ATTACHMENT A-6
GENERAL PLAN IMPACT (LAND USE) ANALYSIS
200 North Las Posas Road Project
General Plan Impact Analysis
prepared for
A & S Engineering
28405 Sand Canyon Road, Suite B
Canyon County, California 91387
prepared by
Rincon Consultants, Inc.
2215 Faraday Avenue, Suite A
Carlsbad, California 92008
November 2022
Table of Contents
General Plan Impact Analysis i
Table of Contents
1 General Plan Impact Analysis ..........................................................................................................1
1.1 Executive Summary ............................................................................................................. 1
1.2 Public Benefits Analysis ....................................................................................................... 4
1.3 Land Use Analysis ................................................................................................................ 7
1.4 Infrastructure and Community Services Impact Analysis ................................................. 19 Tables
Table 1 Recurring Fiscal Revenues (City General Fund) ...................................................................5 Table 2 Recurring Fiscal Costs (City General Fund) ..........................................................................6 Table 3 Annual Net Fiscal Impact (City General Fund) .....................................................................7 Table 4 Consistency of Land Use and Community Design General Plan Goals ................................7 Table 5 Consistency of General Plan Guiding Themes .................................................................. 13 Figures
Figure 1 Project Location ...................................................................................................................3 Figure 2 Surrounding Land Uses ..................................................................................................... 16
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General Plan Impact Analysis
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1 General Plan Impact Analysis
1.1 Executive Summary
The Arco Gas Station project (herein referred to as the proposed plan) is proposed to be located at 200 North Las Posas Road and consists of the development of a 5,000 square foot food mart with a drive thru (3,800 square foot food mart and 1,200 square feet of retail), a 2,000 square foot car wash with a 1,000 square foot equipment room, and a 6,192 square foot gas station canopy with nine fuel dispensing stations (18 fuel pumps). A total of 59 parking spaces would be provided, including three electric vehicle (EV) charging spaces, one vanpool EV parking space, and two future clean air parking spaces. The EV chargers would be Level 2 chargers or better. Three of the 59 parking spaces would also be designated as accessible parking spaces.
The proposed plan would be developed on a currently vacant parcel of land with a current land use designation of MU-3. The project site has a currently approved plan under the land use designation of MU-3 and is comprised of a mix of retail, medical office, general office, and residential. The approved plan proposes approximately 3,000 square feet of retail space, 17,697 square feet of medical office space, 6,000 square feet of general office space, 4,000 square feet of mixed-use office condos space, 52 covered “podium” parking spaces on the ground floor, and 73 uncovered parking spaces. A new project plan has been proposed for the project site. The MU-3 zone does not permit gas station, car wash, or food mart uses, but is instead intended for job-based mixed-use developments. Job-based mixed-use developments include commercial retail, business support services, offices, government uses, and restaurants. Therefore, the development of the proposed plan would require a General Plan Amendment (GPA) and Rezone to Commercial (C) to allow for these uses. The proposed plan is requesting a Conditional Use Permit for the gas station use, drive through restaurant, and car wash. The City of San Marcos Municipal Code states that minimum spacing be 500 feet between gas stations. Portions of the proposed gas station property are closer than 500 feet to the existing gas station on the northeast corner of Mission Boulevard and Las Posas Road. The proposed plan includes a request for a variance to these spacing requirements. Figure 1 below shows the project location.
In conjunction with the proposed plan, a GPA has been proposed (herein referred to as “proposed project”) to change the current land use designation of Mixed-Use Non-Residential (MU-3) to the proposed land use designation of Commercial (C). As part of any GPA application, the City of San Marcos (City) requires the preparation of an Impact Analysis to examine the consistency of the requested land use change in relation to surrounding land uses, available infrastructure, and economic conditions. More specifically, this General Plan Impact Analysis consists of the following components:
▪ Public Benefits Analysis
Analysis of the potential for added sales tax revenue and the new employment opportunities that are associated with the proposed land use designation to result in public benefits.
▪ Land Use Analysis
Analysis of surrounding land uses and impact that proposed land use change will have on the land use pattern.
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200 North Las Posas Road Project
2 ▪ Infrastructure and Community Services Impact Analysis Impact of the proposed project on public services and utilities, including water, sewer, telecommunications, schools, fire, police, and outdoor/recreational facilities.
Each of these components will seek to analyze the impacts of converting the current MU-3land use designation to the proposed C land use designation. Thorough analysis of General Plan Impact Analysis
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Figure 1 Project Location
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4 the City’s current General Plan goals, policies, and Guiding Themes will be conducted along with an analysis of surrounding land uses and the overall public benefit and impact of the project.
1.2 Public Benefits Analysis
To help identify both the qualitative public benefit and the quantitative fiscal benefit for the proposed project, a Fiscal Impact Analysis (FIA) report and an Economic Impact Report (EIR) were conducted by Finance DTA in June 2022. The studies looked at factors such as persons served, job creation, total output, recurring revenue, recurring costs, total net fiscal impact, and overall market considerations. All of these factors were analyzed under the approved plan as well as the proposed plan associated with the proposed change in land use designation from MU-3 to Commercial (C).
The fiscal impacts for the currently approved plan and the proposed plan in conjunction with the land use change are discussed below.
Qualitative Benefit
The currently approved plan proposes a three-story mixed-use structure comprised of retail, medical office, general office, and condo development. The approved project poses public benefits such as additional retail amenities, additional housing for San Marcos, and important services such as medical. However, the approved plan poses challenges to development for the designated parcel.
The FIA identified the following challenges associated with the approved plan for the project parcel:
▪ Three-story mixed-use podium commercial with offices above ground floor retail and underground parking is generally not supported in suburban areas such as the City of San Marcos;
▪ Underground parking garages similar to the one originally planned are prohibitively expensive for commercial developments in locations similar to the project location; ▪ Lack of amenities for daytime population occupying office, medical, and retail spaces; ▪ General office uses suffered during the COVID-19 pandemic and is not recovering at the rate of other commercial sectors;
▪ Medical office buildings are in higher demand in areas adjacent to a hospital or full-scale medical center; and
▪ Coworking office condos are achieving very high rents around Cal State San Marcos but not as high in the location of the project parcel.
Because of both expected and unexpected changes in the market, the challenges associated with the approved plan may continue to pