Conclusion: No Impact. The FEIR (page 5 -1) determined that there is no forest land or timberland located on the UDSP site.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels . APN 220 -201-90-00 is 6.3 acres is not zoned for forest land or timberland nor is it adjacent to lands zoned for such uses. The site is currently identified as Business Park within the HOCSP. Grading has commenced on this parcel consistent with a prior entitlement that was subject to CEQA review (ND 06- 748). APN 220-202-18-00 is 1.7 acres and owned by NCTD. Within the UDSP this parcel would be designated as Office/Commercial with a Railroad ROW overlay.

There are no a spects of the project that would result in a conflict with existing zoning for forest land, timberland, or timberland zoned timber production as defined by Government Code section 51120(g). Therefore, n o new impacts are

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identified for this issue area and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
d) Result in the loss of forest land or conversion of forest land to non-forest land use?
FEIR Conclusion: No Impact. The FEIR (page 5 -1) determined that there is no forestland on the UDSP site.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels. APN 220 -201-90-00 is 6.3 acres and does not support any forest land nor is it adjacent to forest land. Grading has commenced on this parcel consistent with a prior entitlement that was subject to CEQA review (ND 06-748).

APN 220-202-18-00 is 1.7 acres and owned by NCTD. Within the UDSP this parcel would be designated as Office/Commercial with a Railroad ROW overlay. There are no aspects of the project that would result in loss of forest land or a conversion of forest land to non-forest land use. Therefore, no new impacts are identified for this issue area and the previous FEIR conclusions are still app licable for the proposed project.

Finding: There are no new impacts for this issue are a and no changes in information that would require preparation of an EIR.
e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?
FEIR Conclusion: Partially Analyzed/No Impact. The FEIR (page 5 -1) determined that there are no forest lands or farmlands on the UDSP site.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels. APN 220-201-90-00 is 6.3 acres and is not zoned for an agricultural, forest land or timberland use nor is it adjacent to lands zoned for such uses. The site is curre ntly identified as Business Park within the HOCSP. Grading has commenced on this parcel consistent with a prior entitlement that was subject to CEQA review (ND 06-748). APN 220-202-18-00 is 1.7 acres and owned by NCTD.

Within the UDSP this parcel would be designated as Office/Commercial with a Railroad ROW overlay and no development would occur on the 1.7-acre site. There are no aspects of the project which would result in changes to the existing environment which, due to their location or nature, could re sult in conversion of Farmland to non -agricultural use or conversion of forest land to non -forest use.

Therefore, no new impacts are identified for this issue area and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

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3. AIR QUALITY – Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of the applicable air quality plan? FEIR Conclusion: Less than Significant. The FEIR (page 3.2 -19) concluded that the emissions budget for the UDSP project would be consistent with the established San Diego Air Pollution Control District (SDAPCD) Regional Air Quality Strategies (RAQS). The location of the UDSP would reduce vehicular trips, encourage use of the SPRINTER train and alternative transportation. The FEIR concluded that impacts were less than significant for this issue area.

Discussion of the Proposed Project: The proposed project is related to the RAQS and/or the State Implementation Plan (SIP) through the land use and growth assumptions that are incorporated into the air quality planning process. The current air quality planning process would have considered the existing UDSP. The proposed project would decrease the overall intensity of development compared to what is allowed under the current UDSP and what was analyzed in the UDSP FEIR and 2014 Addendum. This results in a reduced amount of air emissi ons.

According to the air quality analysis prepared for the project, the project’s construction and operational emissions will be reduced for all analyzed criteria pollutants compared to the currently approved plan (LDN 2022a). Therefore, the proposed proj ect would not conflict with or obstruct implementation of the applicable air quality plan and impacts remain less than significant.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
FEIR Conclusion: Significant and Unmitigated: The FEIR cumulative air quality analysis (page 3.2-20) concluded that when carbon monoxide (CO), nitrous oxides (NOx) and reactive organic gas (ROG) emissions from operation of the UDSP are considered with the future emissions of the cumulative projects, a significant cumulative impact would occur. The FEIR included mitigation measures to reduce some of the project emissions; however, it was determined t hat impacts would not be reduced to below a level of significance.

Discussion of the Proposed Project: The proposed project would decrease the overall intensity of development within the UDSP planning area. This results in a decrease in trip generation of 49% compared to the UDSP FEIR. This result s in a corresponding reduction in vehicular-related air emissions. Air quality emissions from project construction and operations were analyzed by LDN Consulting (2022a) and the analysis is included in Appendix B of this document. Based upon the analysis prepared by LDN, construction and operational emissions under the proposed project would be lower for all analyzed criteria pollutants (ROG, NOx, CO, SOx, PM10, PM2.5) compared to the emissions anticipated under the current UDSP

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(LDN 2022a). Tables 2 and 3 present the results on the comparative analysis for construction and operational emissions.

Table 2. Construction Emissions Comparison (UDSP vs UDSPA)

Source: LDN, 2022a

Table 3. Operational Emissions Comparison (UDSP vs UDSPA)

Source: LDN, 2022a
Therefore, air emissions generated by the project would be less than what was analyzed in the FEIR. Therefore, the conclusions in the FEIR are still applicable to the proposed project, and no new impacts beyond those identified in the FEIR are identified. Applicable air quality m itigation measures would still apply to development under the proposed project and proposed construction activities would comply with current SDAPCD requirements related to construct ion equipment emissions and control of fugitive dust generation.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
c) Expose sensitive receptors to substantial pollutant concentrations? FEIR Conclusion: Less than Significant. The FEIR (page 3.2 -15) concluded that onsite construction equipment would have a construction -related diesel exhaust health risk level probability of 0.022 percent (or 2.2 one hundredths of a percent risk per 70-year exposure duration assuming that implementation of toxics best available control technology (T-BACT) is used.

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Discussion of the Proposed Project: Development under the proposed project would be at a reduced intensity compared to what was analyzed in the FEIR. The air quality analysis (LDN 2022a) concluded that construction and operational emissions under the proposed project would be lower for all analyzed criteria pollutants (ROG, NO x, CO, SO x, PM 10, PM 2.5) compared to the emissions anticipated under the current UDSP (Tables 2 and 3). Air quality m itigation measures, as applicable , would still apply to development under the proposed project and proposed construction activities would comply with current SDAPCD requirements related to construction equipment emissions and control of fugitive dust generation.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
FEIR Conclusion: Less than Significant. The FEIR (page 3.2 -15) concluded that onsite construction equipment would have a construction -related diesel exhaust health risk level probability of 0.022 percent (or 2.2 one hundredths of a percent risk per 70-year exposure duration assuming that implem entation of toxics best available control technology (T-BACT) is used. This amount of concentration would not have a substantial impact to sensitive receptors and would be considered less than significant.

Discussion of the Proposed Project: Development u nder the proposed project would be of a type that was already considered in the UDSP FEIR but at a lower development intensity. Construction equipment would be similar in type as was considered in the UDSP FEIR. Any construction equipment would adhere to current SDAPCD requirements. The proposed project does not result in any changes in use that would increase the generation of objectionable odors.

Therefore, the conclusions of the FEIR are still applicable to the proposed project and no new impacts for this issue area would occur.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

4. BIOLOGICAL RESOURCES – Would the project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? FEIR Conclusion: Mitigated to Below a Level of Significance. The FEIR (page 3.3- 18) concluded several sensitive avian and reptilian species have been identified within the UDSP project area including Cooper’s hawk, rufous -crowned sparrow, and orange throated whiptail. These species typically nest and forage in the upland habitats (i.e., coastal sage scrub and emergent wetland) found onsite.

Upland habitat occurs within the overall UDSP project area; therefore, potential direct impacts to these species could o ccur during construction activities.

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Activities such as clearing, grubbing and grading would impact habitat where these species could live and/or forage. Mitigation identified in the FEIR would still be applicable for future development under the UDSP and when implemented, would reduce the potential direct impact to these species to below a level of significance. The mitigation includes a mix of habitat mitigation and pre - construction surveys.

Additionally, the FEIR noted that four least Bell’s vireo have been identified outside of the UDSP area within the San Marcos Creek corridor, but within 500 feet of the UDSP area. Mitigation identified in the FEIR would still be applicable to future development within the UDSP and would reduce the impact to below a level of significance.

Two sensitive plant species, southwestern spiny rush and smooth tarplant, were identified within the UDSP area in the FEIR (page 3.3 -18). The spiny rush would be preserved within biological open space. The small population (166 individuals) of smooth tarplant was found in disturbed non-native grasslands vegetation in the eastern portion of the UDSP site. Although the smooth tarplant is a California Native Plant Society (CNPS), List 1B.1 species, it is not covered by the Multiple Habitat Conservation Plan (MHCP). The City does not recognize CNPS status as a determination of sensitivity. Therefore, the FEIR did not identify any impacts related to these two plant species.

Mitigation measures identified in the FEIR (MM BIO 1A through 1E and BIO -1 through 20) would be required to be implemented, as applicable, for all future development. MM-BIO-20 requires that prior to issuance of grading permits within the project area, the City shall confirm that current biological surveys have been conducted for the area proposed to be graded and any additional consultation and permits required from the wildlife agencies have been obtained . Biological surveys shall be deemed as current if they are less than one year old.

The proposed project would not result in any new impacts related to sensitive species or increase the severity of impacts to sensitive species. Therefore, no new impacts are identified for this issue are a and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations,

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or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
FEIR Conclusion: Mitigated to Below a Level of Significance. The FEIR (page 3.3- 26) stated that the UDSP project proposes preservation of habitat, revegetation efforts, and compliance with appropriate permit conditions as determined by the CEQA process, California Department of Fish and Wildlife ( CDFW), United States Army Corp of Engineers (USACE), Regional Water Quality Board (RWQCB), and United States Fish and Wildlife Service (USFWS). Additionally, the project would mitigate impacts in a manner that are consistent with the goals of the Multiple Habitat Conservation Program (MHCP).

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels. APN 220-201-90-00 is 6.3 acres and does not support any riparian habitat or other sensitive natural communities. Grading has commenced on this parcel consistent with a prior entitlement that was subject to CEQA review (ND 06- 748). APN 220 -202-18-00 is 1.7 a cres and owned by NCTD. Within the UDSP, this parcel would be designated as Office/Commercial with a Railroad ROW overlay and no development would occur. There would be no new potential for substantial adverse effects on any riparian habitat or other sensi tive natural communities identified in local or regional plans, policies, or regulations, or by the CDFW or USFWS. Therefore, no new impacts are identified and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
FEIR Conclusion: Mitigated to Below a Level of Significance. The FEIR (page 3.3- 35) identified impacts to jurisdictional wetlands and waters, including permanent impacts to 3.06 acres and temporary impact to 2.06 acres of USACE Jurisdictional wetlands. Mitigation at a 3:1 and 2:1 ratio was identified in the FEIR for these losses and represents a total of 14.92 acres of mitigation. The FEIR also concluded that permanent impacts to 0.03 acre and temporary impacts to 0.32 acre of Jurisdictional Waters of the U.S. will be mitigated at a 1.5:1 and 1:1 ratio, respectively, for a total of 0.371 acres. Permanent impacts to 4.07 acres and temporary impacts to 2.06 acres of State Jurisdictional Wetlands will be mitigated at a 3:1 and 2:1 ratio, respectively, for a total of 16.33 acres. Additionally, before impacting those areas, the project would require a USACE Section 404 permit and RWQCB Section 401 W ater Quality Certification for impacts to USACE jurisdictional wetlands and waters. For impacts to CDFW jurisdictional areas, a Section 1600 Series Streambed Alteration Agreement would be required. Impacts were mitigated to below a level of significance.

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protected wetlands. Grading has commenced on this parcel consistent with a prior entitlement that was subject to CEQA review (ND 06 -748). APN 220 -202- 18-00 is 1.7 acres and owned by NCTD. Within the UDSP, this parcel would be designated as Office/Commercial with a Railroad ROW overlay and no development would occur on the 1.7-acre site. Therefore, there would be no new potential for the project to have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue are a and no changes in information that would require preparation of an EIR.
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? FEIR Conclusion: Mitigated to Below a Level of Significance. The FEIR (page 3.3- 20) concluded that the UDSP project site supports a local corridor within the northwestern portion of the project boundary. This corridor consists primarily of San Marcos Creek and associated riparian habitat. The UDSP was designed to minimize impacts to the San Marcos Creek channel; however, installation of the Grand Avenue bridge and development slopes associated with the project could result in temporary and permanent impacts to the creek which serves as a wildlife corridor. Noise, equipment and human intrusion associated with the construction of the bridge could temporarily disrupt the movements of wildlife that uses the corridor; however, impacts were determined to be less than significant. Biological resources mitigation measures were included in the FEIR and were determined to reduce impacts to below a level of significance.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels. APN 220 -201-90-00 is 6.3 acres and grading has commenced on this parcel consistent with a prior entitlement that was subject to CEQA review (ND 06-748). APN 220-202-18-00 is 1.7 acres and owned by NCTD. Within the UDSP, this parcel would be designated as Office/Commercial with a Railroad ROW overlay and no development would occur on the 1.7-acre site. According to Figure 4-2 of the Conservation and Open Space Element of the City’s General Plan, neither of these parcels are identified as a wildlife corridor or linkage (San Marcos 2012). Therefore, there would be no new potential for the project to interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or mig ratory wildlife corridors, nor impede the use of native wildlife nursery sites . Therefore, the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

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FEIR Conclusion: No Impact. The FEIR (page 3.3-25) identified that the City does not currently have any tree preservation polices and no impact was identified for this issue area.

Since certification of the FEIR, the City’s General Plan was updated and includes a policy related to tree replacement. General Plan Policy COS -2.6 requires that any removed trees be replaced at a 1:1 ratio. Future development within the UDSP area would be required to adhere to the City’s tree replacement policy. Therefore, no new impacts are identified for this issue area and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan?
FEIR Conclusion: Less than Significant. The FEIR (page 3.3-25) identified that the UDSP project area is located within the City’s Subarea Plan (not yet adopted) and is part of the adopted MHCP. The FEIR concluded that mitigation proposed for impacts to sensitive habitat and sensitive species is consistent with the recommendation of the MHCP. The FEIR did not identify any impacts for this issue area.

Discussion of the Proposed Project: The City’s Subarea Plan has not been adopted. Development under the proposed project would still occur within th e footprint analyzed in the FEIR, with the addition of the two parcels. APN 220-201- 90-00 is 6.3 acres and does not support any federally protected wetlands.

Grading has commenced on this parcel consistent with a prior entitlement that was subject to CEQA review (ND 06 -748). APN 220-202-18-00 is 1.7 acres and owned by NCTD. Within the UDSP, this parcel would be designated as Office/Commercial with a Railroad ROW overlay and no development would occur on the 1.7-acre site. There are no aspects of the project which would conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan. Therefore, the previous FEIR conclusions are still applicabl e for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

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5. CULTURAL RESOURCES – Would the project:
a) Cause a substantial adverse change in the significance of a historical resource as defined in §15064.5?
FEIR Conclusion: Less Than Significant . The FEIR concluded that there were t wo historical resources located within the project area (page 3.4 -4): 1) ASM 12760 A&B consists of concrete foundation pads for a post-1945 chicken coop, as well as a concrete drain; and 2) ASM 127760 C consists of concrete foundation pads for a post -1945 chicken coop. The FEIR (page 3.4 -9) concluded that these structures were not eligible for listing on the California Register of Historical Resources and concluded that impacts to historical resources would be less than significant.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
FEIR Conclusion: Mitigated to Below a Level of Significance. The FEIR (page 3.4- 9) identified the following previously -identified archaeological resources within the UDSP project area: 1) SDI-17896, a single bedrock outcrop with three grinding slicks; 2) SDI -17897, a single bedrock grinding slick; and 3) SDI -17898, consisting of a concrete pad with floor tiles, remains of a chimney -like structure, and historic/modern debris. Native American consultation noted that subsurface cultural deposits may exist on the project site and the potential for a significant impact. Mitigation measures were identified in the FEIR to reduce the impact to below a level of significance (MM CR-1 through CR-5).

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through CR —4, which address archaeological monitoring requirements during grading. Additionally, any future development that results in grading is subject to the City’s standard conditions of approval that r equire monitoring by an archaeologist and Native American tribal monitor for any grading activities that occur in previously undisturbed areas. These standard conditions have been developed in coordination with local tribes. There are no aspects of the pro ject which would cause a substantial adverse change in the significance of a n archaeological resource as defined in §15064.5. Therefore, no new impacts are identified for this issue area and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
c) Disturb any human remains, including those interred outside of formal cemeteries?
FEIR Conclusion: Less than Significant Impact. The FEIR (page 3.4 -9) did not identify any human remains or find any indications that they would be expected to be found on the UDSP site.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels. APN 220-201-90-00 is 6.3 acres. Grading has commenced on this parcel consistent with a prior entitlement that was subject to CEQA review (ND 06- 748). APN 220-202-18-00 is 1.7 acres and owned by NCTD. This site is currently designated as Business Park within the HOCSP. Within the UDSP, this parcel would be designated as Of fice/Commercial with a Railroad ROW overlay and no development is proposed within this parcel. Future development within the UDSP planning area will be required to adhere to mitigation measures CR-1 through CR— 5, which address archaeological monitoring du ring grading and the treatment of human remains should they be encountered during grading. Additionally, a ny future development that results in grading is subject to the City’s standard conditions of approval that require monitoring by an archaeologist and Native American tribal monitor for any grading activities that occur in previously undisturbed areas. These standard conditions have been developed in coordination with local tribes. There are no aspects of the project that would increase the potential to disturb human remains, including those interred outside of a formal cemetery.

Future development would be required to adhere to the California Health and Safety Code Section 7050.5, which requires that 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 Office by telephone. Therefore, n o new impacts are identified for this issue area and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

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6. ENERGY – Would the project:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation?
FEIR Conclusion: Not Analyzed. The requirement to analyze a project’s potential impacts related to energy demand and use as a separate environmental topic became a requirement after certification of the FEIR.

Discussion of the Proposed Project: Energy use model ing was prepared by Ldn Consulting to determine the anticipated energy use with buildout of the currently approved UDSP and buildout of the proposed project. The analysis memorandum is included as Appendix C. Table 4 presents a summary of anticipated energy use under the currently adopted UDSP and the proposed project (UDSPA).

Table 4. Energy Use Comparison

Source: LDN 2022b
As shown in Table 4, the UDSPA is estimated to use 14,622,800 kBTU less natural gas annually and 9,261,600 kWh less electrical energy annually when compared to the UDSP.

Since certification of the FEIR there have been additional requirements related to energy efficiency through Title 24 of the California Building Code (2019). This analysis assumed reductions from Title 24 compliance which would improve the efficiency of the project in terms of energy consumption. Additionally, future development proposed within the UDSP will be required to comply with the City’s Climate Action Plan which includes measures related to energy conservation. This will further decrease the energy use for the project. Based on this, energy use associated with UDSPA operation would not result in wasteful, inefficient, or an unnecessary use of energy.

Finding: There are no new significant impacts for this issue area and no changes in information that would require preparation of an EIR. b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
FEIR Conclusion: Not Analyzed. The requirement to analyze a project’s potential to conflict with or obstruct a state or local plan for renewable energy or energy efficiency as a separate environmental topic became a requirement after certification of the FEIR.

Discussion of the Proposed Project: Development under the proposed project would still be of the type considered in the UDSP FEIR, however the intensity of development would decrease. As shown in Table 4, the UDSPA is estimated to

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consume 14,622,800 kBTU less natural gas annually and 9,261,600 kWh less electrical energy annually when compared to the currently approved UDSP. The proposed project would follow applicable energy standards and regulations during the construction and operation p hases. Additionally, the proposed project would be built and operated in accordance with all existing, applicable building regulations at the time of construction. Furthermore, the proposed project would be consistent with all actions in the Climate Action Plan ( CAP) Consistency Worksheet (Appendix D). 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.

Finding: There are no new significant impacts for this issue area and no changes in information that would require preparation of an EIR.

7. GEOLOGY AND SOILS – Would the project:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? (Refer to Division of Mines and Geology Special Publication 42.)
FEIR Conclusion: Less than Significant. The FEIR (page 3.5-6) did not identify any known active faults within or adjacent to the UDSP site. The UDSP site is not located within a mapped Alquist -Priolo Earthquake Fault Zone as shown on United States Geological Survey (USGS) or California Geologica l Survey (CGS) maps.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of two parcels, APN 220-201-90-00 and APN 220-202-18-00. These parcels are not delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map (CDC 2021). Nor are these parcels otherwise identified as containing a fault.

Additionally, a preliminary geotechnical investigation for APN 220-201-90-00 was prepared as part of the prior entitlement for the site and concluded that there are no geologic hazards on this parcel and that no faults are located on this parcel (Robert Prater Associates 2005) as referenced in ND06 -748 (City of San Marcos 2006). Therefore, no new impacts are identified for this issue area and the previous FEIR conclusions are still app licable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
ii) Strong seismic ground shaking?
FEIR Conclusion: Less than Significant. The FEIR (page 3.5-6) concluded that since future development would be held to the requirements of the Uniform

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Building Code (UBC) for Zone 4 for resistance to seismic shaking, a less than significant impact would occur.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels: APN 220 -201-90-00 and APN 220 -202-18-00. Any future development on these parcels would be required to comply with the UBC for resistance to seismic shaking. Therefore, n o new impacts are identified for this issue area and the previous FEIR conclusions are still app licable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
iii) Seismic-related ground failure, including liquefaction? FEIR Conclusion: Less than Significant. The FEIR (page 3.5-9) concluded the project area is not susceptible to liquefaction due to such factors as density and grain size distribution of the relatively thin and dense colluvial soils, Santiago Formation and granitic rock underlying the site. Based on the soil type on the project site and lightly occurring groundwater, impacts from liquefaction would be less than significant.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels: APN 220-201-90-00 and APN 220-202-18-00. According to Figure 6 -1, Geologic Hazards - Soils Slippage Susceptibility (Landslides/ Liquefaction) of the Safety Element of the San Marcos General Plan, these two parcels are identified as having zero susceptibility for geologic hazards.

Additionally, a preliminary geotechnical investigation for APN 220-201-90-00 was prepared as part of the prior entitlement for the site and concluded that there are no geologic hazards on this parcel (Robert Prater Associates 2005) as referenced in ND06 -748 (City of San Marcos 2006). No development is proposed on APN 220 -202-18-00. This parcel is owned by NCTD and would have a Railroad ROW overlay assigned to it in the UDSP. Remo val of the overlay would require and Administrative Amendment and subsequent CEQA review. Therefore, n o new impacts are identified for this issue area and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
iv) Landslides?
FEIR Conclusion: Less than Significant. As described in the FEIR (page 2-13), the UDSP area ranges from 550 to 710 feet above mean sea leve l (AMSL) elevation. The UDSP area is underlain with Cretaceous-aged granitic rock and sandy and silt loam soils. These identified soils and elevations would not be subject to landslides; therefore, impacts due to landslides were determined to be less than significant.

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Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels: APN 220-201-90-00 and APN 220-202-18-00. According to Figure 6-1, Geologic Hazards - Soils Slippage Susceptibility (Landslides/ Liquefaction) of the Safety Element of the San Marcos General Plan, these two parcels are identified as having zero susceptibility for geologic hazards, including landslides. Additionally, a preliminary geotechnical investigation for APN 220-201-90-00 was prepared as part of the prior entitlement for the site and concluded that there are no geologic hazards on this parcel (Robert Prater Associates 2005) as referenced in ND06-748 (City of San Marcos 2006). No development is proposed on APN 220 -202-18-00. This parcel is owned by NCTD and would have a Railroad ROW overlay assigned to it in the UDSP.

Removal of the overlay would require and Administrative Amendment and subsequent CEQA review. Ther efore, no new impacts are identified for this issue area and the previous FEIR conclusions are still app licable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Result in substantial soil erosion or the loss of topsoil? FEIR Conclusion: Less than Significant. The FEIR (page 3.5 -9) identified soil materials on the UDSP project site to range from slight to high potential for erosion. Since the slopes would be constructed using fill material generated from the cut portions of the site, many of the constructed fill slopes would be prone to superficial erosion, especially during periods of rain. The FEIR noted that implementation of a project -specific Erosio n Control Plan and a Storm Water Pollution Prevention Plan (SWPPP) in accordance with the California State Water Resources Control Board Order No. 92 -08-DWQ, NPDES General Permit No.

CAS000002 would reduce any impacts due to soil erosion. The SWPPP would comply with Best Available Technology (BAT) and Best Conventional Pollutant Control Technology to reduce or eliminate storm water pollution from areas of construction activity.

Discussion of the Pr oposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels: APN 220-201-90-00 and APN 220-202-18-00. Future development within the Specific Plan area would be req uired to comply with the City’s BMP Design Manual. Adherence to the requirements in the BMP Design Manual along with a SWPPP , would minimize the potential for erosion and runoff from rain events. Therefore, n o new impacts are identified for this issue area and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

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c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? FEIR Conclusion: Mitigated to Below a Level of Significance . The FEIR (page 3.5- 7) identified the UDSP area as being underlain with Santiago Formation and granitic rock, which are typically not susceptible to liquefaction. The soils derived from the underlain material and bedrock includes very fine to coarse sandy loams and rocky silt loams. Based on the underlying bedrock and the soil composition of the project site, the FEIR determined that impacts due to landslides would be considered less than significant. The FEIR (page 3.5 -10) also identified compressible soils located in a portion of the project area located along Barham Drive and mitigation was identified to reduce the potential impact to below a level of significance (GEO-1). Mitigation measures were identified in the FEIR and would still be applicable to the proposed project.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEI,R with the addition of the two parcels: APN 220-201-90-00 and APN 220-202-18-00. According to Figure 6- 1, Geolog ic Hazards- Soils Slippage Susceptibility (Landslides/ Liquefaction) of the Safety Element of the San Marcos General Plan, these two parcels are identified as having zero susceptibility for geologic hazards, including landslides and liquefaction. Additiona lly, a preliminary geotechnical investigation for APN 220-201-90-00 was prepared as part of the prior entitlement for the site and concluded that there are no geologic hazards on this parcel (Robert Prater Associates 2005) as referenced in ND06 -748 (City o f San Marcos 2006). APN 220-202-18-00 is owned by NCTD and serves as an emergency access and maintenance access point for the SPRINTER rail line. It would be designated as Office/Commercial within the UDSP with a Railroad ROW overlay. No development is proposed within this parcel. Removal of the Railroad ROW overlay would require an Administrative Amendment and subsequent CEQA review prior to any development on the site. Therefore, n o new impacts are identified for this issue area and the previous FEIR conc lusions are still app licable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
d) 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? FEIR Conclusion: Less than Significant. The FEIR (page 3.5-9) identified the UDSP area to consist predominantly of very fine to course, well -drained sandy loams, which have a lo w potential for expansion. Impacts were determined to be less than significant.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcel s: APN 220 -201-90-00 and APN 220 -202-18-00. A preliminary geotechnical investigation for APN 220 -201-90-00 was prepared as part of the prior entitlement for the site and concluded that there are no geologic hazards on

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this parcel (Robert Prater Associates 2005 ) as referenced in ND06 -748 (City of San Marcos 2006). This study did not identify any expansive soils on the parcel.

APN 220-202-18-00 is owned by NCTD and serves as an emergency access and maintenance access point for the SPRINTER rail line. It would be designated as Office/Commercial within the UDSP with a Railroad ROW overlay. No development is proposed within this parcel. Removal of the Railroad ROW overlay would require an Administrative Amendment and subsequent CEQA review prior to any development on the site. Therefore, n o new impacts are identified for this issue area and the previous FEIR conclusions are still app licable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
FEIR Conclusion: No Impact. The FEIR (page 3.5 -9) identified that the UDSP project would not be serviced by either septic tanks or alternative wastewater disposal system.

Discussion of the Proposed Project: The use of septic tanks or alternative wastewater disposal systems is not proposed under the proposed project. Water and wastewater services would be provided by Vallecitos Water District (VWD).

Therefore, no new impacts are identified for this issue area and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
FEIR Conclusion: Less than Significant. The FEIR (page 3.4-9) identified that new ground-disturbing activity has the potential to unearth previously unidentified paleontological resources, particularly in areas underlain by sedimentary formations. However, due to the young age of the Quaternary alluvial deposits on the project site, the potential for paleontological resources was determined to be low. Impacts were determined to be less than significant.

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identified for this issue area and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

8. GREENHOUSE GAS EMISSIONS – Would the project:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
FEIR Conclusion: Significant and Unmitigated. The FEIR (page 3.2 -20) analyzed both construction and operational GHG emissions. Impacts were determined to be less than significant as the UDSP project would reduce GHG emissions by approximately 43 percent below “business as usual”. The FEIR (page 3.2 -30) concluded that project-level GHG impacts were less than significant.

With regard to cumulative GHG emissions, even with implementation of sustainable policies and reduction measures identified as part of the pro ject, cumulative greenhouse gas emissions were determined to be significant and unmitigable due to the legal, regulatory, and factual uncertainty regarding the proper greenhouse gas significance threshold, the method for creating thresholds, and the effect iveness of mitigation measures in actually reducing greenhouse gas emissions (page 7-2). These uncertainties made it speculative to conclude that cumulative impacts are adequately reduced to below a level of significance.

Discussion of the Proposed Project: Since certification of the FEIR, the City of San Marcos adopted a Climate Action Plan (CAP). A project applicant can demonstrate compliance with the CAP by filling out the CAP Consistency Review Checklist (CAP Checklist). Consistency with the CAP would allow the City to determine that GHG impacts would be less than significant. The completed CAP Consistency Worksheet is included as Appendix D of this document.

Analysis Methodology
The CAP Consistency Guidance Memo summarizes the methodology and application of a GHG screening threshold which is set at 500 metric tons of carbon dioxide equivalent (MTCO2e) per year (Ascent Environmental 2020). Projects that are projected to emit fewer than 500 MTCO 2e annually would not make a considerable contribution to the cumulative impact of climate change and would not need to provide additional analysis to demonstrate consistency with the CAP.

This screening threshold is for new development projects consistent with the City’s General Plan. When such a project exceeds t he screening threshold, the project would be required to demonstrate consistency with the CAP through the CAP Checklist.

In most cases, compliance with the CAP Checklist would provide a streamlined CEQA review path to allow project specific environmental documents, if eligible, to tier from and/or incorporate by reference the CAP’s programmatic review of GHG impacts. Projects that are consistent with the General Plan and implement CAP GHG reduction measures may incorporate by reference the CAP’s cumulative GHG analysis. The City’s CAP meets the requirements under Section 15183.5 of

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the CEQA Guidelines as a qualified plan for the reduction of GHG emissions for use in cumulative impact analysis pertaining to development projects.

If a project is consistent with the existing General Plan land use designation(s), it can be determined to be consistent with the CAP projections and can move forward to Step 2 of the CAP Checklist. For projects seeking a plan amendment, such as the proposed project, the CAP Checklist requires a comparative analysis to determine if the amendment results in an equivalent or less GHG- intensive project when compared to the existing designations. In addition to providing evidence to support the conclusion that the project would generate fe wer emissions than existing designations, these projects would demonstrate consistency with the CAP through completion of Step 2 of the CAP Checklist (CAP Measures Consistency)
If a land use designation amendment results in a more GHG-intensive project, the project is required to prepare a quantitative GHG analysis based on applicable sections of the CEQA Guidelines.

Analysis
A Greenhouse Gas Assessment was prepared by LDN Consulting (202 2c) to compare the anticipated GHG emissions for buildout of the UDSP under the proposed project compared to buildout under the currently approved UDSP. Table 5 presents the anticipated emissions under the current UDSP and Table 6 presents the emissions anticipated under the proposed UDSP amendment. The complete analysis is included within Attachment C of this document.

Table 5. Operational Emissions – Currently Adopted UDSP

Source: LDN 2022c
Table 6. Operational Emissions – Proposed UDSPA

Source: LDN 2022c

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When the proposed project GHG emissions (Table 6) are compared to the GHG emission under the current UDSP (Table 5), the project results in a 19% reduction in GHG emissions (70,050 MT CO2e per year compared to 86,086 MT CO2e per year). This reduction is largely driven by the reduced number of vehicle trips th at would occur under the proposed project compared to buildout under the current UDSP. Therefore, the project would be consistent with the City’s CAP and would be required to implement CAP measures applicable to each land use identified within the UDSPA. Based on this, a less than significant impact would be expected on the environment with respect the GHG emissions from the project.

Finding: There are no new significant impacts for this issue area and no changes in information that would require preparation of an EIR. b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
FEIR Conclusion: Significant and Unmitigated. With regard to cumulative GHG emissions, even with implementation of sustainable policies and reduction measures identified as part of the project, cumulative greenhouse gas emissions were determined to be significant and unmitigable due to the legal, regulatory, and fa ctual uncertainty regarding the proper greenhouse gas significance threshold, the method for creating thresholds, and the effectiveness of mitigation measures in actually reducing greenhouse gas emissions (page 7 -2). These uncertainties made it speculative to conclude that cumulative impacts are adequately reduced to below a level of significance.

Discussion of the Proposed Project: Per the City’s CAP Consistency Guidance Memo, CAP consistency can be assumed as long as the amendment results in an equivalent or less GHG -intensive project when compared to the existing designations. In addition to providing evidence to support the conclusion that the project would generate fewer emissions than existing designations, these projects would demonstrate consistency with the CAP through completion of Step 2 of the Checklist. As detailed in 8.a, above, the proposed project was anticipated to emit 70,050 MT CO2e per year and buildout under the current UDSP would generate 86,086 MT CO2e per year. The project results in a 19% reduction in GHG emissions compared to buildout of the UDSP. Based on this, a less than significant impact would be expected by the proposed project.

Finding: There are no new significant impacts for this issue area and no changes in information that would require preparation of an EIR.

9. HAZARDS AND HAZARDOUS MATERIALS – Would the project:
a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
FEIR Conclusion: Mitigated to Below a Level of Significance. As identified in the FEIR (page 3.6 -6), there is potential for accidental upset of fuels, lubricants or various other liquids needed for the operation of construction equipment.

Mitigation was included in the FEIR to reduce the potential for impacts to below a

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level of significance (BIO-1C). This mitigation measure requires a 100-foot buffer between fueling area and sensitive habitat.

Discussion of the Proposed Project: Fueling of construction equipment would still be required during construction under the proposed project. Mitigation identified in the FEIR would still be applicable and would ensure that impacts remain mitigated to below a level of significance. Therefore, no new impacts are identified for this issue area and the previous FEIR conclusions are still app licable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
FEIR Conclusion: Less than Significant. As identified in the FEIR (page 3.6 -8), potential impacts related to hazardous materials were identified due to the presence of lead-based paint, pesticide use, solid waste disposal, and asbestos- containing materials. Mitigation was included in the FEIR to reduce these impacts to below a level of significance. These measures require testing for lead -based paint and asbestos prior to demolition (HAZ -1 and HAZ -2). The mitigation also requires the clean-up of debris on the project site (HAZ -3) and testing of soils in areas where previous agricultural activities occurred (HAZ-4).

Discussion of the Proposed Project: The demolition of building s would still be required as the UDSP builds out. Mitigation identified in the FEIR that addresses the potential for lead -based paint and asbestos -containing materials would still be applicable and would ensure that impacts remain mitigated to below a level of significance (HAZ-1 and HAZ -2). Additionally, soil testing would still be required per HAZ-3. Therefore, n o new impacts are identified for this issue area and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue a rea and no changes in information that would require preparation of an EIR.
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? FEIR Conclusion: Less than Significant. As identified in the FEIR (page 3.6 -5), there are no known public or private schools located within one -quarter mile of the proposed project that would subject sensitive receptors to any hazardous materials due to the pro posed project. Impacts related to this topic were determined to be less than significant during the Initial Study process for the FEIR.

Discussion of the Proposed Project: There are no changes in proposed uses within the proposed Specific Plan Amendment, just a redistribution of some of the uses within the overall UDSP planning area. The proposed uses are of a type that were considered in the FEIR at an overall reduced inten sity. These uses would not be characterized as uses that would emit hazardous emissions or handle hazardous or acutely hazardous materials, substance, or waste. Therefore, no new impacts

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are identified for this issue area and the previous FEIR conclusions are still applicable for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? FEIR Conclusion: Less than Significant. The FEIR (page 3.6-2) included a hazards database records search. The database search did not identify any areas of concern within the UDSP area and impacts were determined to be less than significant.

Discussion of the Proposed Project: At the time of t he FEIR records search, the Unocal Station on 102 East Carmel Street was the nearest leaking underground storage tank (LUST) located east of Twin Oaks Valley Road. The LUST case has completed corrective action and the case was closed as of March 30, 2011. A recent review of the Department of Toxic Substance Control Database (EnviroStor) on January 24, 2022 did not identify any new areas of concern within the UDSP planning area, including the 8 acres that are proposed to be added to the planning area since a doption of the FEIR 1. The previous conclusion of less than significant impact for this issue area is still applicable to the proposed project and no new impacts are identified for this issue area.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
FEIR Conclusion: Less than Significant. The FEIR (page 3.6 -5) noted that the nearest airport is McClellan -Palomar airport, located approximately five miles west of the UDSP area. The influence area is regulated by the Airport Land Use Commission (ALUC), which regulates land uses in the area to be compatible with airport-related noise, safety, airspace protection, and over -flight factors. The project area is lo cated within Review Area 2, which consists of limits on heights of structures in areas of high terrain. Impacts were determined to be less than significant as part of the Initial Study process for the FEIR.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of two parcels, which are proposed to be brought into the UDSP boundary (APNs 220 - 201-90-00 and 220-202-18-00).

1 http://www.envirostor.dtsc.ca.gov/public/

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The proposed project would allow for greater building heights within several areas of the UDSP with a maximum of 16-stories (185 feet maximum) compared to the 7-stories (90 foot maximum) under the current UDSP. All development on the site would be situated at a lower elevation than adjacent topography, including the hills to the southeast of CSUSM.

As part of the review for the project, the City contacted the San Diego County Regional Airport Authority (SDCRAA) Airport Land Use Commission (ALUC). The letter from the SDRAA is included as Appendix E of this document (SDRAA 2021).

The ALUC reconfirmed that the project site is within the Airport Influence Area (AIA) of the adopted Airport Land Use Compatibility Plan (ALUCP) for the McClellan - Palomar Airport in Carlsbad, specifically in Review Area 2. The ALUC indicated that the project requires no submission to the ALUC for a consistency determination.

However, the ALUCP reinforces existing federal and state requirements regarding Federal Aviation Administration (FAA) review of proposed projects within the AIA, which requires project sponsors to file an FAA Notice of Proposed Construction or Alteration (Form 7460 -1) to address potential airspace conflicts, unless determined unnecessary.

In accordance with the adopted McClellan-Palomar Airport ALUCP and Title 14 of the Code of Federal Regulations (14 CFR) Part 77, the ALUC requests that prior to construction or alteration of existing structures that fall within the jurisdiction of the City of San Marcos and the AIA, the necessary notice information be provided to the FAA. If the FAA determines that the proposed structure or temporary construction crane would be a haza rd or obstruction to air navigation the proposed project would then require submittal to the ALUC for review. This requirement will be included a s a condition of project approval and the City will coordinate, as required with the FAA at the time developmen t or alteration of buildings is proposed.

The project would not result in a safety hazard from airport traffic for people residing or working in the project area. The previous conclusion of less than significant impact for this issue area is still applicable to the proposed project and no new impacts are identified for this issue area.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
FEIR Conclusion: No Impact. The UDSP Initial Study (page 21, see Appendix A.2 of the FEIR) concluded that the additional roadway access will improve circulation, allowing for improved emergency services access and would not physically interfere with any adopted emergency response pl ans or emergency evacuation plans. No impact was identified for this issue area in the FEIR.

Discussion of the Proposed Project: Development under the proposed project would still provide the roadway connections via the improvement of both onsite and offsite roadways. Under the proposed project, Mid -City Lane would change from a public vehicular route to a public pedestrian paseo. The paseo would be designed in a manner that would still accommodate emergency access.

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Modifications to the design of North City Drive would include a median that would be designed in a manner so that emergency response vehicles could cross over it., if needed. The project also includes underground parking within a structure.

The parking entrance and circulation within the structur e has been designed to accommodate emergency response vehicles. Finally, t he Fire Marshal has reviewed the proposed SDP for Phases 1 and 2 and has not indicated any issues related to emergency response planning or evacuation. Thus, the conclusions in the FEIR are still applicable to the proposed project and no new impacts are identified.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
g) Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?
FEIR Conclusion: Less than Significant. The FEIR identified that approximately 50 percent of the UDSP area is undeveloped and supports vegetation and noted that the proposed UDSP development with maintained parks and urban open spaces would reduce the danger of wildfires. Per the FEIR, impacts were determined to be less than significant for the UDSP.

The project site is located in an urbanized area of the City. The project site is not located on or near lands classified as a very high fire hazard severity zone. The project site is located within a Non ‐Very High Fire Hazard Severity Zone (Non ‐ VHFHSZ) designation per CalFire’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas also identified as Non ‐VHFHSZ. Further, per Figure 6‐4 of the Safety Element of the City’s General Plan, the project si te and surrounding area are not identified as a SMFPD Community Hazard Zone. Thus, the proposed project would not expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands.

The conclusions of the FEIR are still applicable to the project and no new impacts are identified for this issue area.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

10. HYDROLOGY AND WATER QUALITY – Would the project:
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? FEIR Conclusion: Less than Significant. The FEIR prepared for the UDSP identified significant impacts related to water quality; however, mitigation measures were

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identified (HW-1 and HW-2) to reduce the impacts to below a level of significance.

These measures related to the design of the Johnsto n Lane SR-78 flyover bridge to minimize water quality impacts and the preparation of project -specific Water Quality Technical Reports as individual development projects come forward.

Discussion of the Proposed Project: Development under the proposed proje ct could still have the potential to impact water quality; however, development under the proposed project would be required to comply with the City’s BMP Design Manual. The removal of the Johnston Lane SR -78 flyover bridge also eliminates the potential impact related to the placement of bridge structural supports within the San Marcos Creek. Therefore, the proposed project does not result in any new impact beyond those identified in the FEIR and actually reduces impacts due to the avoidance of potential water quality impacts due to the Johnston Lane SR-78 flyover bridge.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there the project may impede substantial groundwater management of the basin?
FEIR Conclusion: Less than Significant. The FEIR (page 5 -2) noted that some groundwater may be used for irrigation. The FEIR noted that implementation of the Specific Plan would likely increase the amount of impermeable surface area compared to the current condition, but percolation will still occur in areas where grass, permeable pavement , and groundcover is proposed. The FEIR concluded that implementation of the UDSP would not substantially deplete groundwater supplies or interfere substantially with groundwater recharge and impacts are anticipated to be less than significant.

Discussion of the Proposed Project: The project does not propose an increase in groundwater use. Potable water service would continue to come from Vallecitos Water District (VWD) and some groundwater may be used for irrigation within the larger UDSP planning area. The conclusions of the FEIR are still applicable to the project and no new impacts are identified for this issue area.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site?
FEIR Conclusion: Less than Significant. The FEIR (page 3.7-16) identified that the UDSP project, upon build-out, is anticipated to increase flow rates in San Marcos Creek by 385.5 cubic feet per second (cfs) to 1,848.3 cfs. The San Marcos Creek flow rate during a 100-year storm event is approximately 12,400 cfs. Based upon a longer 100-year runoff time of concentration of the San Marcos Creek drainage basin, peak flows for the creek will not occur concurrently with peak flows for the

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project drainage basin. Thus, a less than significant impact was identified in the FEIR.

Development under the proposed project would be required t o comply with the City of San Marcos BMP Design Manual (2016).

The proposed project would not generate increased runoff volumes and incudes a comprehensive approach to stormwater and drainage management A stormwater quality management plan (SWQMP) was pr epared for the SDP for Phase A and B (SCE 2022 b) to handle and treat runoff and to ensure that post project runoff rates and quantities are similar to the pre-project conditions.

Runoff generated by the North City Phase A & B project will convey into a mix ed use of proposed biofiltration basins, proposed proprietary biofiltration systems, and proposed underground detention systems.

Phase A of the project consists of runoff from a proposed building and improvements at the northwest corner of North City Driv e and Campus Way that will drain into an underground detention system, UD-2, for 100-year peak flow and hydromodification mitigation. The runoff will convey into a proposed proprietary biofiltration system, PBF-2, for water quality mitigation, and finally discharge into an existing storm drain.

Phase B consists of two proposed buildings and improvements at the southwest corner of Carmel Street and Campus Way.

Runoff from the south building will convey into a proposed biofiltration basin, BF- 2, for 100-year peak flow, hydromodification, and water quality. The north building will convey into proposed biofiltration basins, BF -3 and BF -4, for 100-year peak flow, hydromodification, and water quality.

Runoff along the eastern portion of Carmel Street will drain into an existing bioretention basin, BR -9 per North City East – Unit 1 TSM 14 -002 IP-4885, for water quality. During a 100 -yr storm event, a portion of the runoff of Carmel Street, 1.90 cfs, will drain into the existing BR -9 for 100 -yr peak flow, and the portion of the street that will bypass, 0.91 cfs, will be collected in a downstream curb inlet that ultimately conveys to the public underground detention system, UD4. The proposed driveway and building in the northern portion of Phase B, will convey runoff into the proprietary biofiltration basin PBF3, for water quality, and then into the underground detention system, UD -3, for hydromodification and 100-yr peak flow. Runoff along Carmel Street will drain into a public proprietary biofiltration system, PBF -4, for water quality, and then convey into a public underground detention system, UD -4, for 100 -year peak flow and hydromodification.

The proposed project would alter the existing Carmel Street biofiltration basin in the ROW for the Phase B building deliv ery driveway. As described above, r unoff along Carmel Street will drain into a public proprietary biofiltration system, PBF-4, for water quality, and then convey into a public underground detention system, UD-4, for 100 -year peak flow and hydromodification . This alternation would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of

University District Specific Plan Amendment 58 City of San Marcos FEIR Addendum May 2022
impervious surfaces, in a manner which would result in substa ntial erosion or siltation on- or off-site. Therefore, the conclusions of the FEIR are still applicable to the proposed project and no new impacts are identified for this issue area.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
d) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
FEIR Conclusion: Less than Significant. The FEIR (page 3.7 -19) concluded that the UDSP project would maintain the same major discharge points as the existing conditions. Flow volume at identified discharge point two during a 100-year storm could not be accommodated by the existing 24 -inch storm drain. An overland release would be constructed to route some of the flow volume to discharge point three to directly discharge to San Marcos Creek, which is determined to have adequate capacity. Thus, implementation would not result in flooding.

Discussion of the Proposed Project: Development under the proposed project would require site grading and preparation of building pads which could alter the drainage pattern of the site which could contribute to erosion or siltation. As discussed in 8.c, above, development under the proposed project would be required to comply with the City’s BMP Design Manual. Additionally, a stormwater quality management plan (SWQMP) was prepared for the SDP for North City Phase A and B (SCE 2022 b), which includes structural, source control and site design BMPs. Runoff generated by the North City Phase A & B project will convey into a mixed use of proposed biofiltration basins, proposed proprietary biofiltration systems, and proposed underground detention systems. Implementation of these features would ensure that the proposed development would not substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site. Therefore, the conclusions of the FEIR are still applicable to the proposed project and no new impacts are identified for this issue area.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
e) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
FEIR Conclusion: Less than Significant. According to the FEIR (page 3.7 -19), the UDSP project would maintain the same major discharge points identified under the existing conditions. Thus, the increase in surface runoff would not exceed capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

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Discussion of the Proposed Project: Development under the proposed project would require site grading and preparation of building pads which could alter the drainage pattern of the site which could contribute to erosion or siltation. As discussed in 8.c, above, development under the proposed project would be required to comply with the City’s BMP Design Manual. Additionally, a stormwater quality management plan (SWQMP) was prepared for the SDP for North City Phase A and B (SCE 2022b). Runoff generated by the North City Phase A & B project will convey into a mixed use of proposed biofiltration basins, proposed proprietary biofiltration systems, and proposed underground detention systems. Porti ons of the drainage system will be relocated within North City Drive and will be appropriately sized to accommodate stormwater flows and ensure the drainage system is adequately sized for the project site. Implementation of these features would ensure that the proposed development would not exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. The proposed project does not result in any new impact beyond those identified in the FEIR.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
f) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
FEIR Conclusion: No impact. The Initial Study prepared for the FEIR determined that the project would not have no impact related to inundation from flood hazards, tsunami or seiche zones (FEIR page 3.7-1).

Discussion of the Proposed Project: The project site remains in a location that would not be subject to inundation from flood hazard, tsunami or seiche zone.

Therefore, the FEIR conclusions remain accurate for the proposed project and no new impacts are identified.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
g) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
FEIR Conclusion: Not Analyzed. This specific threshold was not analyzed in the FEIR as it was not part of CEQA Guidelines Appendix G at the time the FEIR was prepared.

Discussion of the Proposed Project: The project does not propose an increase in groundwater use. Potable water service would continue to come from VWD. Some groundwater may be used for irrigation within the larger UDSP planning area.

However, the proposed project would not conflict with or obstruct implementation of a water quality control plan or sustainable gr oundwater management plan.

Therefore, the FEIR conclusions remain accurate for the proposed project and no new impacts are identified.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

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h) Result in significant alteration of receiving water quality during or following construction?
FEIR Conclusion: Less than Significant. The FEIR (page 3.7 -20) identified the preparation of project -specific SWPPPs per the National Pollutant Discharge Elimination System (NPDES) permit program and implementation of BMPs to prevent construction-related runoff from polluting receiving waters. Additionally, the Specific Plan has been designed to incorporate a variety of BMPs and Low Intensity Design (LID) features to limit the potential for water quality impacts to the greatest extent feasible for a less than significant impact. In addition, a Storm Water Management Plan will be implemented to reduce potential impacts to receiving water quality to ensure water quality standards and discharge requirements. In addition, the grading plan will comply with the City Municipal Code Grading Ordinance, Chapter 17.32, San Diego County Code of Regulatory Storm Water Ordinances Sections 67.801 through 67.811, and Statewide General Construction Stormwater Permit No. CAS000002. Should SWPPP requirements change, due to changes in permit or City SUSMP requirements, the BMPs used during development and construction would reflect the latest requirements.

Implementation of these features would ensure that the proposed developmen t would not result in significant alteration of receiving water quality during or following construction. The proposed project does not result in any new impact beyond those identified in the FEIR.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
i) Result in an increase in pollutant discharges to receiving waters? FEIR Conclusion: Mitigated to Below a Level of Significance. The FEIR prepared for the UDSP concluded that with implementation of BMPs, impacts related to an increase in pollutant discharges to receiving waters would be less than significant (page 3.7-15).

Runoff generated by Phases A & B project will convey into a mixed use of proposed biofiltration basins, proposed proprietary biofiltration systems, and proposed underground detention systems. Implementation of these features along with other BMPs would ensure tha t the proposed development would not result an increase in pollutant discharges to receiving waters. The proposed project does not result in any new impact beyond those identified in the FEIR.

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Finding: There are no new impacts for this issue area and no ch anges in information that would require preparation of an EIR.
j) Be tributary to an already impaired water body as listed on the Clean Water Act Section 303(d) list. If so, can it result in an increase in any pollutant for which the water body is already impaired?
FEIR Conclusion: Less than Significant. The FEIR (page 3.7-15) identified that the San Marcos Creek is listed on the 2008 CWA Section 303(d) List for benthic community effects, benthic -macroinvertebrate bioassessments, DDE, phosphorus, selenium, total dissolved solids, turbidity and sediment. In addition, Lake San Marcos is impaired for ammonia as nitrogen, foam/scum/oil slicks, nutrients, total dissolved solids, and phosphorus. To avoid potential construction- related impacts to sensitive areas, a site -specific SWPPP would be implemented during construction of the project. Implementation of the SWPPP and appropriate BMPs would reduce construction-related runoff from any riparian areas to prevent potential contamination.

Discussion of the Proposed Project: The proposed project would still incorporate BMPs and preparation of a SWPPP and landscape features to desilt and/or filter runoff before outlet into San Marcos Creek and Lake San Marcos. Ple ase see response 10.c, above for specific information on the proposed stormwater management approach for the project site. There are no new impacts for this issue area and the FEIR conclusions remain accurate for the proposed project .

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
k) Be tributary to environmentally sensitive areas (e.g., MSCP, RARE, Areas of Special Biological Significance, etc.)? If so, can it exacerbate already existing sensitive conditions?
FEIR Conclusion: Less than Significant. As noted in the FEIR (page 3.7 -15), San Marcos Creek is located to the northwest of the project area. Under existing conditions surface runoff discharges into San Marcos Creek either b y sheet flow or through minor drainage facilities. To avoid potential construction -related impacts to sensitive areas, a site -specific SWPPP would be implemented during the construction phase of the proposed project.

Discussion of the Proposed Project: Development under the proposed project would still have the potential to impact water quality; however, development under the proposed project would be required to comply with the City’s BMP Design Manual . A site specific SWPPP will be implemented with the project in conformance with the latest construction general permit to minimize impacts during construction. There are no new impacts for this issue area and the FEIR conclusions remain accurate for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

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l) Have a potentially significant environmental impact on surface water quality, to either marine, fresh or wetland waters?
FEIR Conclusion: Less than Significant. The FEIR (Page 3.7 -16) concluded that that upon development and ultimate build -out of the project the site would continue to discharge into San Marcos Creek and Lake San Marcos. The implementation of the SWPPP and applicable BMPs to prevent contaminants from entering storm drains to minimize the amount of uncontrolled runoff to surface waters will prevent potential impact to marine, fresh or wetland waters. The Initial Study prepared for the UDSP project (Appendix A.2 of the FEIR) determined th at all onsite drainage would convey runoff through an appropriately designed drainage system prior to outlet into any marine, fresh water or wetland waters, per the requirements of existing regulations and state and local water quality standards.

Discussion of the Proposed Project: As discussed in 8.c, above, development under the proposed project would be required to comply with the City’s BMP Design Manual. Additionally, a SWQMP was prepared for the SDP for Phase s A and B (SCE 2022b). Runoff generated by Phases A & B project will convey into a mixed use of proposed biofiltration basins, proposed proprietary biofiltration systems, and proposed underground detention systems. Implementation of these features would ensure that the proposed development would not resu lt in potentially significant environmental impact s on surface water quality, to either marine, fresh or wetland waters. There are no new impacts for this issue area and the FEIR conclusions remain accurate for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

11. LAND USE AND PLANNING – Would the project:
a) Physically divide an established community?
FEIR Conclusion: No Impact. The Initial Study (FEIR Appendix A.2) determined that the project would not divide an established community because the development either exists or is planned along the majority of the project boundaries. The UDSP project proposed internal circulation networks that will enhance vehicular, bicycle, and pedestrian movement to better connect to offsite areas.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of two parcels (APNs 220-201-90-00 and 220-202-18-00). The UDSP would not divide an established community. Connectivity between the new 8 -acre area and the current UDSP would be maintained. Proposed revisions to the Mobility Element of the General Plan include removing the following mobility improvement symbo ls:
1) Johnston Lane SR -78 flyover bridge; and 2) the pedestrian bridge from Discovery Street. By removing the Johnston Lane SR -78 flyover bridge, the impacts to existing residencies and business along Johnston Lane would be avoided, thus avoiding disrupti on to an existing neighborhood. The pedestrian bridge from Discovery Street is proposed to be removed because a landing for the Discovery Street pedestrian bridge was not provided for in the entitlements for

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the Discovery Village South development or the K aiser projects. Street level crosswalks in the Discovery Street vicinity would still be present and allow for pedestrian movement and connectivity in the area. There are no aspects of the proposed project that would physically divide an established communi ty Therefore, the conclusions in the FEIR are still applicable to the proposed project and no impact is identified.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? FEIR Conclusion: Less than Significant. The FEIR prepared for the UDSP did not identify any conflicts with applicable land use plan, policy or regulation of an agency with jurisdiction over the project adopted for the purposes of avoiding or mitigating an environmental effect (page 3.8-21).

Discussion of the Proposed Project: The proposed project includes the approval of a General Plan Amendment, a Specific Plan Amendment to the UDSP, a Specific Plan Amendment to the Heart of the City Specific Plan (HOCSP), a Site Development Plan and a Tentativ e Subdivision Map. The proposed project is currently inconsistent with the height requirements of the UDSP, but pursuant to the analysis contained in the Addendum has been deemed to be an impact that is less than significant, and the project would be consistent if the proposed UDSP plan amendment is approved. Table 1.A of the proposed amended UDSP includes a detailed analysis of the project’s consistency with the City’s General Plan. As shown in that table, the proposed UDSP amendment would not result in a ny inconsistencies with any of the analyzed goals and policies. These proposed discretionary actions do not cause any other inconsistency with applicable land use plans, policies or regulation of an agency with jurisdiction over the project. No new impacts are identified.

Finding: There are no significant impacts for this issue area and no changes in information that would require preparation of an EIR.

12. MINERAL RESOURCES – Would the project:
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State?
FEIR Conclusion: No Impact. The FEIR (page 5-4) noted that according to the City’s General Plan, the State’s Mineral Land Classification Maps identifies the City as unsuitable as a source of sand and gravel resources.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels. APN 220-201-90-00 and APN 220-202-18-00. As noted in the FEIR, the State’s Mineral Land Classification Maps identifies the City as unsuitable as

University District Specific Plan Amendment 64 City of San Marcos FEIR Addendum May 2022
a source of sand and gravel resources . This would also apply to the two parcels that are proposed to be added to the UDSP project area. Because the project area is not identified as an area with known valuable mineral resources, the FEIR conclusion of no impact to mineral resources would still be applicable to the proposed project. Therefore, no new impacts are identified for this issue area.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? FEIR Conclusion: No Impact. The FEIR (page 5-4) noted that according to the City’s General Plan, the State’s Mineral Land Classification Maps identifies the City as unsuitable as a source of sand and gravel resources.

Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels. APN 220-201-90-00 and APN 220-202-18-00. As noted in the FEIR, the State’s Mineral Land Classification Maps identifies the City as unsuitable as a source of sand and gravel resources . This would also apply to the two parcels that are proposed to be added to the UDSP project area. The project site is not identified as a locally important mineral recovery site delineated on a local general plan, specific plan or other land use plan.

Because the project area is not identified as an area with known valuable mineral resources, the FEIR conclusion of no impact to mineral resources would still be applicable to the proposed project. Therefore, no new impacts are identified for this issue area.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

13. NOISE – Would the project:
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local genera plan or noise ordinance, or applicable standards of other agencies? FEIR Conclusion: Mitigated to Below a Level of Significance . The FEIR prepared for the UDSP identified noise impacts related to the placement of residential and commercial uses in proximity to each other as part of a mixed -use project (page

3.9-12). Mitigation measures were identified (N-4 and N-5) to reduce the impacts to below a level of significance. These measures require site -specific noise studies a t the time future development is proposed and mitigation to reduce exterior and interior noise levels to meet City standards.

Discussion of the Proposed Project: The development under the proposed project would be similar to the uses analyzed in the FEIR, and the same potential for noise conflicts at the interface of commercial and residential uses exists. Project -

University District Specific Plan Amendment 65 City of San Marcos FEIR Addendum May 2022
specific noise studies and the requirements to mitigate any noise impact to City standards would still be required as individual development project come forward within the UDSP planning area.

With removal of the Johnston Lane SR -78 flyover bridge, traffic would be redistributed in the project vicinity. Additionally, the proposed project would reduce trip generation by 49% compared to what was assumed in the 2009 FEIR and by 37% compared to the currently adopted UDSP (2014 FEIR Addendum).

A noise analysis was prepared by LDN Consulting (2022c) to determine if this redistribution of traffic would result in a significant vehicular noise increase. The analysis is included in Appendix F of this document. Based upon LDN’s analysis, the redistribution of traffic will not result in a significant vehicular noise increase on any of the segments analyzed in the project’s traffic report. Therefore, the proposed project would not result in any changes within the UDSP that would increase exposure of per sons to or generate noise levels in excess of standards established by the City. No new impacts are identified.

The project applicant is proposing to remove two parcels, totaling approximately 8 acres, from the HOCSP and add them to the UDSP.

The 6.3 -acre parcel (APN 220 -201-90-00), known as the Zirpolo property, is currently designated as Business Park in the HOCSP. As part of the proposed project this parcel would be removed from the HOCSP and be added to the UDSP.

It would be designated as Office/Comme rcial within the UDSP. The Mixed Use A building type would be allow ed within the Office/Commercial zone which means residential uses could be introduced to the Zirpolo site. Under the current Business Park designation in the HOCSP, residential uses are not permitted.

Should future development be proposed on the Zirpolo site that includes residential uses, a site-specific noise study will be required. This is consistent with mitigation measure N-4 and N-5 in the UDSP FEIR, which are as follows:

N-4 As development proposals come forward within the Specific Plan area, a site specific noise study(s) shall be prepared for each development. The noise study shall analyze the impact of co-locating residential and commercial uses on the project site, as well as locating uses within proximity to SR -78.

Mitigation measures shall be identified from among those identified herein or other feasible mitigation measures and incorporated into the Conditional Use Permits or other discretionary permits, to reduce noise imp acts associated with these uses. These measures could include sound barriers/walls, noise - reducing pavement, or other mitigation measures to provide sound level reductions so that they are consistent with the CNEL levels identified in the San Marcos Genera l Plan, including 45 dBA CNEL for interior residential areas.

N-5 All proposed sensitive land uses would be subject to compliance with CCR Title 24 interior noise abatement threshold, inclusive of the residential areas, professional and medical areas , and schools. Residential areas shall be interior mitigated to 45 dBA CNEL. Professional spaces and school uses shall be interior mitigated to 50 dBA CNEL.

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The other parcel to be brought into the UDSP planning area is APN 220 -202-18- 00, a 1.7 -acre site lo cated just east of the SPRINTER rail line. This property is owned by the NCTD and is currently designated as Business Park in the HOCSP.

As part of the project this parcel would be removed from the HOCSP and added to the UDSP for connectivity purposes. This parcel serves as an emergency access and maintenance access point for the SPRINTER rail line. It would be designated as Office/Commercial within the UDSP with a Railroad ROW overlay. No development is proposed within this parcel ; therefore, there is no potential for a noise impact. However, should the Railroad ROW overlay be removed in the future and development be proposed, it would be subject to an Administrative Amendment and additional CEQA review and it would be subject to noise mitigation measures N-4 and N-5, as discussed above.

In summary, the addition of the two parcels into the UDSP does not result in a new significant impact or an increase in severity of impacts.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Result in exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels?
FEIR Conclusion: Less than Significant. The FEIR (page 3.9 -10) identified potential construction-related vibration impacts due to proposed blasting.

Mitigation was identified (N -3) to reduce the impact. The mitigation measure required a distance separation between blasting activities and nearby sensitive receptors.

Discussion of the Prop osed Project: While overall less intense uses proposed under the project would be similar to those analyzed in the FEIR. Any construction- related vibration would be of a similar nature as identified in the FEIR. No new uses, which would be characterized as capable of causing excessive groundborne vibration or groundborne noise, would occur. Therefore, the FEIR conclusions are still applicable to the proposed project and no new impacts are identified.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
FEIR Conclusion: Less than Significant. The FEIR (page 3.9-13) identified that the closest public airport to the project area is McClellan -Palomar Airport, located approximately 5.5 miles west of the project site. According to the Airport Land Use Compatibility Plan (ALUCP) for the McClellan -Palomar Airport, the proposed project site is not located within the 60 dB CNEL noise contour of the airport; therefore, impacts related to airport noise are considered less than significant.

University District Specific Plan Amendment 67 City of San Marcos FEIR Addendum May 2022
Discussion of the Proposed Project: The UDSP planning area is in the same location and remains at an adequate distance from any operating airports to avoid any type of noise impact from operating aircraft. The addition of two parcels to the UDSP planning area ( APN 220-201-90-00 and APN 220 -202-18-00) would also be adequ ate distance from operating airports to avoid any type of noise impact from operating aircraft. Please see section 7.e, above, for information on the City’s coordination with the San Diego County Regional Airport Authority (SDCRAA) Airport Land Use Commission (ALUC).

Therefore, the conclusions in the FEIR are still applicable to the proposed project and no new impacts are identified.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

14. POPULATION AND HOUSING – Would the project:
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
FEIR Conclusion: Less than Significant. The FEIR (page 3.10 -5) concluded that the UDSP would increase population with the addition of 2,600 mixed-use residential units and 800 student housing units (3,400 units total) and would create additional infrastructure; however, impacts were determined t o be less than significant.

Discussion of the Proposed Project: Development under the proposed project would reduce the overall intensity of development contemplated in the USDP as detailed in Table 1. This includes reductions in the amount of hotel rooms, medical office, and mixed use retail/commercial uses. The total number of residential units (3,400 units) will remain the same under the proposed project with 2,600 mixed-use residential units and 800 student housing units. Therefore, the population growth associated with the UDSP is already anticipated and there would not be any substantial unplanned population growth in the area that was not already considered in the FEIR. Further, t here are no new road or infrastructure extensions that are required to serve the project that w as not already considered in the FEIR. T herefore, the conclusions in the FEIR are still applicable to the proposed project and no new impacts are identified.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
FEIR Conclusion: Less than Significant. The FEIR (page 3.10 -5) noted that the existing residents could stay in their current locat ions until parcels are acquired by the developer. Until that time, none of the residences with in the UDSP area would be required to be vacated. Full build -out of the UDSP would require approximately 75 existing residences to be removed. The FEIR concluded this was

University District Specific Plan Amendment 68 City of San Marcos FEIR Addendum May 2022
a less than significant impact since 2,600 residential units would be constructed on the site.

Discussion of the Proposed Project: Development under the proposed project would not result in any additional loss of residences not already considered in the UDSP FEIR. Additionally, removal of the Johnston Lane SR-78 flyover bridge would avoid the need to impact residences on Johnston Lane. Therefore, the conclusion of less than significant is still applicable to the proposed project and no new impacts are identified.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

15. PUBLIC SERVICES – Would the project:
a) Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
i) Fire protection?
FEIR Conclusion: Less than Significant. The FEIR (page 3.11 -8) concluded that the UDSP project would r esult in an increase in demand for the San Marcos Fire Department (SMFD) due to the addition of residents and businesses. The FEIR concluded that SMFD would be capable of handling an increase in services. Any incremental effects would be offset by the City requirement for payment of fees in CFD 98-01 for fire protection to make the impact less than significant.

Discussion of the Proposed Project:

The proposed project would m odify building development standards to allow for greater building height (up to 12, 15, and 16 stories) in some areas of the UDSP. The currently adopted UDSP allows for building heights up to 7 stories.

The SMFD has reviewed the proposed project and did not identify any significant impacts associated with servicing the project, includi ng the taller buildings which could be developed under the proposed project.

Based upon information from the National Fire Protection Association (NFPA), the fire death rate per 1,000 fires and the average loss per fire are generally lower in high-rise buildings than in other buildings of the same property use (NFPA 2016). “High -rise” is defined as 7 stories above grade. According to NFPA, high-rise buildings have lower percentages of fires with flame damage beyond room of origin. High -rises are also more likely than shorter buildings to have fire-resistive construction and wet pipe sprinklers which helps prevent fire spread. As noted in the FEIR, future development would pay fees into a CFD to offset the increase in demand. The project would annex into CFD 2001- 01 (Fire) to offset the increase in demand. This CFD is used to finance authorized fire facilities and equipment (fire stations, training facilities, dispatch center, communications systems and equipment) and services (fire

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protection, ambulance and paramedic). The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, a need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acc eptable service ratios, response times or other performance objectives for fire protection. The proposed project does not result in any new impacts related to fire protection services and the conclusions of the FEIR are still applicable.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
ii) Police protection?
FEIR Conclusion: Less than Significant. The FEIR (page 3.11-9) identified that the UDSP project would result in an increase in demand to police protective services from the San Diego County Sheriff’s Department due to the increase in area residents and businesses. Any incremental effects of the proposed project’s demand on police protection were determined to be offset by the City requirement for the payment of fees to CFD 98-01 for police protection to make the impact less than significant.

Discussion of the Proposed Project: The proposed project would decrease the intensity of development within the UDSP, thus resulting in a reduction in demand for police protection services compared to the currently approved UDSP. The San Diego County Sheriff’s Department has reviewed the project and did not identify any impacts. As noted in the FEIR, future development would pay fees into CFD 98-01 (Improvement Area 1) to offset the increase in demand. This CFD funds police services as well as police facilities, communication systems and equipment. The proposed project does not result in any new impacts related to police protection services and would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, a need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection.

The conclusions of the FEIR are still applicable.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
iii) Schools?
FEIR Conclusion: Less than Significant. The FEIR (page 3.11 -10) identified that the UDSP project would generate 1,167 students which would need to be served by the San Marcos Unified School District (SMUSD). To offset the additional facilities and service s that will be needed to accommodate these students, future development would be required to pay SMUSD Level II Statutory School Fees at the time the building permit is obtained . The plan also included an 8 -acre site for an elementary school. Impacts were determined to be less than significant.

University District Specific Plan Amendment 70 City of San Marcos FEIR Addendum May 2022
Discussion of the Proposed Project: The proposed project retains the option for SMUSD to construct a K-6 elementary school within the UDSP. Demands for school services are generated by residential uses. The number of units allowed under the UDSP would remain at a total of 3,400 units and would include 2,600 multifamily residential units and 800 student housing units.

For the purposes of studen t generation for SMUSD schools, only the 2,600 mixed-use residential units are included in the student generation calculation.

This is consistent with the analysis approach in the FEIR. Since certification of the FEIR, SMUSD has refined their student gener ation numbers providing different generation rates for single -family detached, single family attached and multi-family units. At the time the FEIR was prepared, a single generation rate was used regardless of housing type.

Table 7 presents the student generation calculation for the proposed project using the latest generation rates from the School Facilities Needs Analysis (SFNA) (SMUSD 2021).

Using current SMUSD generation rates, the project is now anticipated to generate 843 students. This is a reduction of 324 students compared to what was anticipated in the FEIR analysis.

New residential and commercial development under the proposed project would still be required to pay the applicable Level II Statutory Schools fees in effect at the time of building permit which would offset the demand for school services and is considered complete and full mitigation. Pursuant to Education Code Section 17620 et seq. and Government Code sections 65995(h) and 65996(b) (SB 50), the payment of statutorily capped fee amounts provides “full and complete mitigation of the impacts of any legislative or adjudicative act…on the provision of adequate school facilities.” The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, a need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service for school services. No new impacts are identified due to the implementation of the proposed project and the conclusions of the FEIR are still applicable.

Table 7. Proposed Student Generation with Current SFNA Generation Rates

Grade Level Student Generation Rate (1) Students Generated Single Family Detached (50 units)
Elementary 0.3537 18
Middle 0.1266 7
High 0.155 8
Single Family Attached (Townhomes) (600 units)
Elementary 0.2123 128
Middle 0.0587 36
High 0.0754 46
Multi-Family (1,950 units)
Elementary 0.149 291
Middle 0.0598 117
High 0.0984 192
Total Students Generated 843

University District Specific Plan Amendment 71 City of San Marcos FEIR Addendum May 2022
Note 1: Student Generation Rates are from Tables 1, 2, and 3 from the SMUSD School Facilities Needs Analysis (2021).

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
iv) Parks?
FEIR Conclusion: Less than Significant. The FEIR (page 3.12-9) identified that the UDSP would construct 17.37 acres of park space, 7.96 acres of plazas and paseos, and 1.38 acres of trails. Even with the additional park space and trails proposed under the UDSP, impacts would occur to recreational facilities and parks due to the additional 10,500 residents that the UDSP would add to the City’s population. This would result in a deficiency in park space. The FEIR concluded that this deficiency would be made up through the payment of fees as required by City Ordinance 88 -799 (Municipal Code, Chapter 20.12, Growth Management). Park, plaza, paseo and trail acreage were modified via a 2014 SPA.

Discussion of the Proposed Project: Development under the proposed project would not result in additional residents to the area, nor would it put an increased demand on park facilities. The proposed revisions to the UDSP would increase the amount of parks and urban open space by approximately 2 acres, which provides additional recreation and amenity space for future residents of the project site and residents of San Marcos. If the K-6 school is not constructed on the 8 -acre site, there is an alternative for the site to be developed with 4 acres of park (an extension of the Knoll Park) and 4 acres of Mixed-Use Residential. Under this scenario, there would be an addition of approximately 6 acres of Park and Urban Open Space compared to the currently adopted UDSP. The proposed project does not result in any increase in park impacts and the potential for substantial adverse physical impacts of that increased park area are addressed in the FEIR and this Adde ndum. No new impacts would be realized from the proposed project and the conclusions from the FEIR are still applicable.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
v) Other public facilities?
FEIR Conclusion: Less than Significant. The FEIR (page 3.11 -10) identified that the UDSP would result in additional residents that would increase demands on library services and resources, although additional library services were identified through the California State University San Marcos and Palomar College campuses. The additional library facilities would reduce impacts to a level of less than significant impact.

Discussion of the Proposed Project: The proposed project does not result in any changes to the amount of residential development within the overall UDSP planning area, thus the demand for library service would be the same.

Impacts to libraries would be less than significant under the proposed project.

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This is consistent with the conclusion in the FEIR. No new impacts would be realized from the proposed project.

Finding: No new impacts for this issue area and no changes in information that would require preparation of an EIR.

16. RECREATION – Would the project:
a) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
FEIR Conclusion: No Impact. The UDSP project proposes the construction of

17.37 acres of park space, 7.96 acres of plazas and paseos, and 1.3 8 acres of trails. The FEIR (page 3.12 -9) identified impacts to recreational facilities and parks even with the additional park space and trails due to the additional 10,500 residents that the UDSP would add to the City population, which would result in a deficiency in park space. This deficiency would be made up through the payment of fees as required by City Ordinance 88 -799 (Municipal Code, Chapter 20.12, Growth Management) as part of the project design for future development of parks and recreation. Par k, plaza, paseo and trail acreage were modified via a 2014 SPA.

Discussion of the Proposed Project: Development under the proposed project would not result in additional residential units to the planning area beyond what was already considered in the FEIR. The proposed revisions to the UDSP would increase the amount of parks and urban open space by approximately 2 acres which provides additional recreation and amenity space for future residents of the project site and residents of San Marcos. If the K-6 school is not constructed on the 8-acre site, there is an alternative for the site to be developed with 4 acres of park (an extension of the Knoll Park) and 4 acres of Mixed -Use Residential.

Under this scenario, there would be an addition of approximately 6 acres of Park and Urban Open Space compared to the currently adopted UDSP. The proposed project does not result in any increase in park impacts and the potential for substantial adverse physical impacts of that increased park area are addressed in the FEIR and this Addendum. No new impacts would be realized from the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment?
No Impact. Please refer to Section 16.a above.

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17. TRANSPORTATION– Would the project:
a) Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? FEIR Conclusion: Significant and Unmitigated. The FEIR analyzed trip generation from the following land uses: mixed use multi- family residential, mixed use community commercial, mixed use office, mixed use medical office, hotel, community center, and elementary school, in addition to construction -related traffic over a 20-year time period for future development. The FEIR (page 3.13-64 through 3.13-67) concluded that the project would not impact roadway segments for the Year 2015-time frame. Impacts would be considered less than significant for the 2020 -time frame with the completion of the SR-78 flyover at Westlake Drive bridge, and impacts would be significant and unmitigated for SR -78 ramps for the 2030 timeframe scenario. Mitigation measure TR-1 of the FEIR noted that, based upon the focused traffic studies demonstrat ing compliance with the performance criteria set forth therein, the City Manager may modify the transportation phasing plan for the Specific Plan area. The FEIR identified a traffic phasing plan on a year ly basis, with specific improvements to be constructed by Years 2015, 2020, and 2030.

In the 2014 FEIR Addendum prepared for an amendment to the UDSP, a new traffic study was prepared and identified a traffic mitigation phasing plan that required improvements based upon peak hour trip generation for development within the UDSP project area instead of a specific year trigger. This was deemed a more realistic mitigation phasing approach since development had not occurred at the rate originally anticipated in the FEIR. Specific intersection and roadway improvements were triggered at 760 PM peak hour trips, 1,760 PM peak hour trips, and 2,855 PM peak hour trips respectively (see Tables 8 and 9 of RBF’s University District Specific Plan Amendment Traffic Impact Assessment, April 17, 2014). These thresholds were set based upon assump tions that certain Capital Improvement Projects (CIP) would be constructed, including the extension of Discovery Street from Bent Avenue to Craven Road and construction of Rush Drive.

Discussion of the Proposed Project: While Level of Service (LOS) is no longer used to determine if there are significant transportation impacts under CEQA, the City’s Mobility Element identifies LOS goals for transportation facilities in Policy M -1.4.

Therefore, consistency with the General Plan requires compliance with the L OS goals in Policy M -1.4. Since LOS was discussed in the transportation section of the FEIR, it is also being addressed here.

The Local Transportation Analysis prepared by Urban Systems Associates dated May 19, 2022 (2022 LTA) was prepared to assess the traffic impacts of the proposed UDSP amendment. A total of 31 segments and 39 intersections were evaluated. The study area was determined in conjunction with City staff and differed from the study area in the FEIR and 2014 Addendum due to the roadway network changes and reduction in trip generation that would occur under the proposed project.

The overall development intensity within the UDSP planning area would decrease with the proposed UDSP amendment. This includes a reduction in medical office

University District Specific Plan Amendment 74 City of San Marcos FEIR Addendum May 2022
use, mixed use retail/commercial and the number of hotel rooms. There would be an increase in general office and an increase in parks and urban open space.

Reductions in the development intensity of other developments in the project vicinity have resulted in a further reduction in trips on project area roadways.

The project proposes removal of the Johnston Lane SR-78 flyover bridge (referred to in the original FEIR as the Westlake Drive flyover bridge) as part of the amendment to the UDSP. The 2022 LTA substantiated that the decreased trip generation combined with the redistribution of traffic resulting from the completion of the Discovery Street extension project ensures that the bridge will no longer be required, and no significant traffic impacts will result from its removal from the UDSP.

Trip Generation
Trip generation considered under the proposed UDSP amendment, 2009 FEIR, and 2014 UDSP FEIR Addendum is summarized in Table 8. As shown in Table 8, the project results in a 49% reduction in trips compared to what was analyzed in the FEIR and a 37% reduction compared to 2014 Addendum for the currently approved UDSP consistent with the reduction in development yield.

Table 8. Trip Generation in the UDSP

Level of Services (LOS) Standards
Level of S ervice standards for roadway segments and intersections are defined within Section 3.7 of the TIA Guidelines. A project is considered to require network improvements when project traffic decreases operations past the defined thresholds.

Study intersections must identify improvements to increase performance to acceptable or pre-project conditions if the proposed project:
• Triggers an intersection operating at acceptable LOS to operate at unacceptable LOS and increa ses the average delay per vehicle by more than 2.0 seconds.
• Increases the average delay per vehicle for a study intersection that is already operating at unacceptable LOS by more than 2.0 seconds.

Improvements should also be identified for roadway segments when traffic generated from the proposed project:
• Triggers a roadway segment operating at acceptable LOS to operate at unacceptable LOS and increases the volume/capacity (V/C) ratio by more than 0.02.

University District Specific Plan Amendment 75 City of San Marcos FEIR Addendum May 2022
• Increases the V/C ratio for a study roadway segment th at is already operating at unacceptable LOS by more than 0.02.

The City generally aims to provide LOS “D” or better on roadways and intersections. Mobility Element Policy M -1.4 allows for flexible LOS (accepting a lower LOS than D) where warranted, such as at locations within the Urban Core of San Marcos, or where widening is considered infeasible from a financial or environmental perspective. Table 3-4 of the Mobility Element of the General Plan identifies where a flexible LOS is w arranted based upon the mode preference of the street. For example, on portions of San Marcos Boulevard LOS E is acceptable.

Traffic Counts
To determine existing average daily traffic volumes and intersection peak hour turning movement volumes, traffic counts were obtained in April and May of 2019 by USA. Two -hour peak period vehicular, bicycle, and pedestrian volumes were collected on a weekday for all studied intersections during the AM and PM peaks and 24-hour daily vehicle counts were collected for al l study roadway segments.

These traffic counts were collected pre-COVID and while schools were in session.

Transportation Network Improvement
As a feature of the UDSP amendment project, the applicant will construct an eastbound right turn lane and overlap turn signal phasing at the intersection of Discovery Street and Craven Road.

The Discovery Street extension project completing Discovery Street from Craven Road to Twin Oaks Valley Road w as under construction at the time of the preparation 2022 LTA . The 2022 LTA utilized conservative assumptions regarding the manner in which the public will adjust driving patterns at the Discovery Street/Craven Road intersection in response to the through connection provided by the Discovery Street improvements. As a result, the project design feature includes a future addition of a separate right turn pocket for east bound traffic at the intersection of Discovery Street and Craven Road. Given the unique circumstances, there are two alternatives for this design feature.

Alternative 1 - Traffic Monitoring. Traffic monitoring may be conducted to assess the assumption of this UDSPA that a separate right turn lane will be a required project feature. The initia l traffic monitoring should be conducted following the completion of the Discovery Street extension connecting Bent Avenue with Twin Oaks Valley Road and the stabilization of area traffic patterns once the extension is open to traffic. This initial traffic monitoring effort will establish a new baseline in the traffic patterns at the intersection, providing an improved foundation for accurately assigning future 2035 and 2050 traffic growth.

To allow this stabilization of traffic patterns to occur, the AM an d PM peak traffic counts will be obtained at the Discovery Street/Craven Road intersection at least two months but no more than six months after the opening of the Discovery Street extension, or as determined by the City’s Development Services Director.

The study shall be conducted when Cal State University San Marcos is in regular session and not during a summer or holiday period. The study shall be conducted by a California licensed Traffic Engineer and shall include documentation of the post extension project right turn traffic volume destined to Craven Road. The study

University District Specific Plan Amendment 76 City of San Marcos FEIR Addendum May 2022
shall analyze traffic operations for options with and without the right turn lane.

For the option including the right turn lane, the analysis will assess both with and without overlap sign al phasing for the east -to-south and north -to-west turning movements.

The study shall include an analysis of three scenarios including Existing Conditions, 2035 With Project, and 2050 With Project. Previously developed traffic forecasts will be adjusted as appropriate to reflect the traffic patterns documented in the peak period traffic counts with the Discovery Street extension completed. A memo report with appropriate exhibits and the preparing Traffic Engineer's professional opinion as to the required improvements at the Discovery Street and Craven Road intersection shall be provided to the City for review and acceptance. The City Development Services Director or their representative shall make the determination if the right turn lane is to be installed by the Project. The Project shall construct the project feature prior to issuance of occupancy of the building permits that would trigger a LOS E or F impact at the intersection.

If the monitoring study traffic data does not conclusively show that there wi ll not be a future need for the right turn lane, the Project shall provide additional monitoring prior to the ultimate build -out of the University District Specific Plan.

At times as determined in the discretion of the Development Services Director, the Pr oject shall monitor the operations of the intersection in an incremental manner as the West Side development parcels are submitted for final City building permit approval and occupancy permits are requested. If the incremental monitoring effort determines that the dedicated right turn lane is required to ensure adequate intersection operation, the Project shall construct the project feature prior to issuance of occupancy of the building permits that would trigger a LOS E or F impact at the intersection.

If the incremental monitoring does not indicate the construction of a dedicated right turn lane, the Project shall provide a final monitoring effort just prior to full build-out of the West side of the University District Specific Plan to conclude whether the dedicated right turn lane improvement will be warranted to support adequate intersection operation. If the study shows that the post -development traffic patterns do not warrant a right turn lane, then the Development Services Director may make a finding that the intersection is not impacted in the ultimate condition, and that the project feature to address the forecasted impact at the intersection is no longer required. If the study shows that the turn lane is needed, then the University District shall design and construct the improvement.

Alternative 2 – Construct Eastbound Right Turn Lane. If the Developer opts to construct the eastbound right turn lane prior to the commencement of the monitoring of the intersection, or during the monitoring of the inters ection, then monitoring requirements will no longer be required upon completion of construction of the right -turn lane. The conceptual layout of this improvement is included in Figure 6.4 of the LTA .

University District Specific Plan Amendment 77 City of San Marcos FEIR Addendum May 2022
LTA Analysis Scenarios
The LTA is included as Appendix G of this document. The scenarios studied in the LTA are:
• Existing Condition;
• Year 2035 Without Project;
• Year 2035 With Project;
• Year 2050 Without Project; and
• Year 2050 With Project.

Existing Condition Scenario
Chapter 4 of the LTA presents the existing roadway and intersection operations information. The following seven roadway segments are currently operating at a LOS worse than D in the Existing Condition scenario:
• San Marcos Boulevard from Rancho Santa Fe Road to Discovery St reet (LOS E)
• Discovery St reet from San Marcos Boulevard to Discovery St reet/La Sombra Drive (LOS F)
• Discovery Street from Via Vera Cruz to Bent Avenue/Craven Road (LOS F) • Discovery Street from Rush Drive to Twin Oaks Valley Road (LOS F) • Twin Oaks Valley R oad from San Marcos Boulevard to Richmar Ave nue (LOS E)
• Barham Drive from Warplex Avenue to Woodland Parkway (LOS F) • Barham Drive east of SR-78 EB ramp (LOS F)
The following four intersections are deficient in the Existing Condition scenario:
• Discovery Street at Bent Avenue (LOS F in the AM Peak/ LOS F in the PM Peak)
• San Marcos Boulevard at Westlake Drive (LOS E in the PM Peak) • Craven Road at Echo Lane (LOS E in the PM Peak)
• Twin Oaks Valley Road at San Marcos Boulevard (LOS E in the AM Peak) Year 2035 Scenario Analysis
Chapters 5 and 6 of the LTA (Appendix G of this document) present the Year 2035 Without Project Condition and the Year 2035 With Project analysis.

Year 2035 – Without Project Scenario
The Year 2035 Without Project scenario analysis assumes that the following roadway improvements will be in place by 2035:
• Barham Drive will expand to a 4-lane major from West La Moree Road to Woodland Parkway
• Discovery Street extension will be complete
• A traffic signal will be installed at the intersection of Bent Avenue and Creekside Drive
• The channelized right turns at the intersection of Twin Oaks Valley Road and Discovery Street/Barham Drive will be removed
• Completion of the Bent Avenue Bridge

University District Specific Plan Amendment 78 City of San Marcos FEIR Addendum May 2022
Segments
In the Year 20 35 Without Project Scenario, all analyzed roadway segments are forecast to operate at an acceptable LOS.

Intersections
In the Year 20 35 Without Project Scenario, the following two intersection are forecast to operate at an unacceptable LOS:
• Discovery Street/Craven Road
o PM Peak Hour – LOS F – 96.7 second delay
• Twin Oaks Valley Road/ San Marcos Boulevard
o AM Peak Hour – LOS F – 73.1 second delay
o PM Peak Hour – LOS E – 70.7 second delay
Year 2035 – With Project Scenario
The Year 2035 With Project scenario analysis assumes that the following roadway improvements will be in place by 2035:
• Barham Drive will expand to a 4-lane major
• Discovery Street extension will be complete
• A traffic signal will be installed at the intersection of Bent Avenue an d Creekside Drive
• The channelized right turns at the intersection of Twin Oaks Valley Road and Discovery Street/Barham Drive will be removed
• An eastbound right turn lane will be added to the intersection of Discovery Street and Craven Road
Segments
One roadway segment will surpass thresholds in the Year 2035 With Project scenario:
• San Marcos Boulevard (Rancho Santa Fe Road to Discovery Street) o V/C of 0.97 (LOS E)

A significant impact is found for the segment of San Marcos Boulevard from Rancho Santa Fe R oad to Discovery Street because the V/C ratio increase exceeds the 0.02 significance threshold. However, in practice, the peak -hour intersection analysis better indicates street network performance and should supersede the more generalized roadway segmen t daily V/C ratio findings. This is because average daily roadway capacity values include assumptions about the portion of daily traffic occurring occurs during the critical peak hours that neglect the variance in peaking characteristics from one roadway segment to another.

The most accurate evaluation of a roadway segment’s performance should consider peak hour conditions at intersections that bookend the roadway segment, which effectively constrain the capacity of the street segment in between. The peak -hour intersection analysis does not indicate a significant impact at the intersections of San Marcos Boulevard with Rancho Santa Fe Road and Discovery Street, respectively. The acceptable performance of the bookending intersections indicates that the segment of San Marcos Boulevard in between is also performing at an acceptable level.

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Intersections
Two intersections will surpass thresholds in the Year 2035 With Project scenario:
• Discovery Street/Craven Road
o PM Peak Hour – 107.8 second delay – (11.1 second increase in delay compared to 2035 Without Project scenario)
• Twin Oaks Valley Road/San Marcos Boulevard
o AM Peak Hour – LOS E – 74.6 second delay – (1.5 second increase in delay compared to 2035 Without Project scenario) o PM Peak Hour – LOS E – 72.0 second delay – (1.3 second increase in delay compared to the 2035 Without Project scenario) For intersections operating at LOS E or F, an increase in delay of up to 2 seconds is allowed before it would surpass a threshold.

At the intersection of Twin Oaks Valley Road and San Marcos Boulevard, the increase in delay is 1.5 seconds in the AM peak and 1.3 seconds in the PM Peak.

At the intersection of Discovery Street/Craven Road, the increase in delay would be 11.1 seconds if no mitigating project feature was proposed . However, as a project transportation network improvement, the applicant will construct an eastbound right turn lane and signal overlap to the eastbound right. The conceptual layout of this improvement is included in Figure 6.4 of the LTA and the improvements would occur within existing ROW. With this improvement, the intersection will reduce the delay from 107.8 seconds to 25.6 seconds and the intersection is forecast to operate at LOS C so no significant impact is reached.

Therefore, the project would not contribute to a situation where LOS standards are exceeded in the Year 2035 With Project scenario.

Year 2050 Scenario Analysis
Chapters 7 and 8 of the LTA (Appendix G of this document) present the Year 2050 Without Project Condition and the Year 2050 With Project Condition.

Year 2050 – Without Project Scenario
The Year 2050 Without Project scenario analysis assumes that the following roadway improvements will be in place by 2050:
• Barham Drive will expand to a 4-lane major by 2035
• Discovery Street extension will be complete by 2035
• A traffic signal will be installed at the intersection of Bent Avenue and Creekside Drive by 2035
• The channelized right turns at the intersection of Twin Oaks Valley Road and Discovery Street/Barham Drive will be removed by 2035 • The modifications to the SR-78 ramps along Barham will be complete by 2050
• The Grand Avenue bridge will be complete by 2050
• The Bent Avenue bridge will be complete by 2050
Segments
In the Year 20 50 Without Project Scenario, all analyzed roadway segments are forecast to operate at an acceptable LOS.

University District Specific Plan Amendment 80 City of San Marcos FEIR Addendum May 2022
Intersections
The following three intersections will surpass thresholds in the Year 2050 Without Project scenario:
• Twin Oaks Valley Road at Discovery Street/Barham Drive o PM Peak Hour (LOS E) 56.6 second delay
• Twin Oaks Valley Road at San Marcos Boulevard
o AM Peak Hour (LOS F) 80.3 second delay
o PM Peak Hour (LOS E) 75.1 second delay
Year 2050 – With Project Scenario
The Year 2050 With Project scenario analysis assumes that the following roadway improvements will be in place by 2050:
• Barham Drive will expand to a 4-lane major from West La Moree Road to Woodland Parkway by 2035
• Discovery Street extension will be complete by 2035
• A traffic signal will be installed at the intersection of Bent Avenue and Creekside Drive by 2035
• An eastbound right turn lake will be added at the intersection of Discovery Street and Craven Road
• The channelized right turns at the intersection of Twin Oaks Valley Road and Discovery Street/Barham Drive will be removed by 2035 • Completion of the Bent Avenue Bridge by 2035
• The Grand Avenue bridge will be complete by 2050
• Woodland Parkway Interchange Ramp improvements complete by 2050 • Expansion of San Marcos Boulevard from Rancho Santa Fe Road to Discovery Street to a 6 -lane Prime Arterial by 2050 per the Mobility Element
Segments
In the Year 2050 with Project Scenario, all analyzed roadway segments are forecast to operate at an acceptable LOS.

Intersections
Two intersections will surpass thresholds in the Year 2050 With Project scenario:
• Twin Oaks Valley Road at Discovery Street/Barham Drive o PM Peak Hour – LOS E – 58.4 second delay (1.8 second increase in delay compared to the 2050 Without Project scenario) • Twin Oaks Valley Road at San Marcos Boulevard
o AM Peak Hour – LOS F – 81.1 second delay (0.8 second increase in delay compared to the 2050 Without Project scenario) o PM Peak Hour – LOS E – 76.9 second delay (1.8 second increase in delay compared to the 2050 Without Project Scenario) For intersections operating at LOS E or F, an increase in delay of up to 2 seconds is acceptable before it would surpass a threshold.

At the intersection of Twin Oaks Valley Road at Discovery Street/Barham Drive, the increase is 1.8 seconds in the PM Peak. At the intersection of Twin Oaks Valley Road and San Marcos Boulevard, the increase in delay is 0.8 seconds in the AM

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peak and 1.8 seconds in the PM Peak. None of the increases in delay between the Year 2050 Without Project and the Year 2050 With Project Condition would result in a 2 second increase in delay. With the identified network improvements, the project would not contribute to a situation where thresholds are surpassed in the Year 2050 With Project scenario.

Table 10, located at the end of this document, provides a comparison between the traffic analysis in the FEIR, the 2014 FEIR Addendum and the 2002 LTA. It demonstrates that for all analyzed segments and intersections there will be no new significant transportation network impacts or any increase in se verity of transportation network impact with implementation of the proposed project.

Transportation network impacts have been reduced due to the reduction in trips from the proposed project, a reduction in trip generation from projects in the vicinity of t he UDSP, the implementation of roadway and intersection improvements that have already occurred as part of the buildout of the UDSP, the redistribution of traffic from removal of the Johnston Lane SR -78 flyover bridge, and network improvements proposed by the project applicant. In conclusion, there are no new impacts identified for this issue area and no increase in severity of impacts.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3 subdivision (b)?
FEIR Conclusion: Not Analyzed . Section 15064.3(b) of the CEQA Guidelines provide criteria for analyzing transportation impacts. At the time the FEIR was certified, CEQA Guidelines Section 15064.3 was not in effect.

Discussion of the Proposed Project: In order to analyze this threshold, a Vehicle Miles Traveled (VMT) analysis was prepared by Urban Systems as part of the LTA (USA 2022). The analysis is included in Chapter 10 of Appendix G.

Methodology
The methodology used in the VMT analysis is consistent with the TIA Guidelines for a Specific Plan project generating greater than 2,400 average daily trips. The recommendations for a project VMT analysis are based on guidance from the California Governor’s Office of Planning and Research (OPR) through their December 2018 publication, the Technical Advisory on Evaluating Transportation Impacts in CEQA with consideration and focus on the San Diego region. An estimation of vehicle miles traveled specific to the proposed project are to be calculated and modeled by SANDAG as established within the guidelines. Project specific VMT results are then to be compared to regional averages.

Section 2.3 of the TIA Guidelines for a specific plan update requires three (3) SANDAG model runs be conducted as listed below:
• Base Year Model (2016 conditions)
• Cumulative Year Model (2035 currently approved Specific Plan)

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• Cumulative Year Model (2035 proposed Specific Plan Amendment) The TIA Guidelines also require that VMT per resident and VMT per employee be estimated. All three required model runs were complete d and SANDAG VMT reports were produced . Project VMT/capita and VMT/employee estimates were developed in the Series 13 model produced by SANDAG for the cumulative year of 2035. The modeling results are in Chapter 10 of the traffic report (Appendix G) and summarized below.

A significant impact is triggered if the proposed Specific Plan Amendment increases either the VMT per resident or per employee, respectively, over either the base year or the currently approved specific plan levels. If a VMT increas e occurs, an offsetting strategy to lower the VMT to less than the threshold is required.

Analysis Results
The comparative analysis for each of the analysis scenarios is presented in Table 9, with the 2035 VMT forecasted for both the currently approved UD SP and the proposed UDSP amendment.

Table 9. VMT Analysis Summary

Source: Urban Systems 2022
Proposed Plan vs Base Year VMT/Resident
Section 2.3.2 of the TIA Guidelines specifies that there is a n impact if the future plus project scenario exceeds the VMT per resident in the existing (Base Year) condition. The VMT per resident is 6.3 for the proposed specific plan amendment and the VMT per resident is 15.6 for the Base Year (Existing) condition (T able 9).

Since 6.3 is less than 15.6, the VMT does not exceed the threshold and no impact identified.

Proposed Plan vs Base Year VMT/Employee
Section 2.3.2 of the TIA Guidelines specifies that a project surpasses a threshold if the future plans project scenario exceeds the VMT per employee in the existing (Base Year) condition. The VMT per employee is 19.4 for the proposed specific plan amendment and the VMT per employee is 22.4 for the base year (existing) condition (Table 9). Since 19.4 is less than 2 2.4, the VMT does not exceed the threshold and no impact identified.

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Proposed Specific Plan Amendment vs Currently Approved Specific Plan:

VMT/Capita
The VMT per capita for the proposed specific plan amendment is 6.3 and the VMT per capita for the currently approved (previous) specific plan is 10.1 (Table 9).

Since the proposed plan 6.3 is less than the approved plan 10.1, the VMT does not exceed the threshold and no impact identified.

Proposed Specific Plan Amendment vs Currently Approved Specific Plan:

VMT/Employee
Section 2.3.2 of the TIA Guidelines specifies that a project surpasses a threshold if the proposed plan exceeds the approved plan VMT per employee. From Table 9 the proposed specific plan amendment VMT per employee is 19.4 and the VMT for the approved plan is 19.3. Since 19.4 is more than 19.3, the VMT exceeds the threshold.

To address this, VMT reduction measures were identified from Appendix C of the TIA Guidelines (VMT Mitigation Measures Memorandum) (City of San Marcos 2020). Within this memorandum it states that “in a suburban setting the Land Use and Location strategies…would be capped at 5%, and the total reduction would be capped at 15%.”
To calculate the VMT reduction m easures applicable to this project, Table 1:

Applicable VMT Reduction Strategies within Appendix C of the TIA Guidelines (City of San Marcos 2020) was referenced. The VMT reduction measure used to reach the 5% maximum for Project Tier: Land Use and Location was “Increase Job Density.” Therefore, the tot al credit for implementation of sanctioned VMT reduction measures is capped at 5% for the land use and location strategies and 15% total across all strategies.

To calculate this reduction measure, the December 2021 California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity was used (CAPCOA Handbook) (CAPCOA 2021). Based upon the methodology presented in the CAPCOA Handbook, an overall VMT reduction of 5% was achieved via the “increase in job density” strategy. The Amendment proposes 250 jobs per acre, exceeding the typical development density of 145 jobs per acre. Credit for implementing the job density measure achieves 18.4 VMT per employee, which avoids a significant VMT impact.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? FEIR Conclusion: Less than Significant . The Initial Study for the FEIR (Appendix A.2 of the FEIR) did not identify any hazards related to design features or incompatible uses. Impacts were determined to be less than significant.

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Discussion of the Proposed Project: The project does not propose any incompatible uses that could result in hazards. The uses proposed by the project are similar to what was considered in the FEIR and the overall intensity of development within the UDSP would decrease with implementation of the project.

Therefore, no impacts are identified for the proposed project for this issue area.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
d) Result in inadequate emergency access?
FEIR Conclusion: No Impact. The Initial Study of the FEIR (Appendix A.2 of the FEIR) did not identify any impacts related to emergency access.

Discussion of the Proposed Project: Development under the proposed project would still provide the roadway connections via the improvement of both onsite and offsite roadways with the exception of the removal of the Johnston Lane SR- 78 flyover bridge. Under the proposed project, Mid-City Lane would change from a public vehicular route to a public pedestrian paseo. The paseo would be designed in a manner that would still accommodate emergency access.

Modifications to the design of North City Drive would include a median along with re-configuring portions the northerly curb line of North City Drive with rolled curbs that would be designed in a manner so that emergency response vehicles could cross over it, if needed. On-street parking would be restricted along North City Drive and Campus Way to accommodate emergency access. The project also includes underground parking within a structure. The parking entrance and circulation within the structure has been designed to accommodate emergency response vehicles. Finally, t he Fire Marshal has reviewed the proposed SDP for Phases 1 and 2 and has not indicated any issues related to emergency access and response. The LTA demonstrates that there will not be any new roadway or intersection impacts beyond what was already analyzed in the FEIR. Thus, the conclusions in the FEIR are still applicable to the proposed project and no new impacts are identified.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

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18. TRIBAL CULTURAL RESOURCES – Would the project:
a) Cause a substantial adverse change in the significance of a tribal cultural resources, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is listed or eligible for listing in the California Register of Historic Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k)? FEIR Conclusion: Not Analyzed. The requirement to analyze a project’s potential impact to tribal cultural resources became a requirement after certification of the FEIR. The FEIR did analyze potential impacts to cultural resources, and those conclusions are summarized in Section V. of this document.

Discussion of the Proposed Project: Consistent with the requirements of SB 18, the City sent out letters to local Tribes. Consultation requests were received from the San Luis Rey Band of Mission Indians, the Rincon Band of Luiseno Indians and the San Pasqual Band of Mission Indians. The Jamul Indian Village of California also submitted a letter but did not request consultation. Mitigation measures identified for cultural resources would still be applicable under the proposed project. Future developmen t within the UDSP planning area will be required to adhere to mitigation measures CR -1 through CR —4, which address archaeological monitoring requirements during grading. Additionally, a ny future development that results in grading is subject to the City’s standard conditions of approval that require monitoring by an archaeologist and Native American tribal monitor for any grading activities that occur in previously undisturbed areas.

These standard conditions have been developed in coordination with local tribes.

The proposed project does not result in any increase in potential for impact to tribal cultural resources.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Cause a substantial adverse change in the significance of a tribal cultural resource that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of the Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

FEIR Conclusion: Not Analyzed. The requirement to analyze a project’s potential impact to tribal cultural resources became a requirement after certification of the FEIR. The FEIR did analyze potential impacts to cultural resources, and those conclusions are summarized in Section V. of this document.

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California also submitted a letter but did not request consultation. Mitigation measures identified for cultural resources would still be applicable under the proposed project. Future development within the UDSP planning area will be required to adhere to mitigation measures CR -1 through CR —4, which address archaeological monitoring requirements during grading. Additionally, a ny future development that results in grading is subject to the City’s standard conditions of approval that require monitoring by an archaeologist and Native American tribal monitor for any grading activities that occur in previously undisturbed areas.

These standard conditions have been developed in coordination with local tribes.

The proposed project does not result in any increase in potential for impact to tribal cultural resources.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

19. UTILITIES AND SERVICE SYSTEMS – Would the project:
a) Require or result in relocation or the construction of new or expanded water, wastewater treatment facilities, or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
FEIR Conclusion: Mitigated to Below a Level of Significance. The FEIR (pages

3.14-8 through 3.14 -18) analyzed the potential for the UDSP project to impact water and wastewater infrastructure due to additional residential, student housing, hotel and commercial business development. The FEIR concluded that additional development would increase demands on water and wastewater treatment facilit ies and require regional infrastructure improvements to accommodate the increases. Mitigation measures US -4 through US -6 were identified in the FEIR to reduce the impact to below a level of significance. These mitigation measures require fair share funding for future wastewater upgrades.

Discussion of the Specific Plan Amendment: Development of the proposed project would decrease development yield and decrease the overall demand for utilities compared to the currently approved UDSP.

Based upon the Water System Analysis and the Sewer System Analysis prepared by Dexter Wilson Engineering (DWE) and included in Appendices I and J, the project will decrease wastewater generation by approximately 33% and water demand by approximately 19%. Information related t o water and sewer infrastructure, as analyzed in the DWE reports, is provided below.

Water Infrastructure Analysis
The proposed project would still be served by VWD for water service. The storage and supply for the proposed project will still be from the District 920 Zone System.

The 920 Zone system feeds the 855 Zone system through several pressure reducing stations. The majority of existing water demands within VWD are supplied by the 920/855 Zone system. The 920 Zone includes four water storage reservoirs with a total combined capacity of 18 million gallons. There is a 24-inch transmission line in Twin Oaks Valley Road that supplies 920 Zone water to the area. The 855 Zone is formed by five existing pressure reducing stations that

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supply water from the 920 Zone. One of these pressure reducing stations (PRS), Barham PRS, is located adjacent to the project at the intersection of Twin Oaks Valley Road and Barham Drive. This station includes 4 -inch and 8-inch pressure reducing valves. There are 12-inch water lines at the western edge of the project in Grand Avenue and Discovery Street.
855 Zone Facilities
The primary source of water to the project’s 855 Zone supply will be the 920/855 Zone pressure reducing station located at the inters ection of Twin Oaks Valley Road and Barham Drive. There are also 920/855 Zone pressure reducing stations west and north of the project that can supply water to the project. To meet the fire flow requirements of the project, the Water Analysis Study (DWE 2021a) recommends several connections with 12 -inch looping throughout the project west of Twin Oaks Valley Road. Two connections are proposed to the 12- inch future water line in Discovery Street. The 12 -inch water line is proposed to be constructed within the development footprint of Discovery Street westerly to the existing 12-inch water line in Grand Avenue.
920 Zone Facilities
The primary source of water to the project’s 920 Zone supply will be the large diameter transmission water lines originating from several existing VWD storage reservoirs. The closest District 920 Zone storage reservoir to the project site is the 7 million gallon Via Vera Cruz Reservoir approximately one mile south of the project’s southwest corner. To meet the fire flow requirements of the project, the Water Analysis Study (DWE 2021a) recommends several connections with 12 - inch and 10 -inch looping throughout the project east of Twin Oaks Valley Road.

These connections are within the proposed development footprint and would not result in any new impacts or increase in severity of impacts.

Sewer Infrastructure
Onsite Sewer Facilities
The project would still be served by VWD for sewer services. The sewer system analysis concluded the proposed project can be served by the construction of onsite gravity sewers and connection to the existing system at several locations (DWE 2021b) . The eastern portion of the project proposes to connect to an existing 8-inch diameter gravity sewer line in Carmel Street. The majority of the project proposes to connect to the existing gravity sewer lines in Twin Oaks Valley Road. The western portion of the project will convey flow to the intersection of Discovery Street and Grand Avenue. From this location, approximately 1,000 to 2,000 feet of offsite sewer line will be necessary to convey flow westerly to the existing 16 -inch diameter sewer line in Craven Road. This sewer segment is currently being installed as part of the Discovery Road extension.

Offsite Sewer Facilities
The eastern portion of the project will convey flows through an existing 8 -inch sewer line in Carmel Street. This line conveys flow s northerly across SR-78 and connects into a 12-inch line. The hydraulic analysis indicates that one section of this alignment flows above a 0.5 d/D ratio with additional flows from the project.

The western portion of the project will require an offsite sewer line to convey flow to the existing 16 -inch gravity sewer line in Craven Road, as detailed above.

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Approximately 1,000 to 2,000 feet of offsite sewer line will be necessary to convey flow westerly to the existing 16 -inch diameter sewer line in Craven Road. This sewer segment is currently being installed as part of the Dis covery Road extension.

The middle portion of the project will convey flow to an existing 21 -inch diameter sewer line in Twin Oaks Valley Road that conveys flow northerly across SR -78 before connecting into a regional interceptor. A separate memorandum was prepared by DWE, Assessment of Capacity in the Existing 21 -Inch Sewer Twin Oaks Valley Road at State Route 78 Undercrossin g, to specifically assess the capacity of the existing 21 -inch trunk sewer line in Twin Oaks Valley Road (DWE 2022). Per the DWE 2022 memo, several sewer studies have been performed by VWD which have provided updated analysis for this 21-inch sewer line as well as the overall regional sewer systems. There was also an update to the overall VWD Master Plan in 2018 which used the current UDSP land use assumptions. VWD studies in 2017, 2019 and 2021 all analyzed the 21-inch sewer line and all three studies concluded that there is sufficient capacity for the proposed project. These studies concluded that peak flows are projected to between 2,004 gallons per minute (gpm) and 2,409 gpm. These flows result in a maximum d/D ratio of 0.60.

This is below the VWD maximum d/D ratio of 0.75.

Regional Analysis and Improvements
At the time of the 2009 FEIR preparation, there was an approximately 7,000 foot section of existing interceptor from Grand Avenue to Lift Station Number 1 that was identified for replacement in the VWD Master Plan. This interceptor has been ultimately replaced since that time with a 42-inch diameter sewer interceptor.

VWD is also planning to construct a parallel and replace select land outfall segments from Lift Station Number 1 to the Encina Wastewater Authority to accommodate ultimate development. VWD is planning on a 30-inch to 48 -inch parallel and new outfall pipelines to accommodate buildout flows per the Master Plan. These proposed VWD improvements incorporate the anticipated flows from the proposed project.

The VWD has 7.67 million gallons per day (mgd) of liquid treatment capacity at Encina and 5.0 mgd at the Meadowlark Treatment Plant for a total of 12.67 mgd.

The 2018 VWD Master Plan projected ultimate flows for VWD to be 14.40 mgd.

VWD will be required to purchase additional capacity in the Encina System.

Stormwater Drainage
Stormwater drainage was addressed in Section 10, Hydrology and Water Quality, above. The project will relocate
Add discussion on stormwater drainage about relocation into North City Drive and upsizing of storm drain line, and storm water quality facilities on-site.

Future development within the UDSP would be required to coordinate with VWD for project-specific water/sewer studies and the applicant would be required to comply with all requirements identified in the studies. Similarly, the project applicant would b e required to coordinate with SDG&E for electricity and gas service. Therefore, the conclusions of the FEIR apply to the proposed project and no new impacts are identified.

University District Specific Plan Amendment 89 City of San Marcos FEIR Addendum May 2022
Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? FEIR Conclusion: Mitigated to Below a Level of Significance. The FEIR (page 3.14- 28) determined that the water demand for the project would be 1,207,011 gallons per day (gpd). Water supply impacts w ere determined to be significant, and improvements would be required for water storage and water infrastructure to accommodate the increase in demand due to the proposed project. Mitigation measures US -1 through US -3 would provide water pipeline improvements and payment of fees towards the provision of a dditional water storage. Improving infrastructure and increasing storage would reduce impacts to below a level of significance.

Discussion of the Specific Plan Amendment: A Water System Analysis was prepared for the project by Dexter Wilson Engineering (DWE) dated November 24, 2021. The complete report is included as Appendix H. The report provides information concerning projected water demands, existing facilities, and proposed major facilities and onsite/offsite improvements necessary to provide adequate water service to the proposed project.

Projected water demand for the proposed project would be 975,225 gpd. The FEIR assumed a water demand of 1,207,011 gpd Therefore, the proposed project would decrease overall water demand by 231,786 gpd, or approximately 19%.

VWD’s Master Plan assumed the b uildout of the current UDSP in their water planning efforts. Therefore, the less intensive water demand under the proposed project would have been accounted for and there are no new significant impacts or an increase in impacts related to water supply.

Additionally, s ince certification of the FEIR, there have been additional requirements related to water conservation and water efficiency through CALGreen (California Green Building Standards Code). Future development within the UDSP would have to adhere to the latest CALGreen requirements which would reduce water demand. Local requirements include water efficiency measures that are identified in the City’s CAP and implantation of the City’s Water Efficient Landscape Ordinance (WELO). Therefore, the conclusions of the FEIR apply to the proposed project and no new impacts are identified.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
c) Result in a determination by the wastewater treatment provider, which serves or may serve the project, that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? FEIR Conclusion: Mitigated to Below a Level of Significance. The FEIR (page 3.14- 28) determined that wastewater impacts would be significant and infrastructure and treatment facility improvements are required for the UDSP project. The FEIR

University District Specific Plan Amendment 90 City of San Marcos FEIR Addendum May 2022
assumed a sewer generation of 1,058,389 gpd. Mitigation measures US -4 through US-6 require the future developer to participate in regional infrastructure improvements to accommodate the increase in wastewater flows. Additionally, payment of fees towards increased wastewater treatment capacity would ensure that adequate services ar e available for the proposed project. The future developers within the site will be required to enter into future water and sewer service agreements. These agreements will further detail the extent and timing of the water and sewer mitigation and define h ow these improvements relate to other fees to be paid to VWD. By implementing these mitigation measures, impacts to wastewater would be reduced to below a level of significance for the UDSP.

Discussion of the Specific Plan Amendment: A Sewer System Analysi s was prepared for the project by Dexter Wilson Engineering (DWE) dated November 24, 2021. The complete report is included as Appendix I. The report provides a sewer system analysis for the proposed project including the calculation of the projected sewage flows, existing facilities, proposed major facilities, and onsite/offsite improvements necessary to provide adequate sewer service to the project.

Projected sewer generation for the proposed project would be 710,480 gpd. The FEIR assumed a sewer generati on of 1,058,389 gpd. Therefore, the proposed project, which decreases overall development yields, will decrease wastewater generation by 347,909 gpd or approximately 33%.

Additionally, VWD’s 2018 Water, Wastewater and Recycled Water Master Plan assumed a higher development yield on the project site than what is currently proposed. As indicated on page 2 -11 of the Master Plan, “permitted planned development includes 1,000,000 s.f. of commercial space, 938,000 s.f. of office space, 30,000 s.f. of civic/community space, 2,600 multi-family residential units, 800 student housing units, and 450 hotel rooms.”
Development of the proposed project would decrease the overall development yield which decreases sewer generation by approximately 33%. The project’s wastewater generation and treatment needs were considered in VWD’s 2018 Master Plan. The proposed project would not result in any new wastewater impacts or an increase in severity of wastewater impacts. Theref ore, the conclusions in the FEIR apply to the proposed project and no new impacts are identified.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
d) Generate solid waste in excess of State or local standards or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
FEIR Conclusion: Less than Significant. The FEIR (page 3.14 -19) identified that the Sycamore Sanitary Landfill would have sufficient capacity for the UDSP project assuming a 50 percent diversion rate and with the implementation of a construction waste management program to divert materials. The FEIR analysis included waste generated due to the demolition of structures on the project site.

University District Specific Plan Amendment 91 City of San Marcos FEIR Addendum May 2022
Discussion of the Specific Plan Amendment: Development under the proposed project would still be of the type considered in the UDSP FEIR, however the overall development yield would decrease. Since certification of the FEIR, there have been additional regulatory requirements related to recycling and landfill diversion.

Thus, the amount of solid waste to be generated by the UDSP planning area, as a whole, is anticipated to be less than what was anticipated in the FEIR due to the reduction in development intensity and the increase in landfill diversion and recycling requirements. Therefore, no new impacts are identified for this issue area. The proposed project would comply with federal, state and local statues and regulations related to solid waste. Therefore, the conclusions of the FEIR apply to the proposed project and no new impacts are identified.

Finding: There are no new impacts for this issue area and no cha nges in information that would require preparation of an EIR.
e) Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
FEIR Conclusion: No Impact. The FEIR (page 3.14 -3) addresses AB 939, the Integrated Waste Management Act, which identifies the diversion rate of 50 percent of solid waste through reduction, recycling, and composting activities and the mandate that all California cities and counties achieve a 75 percent diversion rate by the year 2010. According to the FEIR, the City was at a 50 percent reduction rate as of 2009 and is compliant with AB 939.

Discussion of the Specific Plan Amendment: Development under the proposed project would still be of the type considered in the UDSP FEIR, however the overall development yield would decrease. Since certification of the FEIR, there have been additional regulatory requirements related to recycling and landfill diversion including state requirements addressing green waste and composting . Thus, the amount of solid waste to be generated by the UDSP planning area, as a whole, is anticipated to be less than what was anticipated in the FEIR due to the reduction in development intensity and the increase in landfill diversion and recycling requirements. Therefore, no impacts are identified for this issue area. The proposed project would comply with federal, state and local statues and regulations related to solid waste. Therefore, the conclusions of the FEIR apply to the proposed project and no new impacts are identified.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

20. WILDFIRE. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones would the project:
a) Substantially impair an adopted emergency response plan or emergency evacuation plan;

b) Due to slope, prevailing wind, and other factors exacerbate wildlife risk, and thereby, expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of wildfire;

University District Specific Plan Amendment 92 City of San Marcos FEIR Addendum May 2022
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; or
d) Expose people or structure to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability or drainage changes.

FEIR Conclusion: Not Analyzed. The requirement to analyze a project’s potential impacts related to wildfire as a separate environmental topic became a requirement after certification of the FEIR. The FEIR did analyze the potential for the project to expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where resid ences are intermixed with wildlands and impacts were determined to be less than significant (FEIR Section 3.6).

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

The project site is located within a Non‐Very High Fire Hazard Severity Zone (Non‐ VHFHSZ) designation per CalFire’s San Marcos Fire Hazards Severity Zones Map (2009) and is surrounded by areas also identified as Non‐VHFHSZ. Therefore, this threshold does not apply to the project. Further, per Figure 6 ‐4 of the Safety Element of the City’s General Plan, the project site and surrounding area are not identified as a SMFPD Community Hazard Zone. Thus, the proposed project would result in less than significant impacts related to wildfire.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

21. MANDATORY FINDINGS OF SIGNIFICANCE
a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?
FEIR Conclusion: The Final EIR for the UDSP concluded that all biological resource impacts would be mitigated to below a level of significance (FEIR Section 3.3).

Additionally, the FEIR concluded that that impact to cultural resources would be mitigated to below a level of significance (FEIR Section 3.4).

University District Specific Plan Amendment 93 City of San Marcos FEIR Addendum May 2022
Discussion of the Proposed Project: Development under the proposed project would still occur within the footprint analyzed in the FEIR, with the addition of the two parcels. APN 220 -201-90-00 is 6.3 acres and grading has commenced on this parcel consistent with a prior entitlement that was subject to CEQA review (ND 06-748). APN 220 -202-18-00 is 1.7 acres and owned by NCTD. Within the UDSP, this parcel would be designated as Office/Commercial with a Railroad ROW overlay and no development would occur on the 1.7-acre site.

Biological resources and cultural resources mitigation identified in the FEIR will still be applicable to future development under the proposed project. The proposed project would not result in any increase in impacts to biological resources or cultural resources compared to what was analyzed in the FEIR.

Finding: There ar e no new impacts for this issue area and no changes in information that would require preparation of an EIR.
b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.)
FEIR Conclusion: The FEIR prepared for the UDSP concluded that the project would have significant and unmitigated cumulative impacts related to air quality (CO, NOx, and ROG), greenhouse gas emissions, and traffic in the 2030 -time frame (SR -78 ramps/segments and the intersection of San Marcos Boulevard/Rancho San ta Fe Road). All other issues areas were determined to have cumulative impacts that were less than significant.

Discussion of the Proposed Project: Implementation of the proposed project would result in a type of development that was considered in the UDSP FEIR but at a lower overall development intensity. As part of this analysis the University District Local Transportation Analysis was prepared for the project (USA 2022).

The analysis did not identify any new traffic impacts and some of the previously identified roadway segment and intersection impacts would be reduced due to the redistribution of traffic that would come with removal of the Johnston Lane SR-78 flyover bridge. No new cumulative impacts are identified for the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.
c) Does the project have environmental effects that will cause substantial adverse effects on human beings, either directly or indirectly? FEIR Conclusion: The FEIR prepared for the UDSP did not identify any project impacts that would have environmental effects on human beings either directly or indirectly with the exception of unmitigated project - and cumulative-level air quality and greenhouse gas impacts, as discussed in 20(b), above.

Discussion of the Proposed Project: Development proposed under the project would still be of the type contemplated in the UDSP FIER but at a lower

University District Specific Plan Amendment 94 City of San Marcos FEIR Addendum May 2022
development intensity. There are no new impacts or issues ide ntified that would have environmental effects on human beings either directly or indirectly that were not previously identified in the FEIR. Therefore, the FEIR adequately disclosed the potential impacts of the proposed project.

Finding: There are no new impacts for this issue area and no changes in information that would require preparation of an EIR.

EARLIER ANALYSES
Earlier analyses may be used where, pursuant to tiering, program EIR, or other CEQA process, one or more effects have been adequately analyzed in an earlier EIR or Negative Declaration (Section 15063(c)(3)(D)). These documents are on file with the City of San Marcos Planning Division.
o GPA 06-97/RC06-134/SPA 87-29 (06M #21)/TA 06 -59/SDP 06-319/ TPM 651 (Zirpolo Property). Negative Declaration No. 06-748. 2006 o University District Specific Plan Final Environmental Impact Report. 2009. (SCH No. 2008101083)
o University District Rock Crusher Conditional Use Permit. 2011. (SCH No. 2011081083)
o University District Specific Plan Final Environmental Impact Report Addendum. 2014.
o University District Specific Plan Block 3 Addendum to FEIR. 2017. o Heart of the City Final Environmental Impact Report No 06 -87. City of San Marcos. SCH No. 87072926.

University District Specific Plan Amendment 95 City of San Marcos FEIR Addendum May 2022
References
Ascent Environmental. 2020. Guidance to Demonstrating Consistency with the City of San Marcos Climate Action Plan: For Discretionary Project Subject to CEQA Memorandum. July 15.

CalFire. 2009. Very High Fire Hazards Severity Zones in LRA.

California Air Pollution Control Officers Association (CAPCOA). 2021. Handbook for Analyzing Greenhouse Gas Emissions Reduction, Assessing Climate Vulnerabilities and Advancing Health and Equity. Final Draft. December.
http://www.airquality.org/ClimateChange/Documents/Final%20Handbook_AB434.pdf California Department of Conservation (CDC). 2021. EQ Zapp: California Earthquake Hazard Zone Application. https://www.conservation.ca.gov/cgs/geohazards/eq-zapp :Last updated September 23, 2021.

Caltrans (California Department of Transportation). 2011. Officially Designated State Scenic Highways.https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community- livability/lap-liv-i-scenic-highways Viewed January 14, 2022.

Cambria Community Services District (CCSD). 2017. Sustainable Water Facility Project Final Subsequent Environmental Impact Report. July.

City of San Luis Obispo. 2017. San Luis Ranch Specific Plan Final Environmental Impact Report.

May.
https://www.slocity.org/home/showpublisheddocument/15653/636305426516470000 City of San Marcos. 2020. Transportation Impact Guidelines. November 16.

City of San Marcos. 2012. General Plan. https://www.san -marcos.net/departments/development- services/general-plan
City of S an Marcos. 2006. Negative Declaration No. 06 -748 for GPA 06 -97/RC06-134/SPA 87-29 (06M #21)/TA 06-59/SDP 06-319/ TPM 651. November 13.

County of San Diego. 2007. Report Format & Content Requirements – Visual Resources. July 30. https://www.sandiegocounty.gov/content/dam/sdc/pds/docs/visual_report_formats.pdf

Department of Toxic Substance Control (DTSC). 2022. EnviroStor Database. https://www.envirostor.dtsc.ca.gov/public/map/?myaddress=san+marcos%2C+ca Viewed January 14, 2022.

Dexter Wilson Engineering, Inc. (DWE). 2022. Assessment of Capacity to the Existing 21 -inch Sewer Twin Oaks Valley Road and State Route 78 Undercrossing – University District Project. April 19.

Dexter Wilson Engineering, Inc. (DWE). 2021a. Water System Analysis for the North City U niversity District Specific Plan Amendment. November 24.

Dexter Wilson Engineering, Inc. 2021b. Sewer System Analysis for the North City University District Specific Plan Amendment. November 24.

LDN Consulting. 2022a. Air Quality Emissions Letter - UDSP Amendment in San Marcos, CA. May 13.

University District Specific Plan Amendment 96 City of San Marcos FEIR Addendum May 2022
LDN Consulting. 202 2b. Greenhouse Gas Assessment. University District Specific Plan Amendment.

May 13.

LDN Consulting. 2022c. Energy Usage Letter – UDSP Amendment in San Marcos. May 13.

LDN Consulting. 2022d. Noise Analysis Letter – UDSPA Amendment in San Marcos CA. May 13.

National Fire Protection Association (NFPA). 2016. High -Rise Building Fires. November. https://www.nfpa.org/-/media/Files/News-and-Research/Fire-statistics-and-reports/Building-and- life-safety/oshighrise.pdf
RBF Consulting. 2014. University District Specific Plan Amendment Traffic Impact Assessment. April

17. San Diego County Regional Airport Authority (SDCRAA). 2021. Letter to Arthur Piñon from Ralph Redman.

San Marcos Unified School District (SMUSD). 2021. School Facilities Needs Analysis (SFNA). March

18. Stevens Cresto Engineering (SCE). 2002a. Preliminary Drainage Study for North City Phase A & B SDP 21-0002, San Marcos, CA. May 16.

Stevens Cresto Engineering, Inc (SCE). 2022 b. PDP Stormwater Quality Management Plan for North City Phase A and B SDP 21-0002. May 16.

United States Census Bureau (USCB). 2020. Quick Facts Escondido City, San Marcos City, California, United States.
https://www.census.gov/quickfacts/fact/table/escondidocitycalifornia,sanmarcoscitycalifornia,US/P ST045219
Viewed January 14, 2022

Urban Systems Associates. 2022. University District Local Transportation Analysis. May 19.

University District Specific Plan Amendment 97 City of San Marcos FEIR Addendum May 2022
Table 10. Traffic Impact Analysis Comparison FEIR, 2014 FEIR Addendum and 2022 LTA Analysis Segment or
Intersection Identified
as Having a Significant
Impact in FEIR

FEIR Conclusions 2014 FEIR Addendum

2022 LTA Analysis New Significant Effect or
a Substantial Increase in
the Severity of
Previously Identified
Significant Effects?

SEGMENTS
Discovery Street, from
San Marcos Boulevard to
La Sombra Drive

Significant impact,
mitigation identified to
reduce to below a level of
significance
Mitigation reconfirmed and
timing for implementation
clarified.

Due to changes in volume
distribution, this segment is no longer
impacted.

No
Discovery Street, from La
Sombra Drive to Via Vera
Cruz

Significant impact,
mitigation identified to
reduce to below a level of
significance
Mitigation reconfirmed and
timing for implementation
clarified.

Due to changes in volume
distribution, this segment is no longer
impacted.

No
Bent Avenue, from San
Marcos Boulevard to
Discovery Street

Significant impact,
mitigation identified to
reduce to below a level of
significance
Mitigation reconfirmed and
timing for implementation
clarified.

Due to changes in volume
distribution, this segment is no longer
impacted.

No
Westlake Drive, North of
San Marcos Boulevard

Significant impact,
mitigation identified to
reduce to below a level of
significance
Mitigation reconfirmed and
timing for implementation
clarified.

Not analyzed as it was not in the
study area for the updated traffic
report (See Note 1)

No - Segment no longer in
study area
Twin Oaks Valley Road,
from San Marcos
Boulevard to Richmar
Avenue

Significant impact,
mitigation identified to
reduce to below a level of
significance

Mitigation reconfirmed and
timing for implementation
clarified.

Due to changes in volume
distribution, this segment is no longer
impacted.

No
San Marcos Boulevard
from Rancho Santa Fe to
Discovery Street

Analyzed, no impact
identified.

No impact identified. Due to changes in volume
distribution, this segment is no longer
impacted.

INTERSECTIONS
Mission Road /
Knoll Road
Mitigation identified to
reduce impact to below a
level of significance
Mitigation reconfirmed and
timing for implementation
clarified.

Not analyzed as it was not in the
study area for the updated traffic
report (See Note 1)

No - Intersection no longer
in study area

University District Specific Plan Amendment 98 City of San Marcos FEIR Addendum May 2022
Segment or
Intersection Identified
as Having a Significant
Impact in FEIR

FEIR Conclusions 2014 FEIR Addendum

2022 LTA Analysis New Significant Effect or
a Substantial Increase in
the Severity of
Previously Identified
Significant Effects?
San Marcos Boulevard /
Rancho Santa Fe Road
Significant and unmitigated
in 2030 scenario.

Mitigation reconfirmed and
timing for implementation
clarified.

Not analyzed as it was not in the
study area for the updated traffic
report (See Note 1).

No - Intersection no longer
in study area
San Marcos Boulevard /
Discovery Street
Analyzed, no impact
identified.

No impact identified. No impact in the 2035 or 2050 time frame.

No
San Marcos Boulevard /
Las Posas Road
Mitigation identified to
reduce impact to below a
level of significance.

Mitigation reconfirmed and
timing for implementation
clarified.

Not analyzed as it was not in the
study area for the updated traffic
report (See Note 1).

No - Intersection no longer
in study area
San Marcos Boulevard /
Via Vera Cruz
Mitigation identified to
reduce impact to below a
level of significance.

Mitigation reconfirmed and
timing for implementation
clarified.

Due to changes in volume distribution
this intersection no longer impacted.

No
San Marcos Boulevard/
Bent Avenue
Mitigation identified to
reduce impact to below a
level of significance.

Mitigation reconfirmed and
timing for implementation
clarified.

Due to changes in volume distribution
this intersection no longer impacted.

No
San Marcos Boulevard /
Grand Avenue
Mitigation identified to
reduce impact to below a
level of significance.

Mitigation reconfirmed and
timing for implementation
clarified.

Due to changes in volume distribution
this intersection no longer impacted.

No
San Marcos Boulevard /
Twin Oaks Valley Road
Mitigation identified to
reduce impact to below a
level of significance.

Mitigation reconfirmed and
timing for implementation
clarified.

Due to changes in volume
distribution, this segment is no longer
impacted.

No
Discovery Street /
Bent Avenue
Analyzed, no impact
identified.

Not analyzed. No impact in the 2035 or 2050 time
frame.

No
Discovery Street /
La Sombra Drive
Mitigation identified to
reduce impact to below a
level of significance.

Mitigation reconfirmed and
timing for implementation
clarified.

Due to volume distribution, this
intersection no longer impacted.

No
Discovery Street /
Craven Road
Analyzed, no impact
identified.

Not analyzed. Project applicant will construct an
eastbound right turn lane and overlap
to the eastbound right.

No significant effect with
implementation of
identified project design
feature improvement.

Discovery Street /
Via Vera Cruz
Analyzed, no impact
identified.

Not analyzed. No impact in the 2035 or 2050 time
frame.

University District Specific Plan Amendment 99 City of San Marcos FEIR Addendum May 2022
Segment or
Intersection Identified
as Having a Significant
Impact in FEIR

FEIR Conclusions 2014 FEIR Addendum

2022 LTA Analysis New Significant Effect or
a Substantial Increase in
the Severity of
Previously Identified
Significant Effects?
Barham Drive /
La Moree Road
Mitigation identified to
reduce impact to below a
level of significance.

Mitigation reconfirmed and
timing for implementation
clarified.

Due to changes in volume distribution
this intersection no longer impacted.

No
Barham Drive /
Woodland Parkway
Mitigation identified to
reduce impact to below a
level of significance.

Mitigation reconfirmed and
timing for implementation
clarified.

Not analyzed as it was not in the
study area for the updated traffic
report (See Note 1).

No - Intersection no longer
in study area
Twin Oaks Valley Road/
Borden Road
Mitigation identified to
reduce impact to below a
level of significance.

Mitigation reconfirmed and
timing for implementation
clarified.

Due to changes in volume distribution
this intersection no longer impacted.

No
Twin Oaks Valley Road/
San Marcos Boulevard
Mitigation identified to
reduce impact to below a
level of significance.

Mitigation reconfirmed and
timing for implementation
clarified.

Due to changes in volume distribution
this intersection no longer impacted.

No
Twin Oaks Valley Road/
SR 78 Eastbound Ramp
Significant and unmitigated
in 2030 scenario.

Mitigation reconfirmed and
timing for implementation
clarified.

Due to changes in volume distribution
this intersection no longer impacted.

No
Bent Avenue/
Creekside Drive
Not analyzed because
intersection did not exist at
that time FEIR was
prepared.

Not analyzed. No impact identified. No
Notes:
(1) The study area was determined with use of the SANDAG model and coordination with city staff, this segment or intersection did not fall into the determined study area.

University District Specific Plan Amendment 100 City of San Marcos FEIR Addendum May 2022
Figure 1. UDSP Site Map

University District Specific Plan Amendment 101 City of San Marcos FEIR Addendum May 2022
Figure 2. Proposed Building Height Regulating Plan

University District Specific Plan Amendment 102 City of San Marcos FEIR Addendum May 2022
Figure 3a. Twin Oaks Valley Road and Craven Road (Looking North) – Current Height Regulations

University District Specific Plan Amendment 103 City of San Marcos FEIR Addendum May 2022
Figure 3b. Twin Oaks Valley Road and Craven Road (Looking North) – Proposed Height Regulations

University District Specific Plan Amendment 104 City of San Marcos FEIR Addendum May 2022
Figure 4a. North Twin Oaks Valley Road at Mission Road Overpass (Looking South) – Current Height Regulations

University District Specific Plan Amendment 105 City of San Marcos FEIR Addendum May 2022
Figure 4b. North Twin Oaks Valley Road at Mission Road Overpass (Looking South) – Proposed Height Regulations

University District Specific Plan Amendment 106 City of San Marcos FEIR Addendum May 2022
Figure 5a. North Twin Oaks Valley Road Approaching San Marcos Boulevard (Looking South) – Current Height Regulations

University District Specific Plan Amendment 107 City of San Marcos FEIR Addendum May 2022
Figure 5b. North Twin Oaks Valley Road Approaching San Marcos Boulevard (Looking South) – Proposed Height Regulations

University District Specific Plan Amendment 108 City of San Marcos FEIR Addendum May 2022
Figure 6a. North Twin Oaks Valley Road Approaching San Marcos Boulevard (Looking South) – Proposed Height Regulations

University District Specific Plan Amendment 109 City of San Marcos FEIR Addendum May 2022
Figure 6b. North Twin Oaks Valley Road Approaching San Marcos Boulevard (Looking South) – Proposed Height Regulations

University District Specific Plan Amendment 110 City of San Marcos FEIR Addendum May 2022
Figure 7a. SR-78 at San Marcos Boulevard Overcrossing (Looking South-East) – Current Height Regulating Plan

University District Specific Plan Amendment 111 City of San Marcos FEIR Addendum May 2022
Figure 7b. SR-78 at San Marcos Boulevard Overcrossing (Looking South-East) – Proposed Height Regulating Plan

University District Specific Plan Amendment 112 City of San Marcos FEIR Addendum May 2022
Figure 8a. Eastbound SR-78 East of Twin Oaks Valley Road (Looking East) – Current Height Regulating Plan

University District Specific Plan Amendment 113 City of San Marcos FEIR Addendum May 2022
Figure 8b. Eastbound SR-78 East of Twin Oaks Valley Road (Looking East) – Proposed Height Regulating Plan

University District Specific Plan Amendment 114 City of San Marcos FEIR Addendum May 2022
Figure 9a. Westbound SR-78 (Looking West) – Current Height Regulating Plan

University District Specific Plan Amendment 115 City of San Marcos FEIR Addendum May 2022
Figure 9b. Westbound SR-78 (Looking West) – Proposed Height Regulating Plan

University District Specific Plan Amendment 116 City of San Marcos FEIR Addendum May 2022
Figure 10a. Twin Oaks Valley Road & North City Drive (Looking South-East) – Current Height Regulating Plan

University District Specific Plan Amendment 117 City of San Marcos FEIR Addendum May 2022
Figure 10b. Twin Oaks Valley Road & North City Drive (Looking South-East) – Proposed Height Regulating Plan

University District Specific Plan Amendment 118 City of San Marcos FEIR Addendum May 2022
Figure 11. Building Height Diagram

University District Specific Plan Amendment 119 City of San Marcos FEIR Addendum May 2022
Figure 12a. Building Height Cross Section (1 of 2)

University District Specific Plan Amendment 120 City of San Marcos FEIR Addendum May 2022
Figure 12b. Building Height Cross Section (2 of 2)

University District Specific Plan Amendment 121 City of San Marcos FEIR Addendum May 2022
Figure 13. Twin Oaks Valley Road and Campus Market Place (Looking North) – Night Rendering

University District Specific Plan Amendment 122 City of San Marcos FEIR Addendum May 2022
Figure 14. Twin Oaks Valley Road and North City Drive (Looking South-East) – Night Rendering 2

San Marcos City CouncilJuly 12, 2022

San Marcos City Council
July 12, 2022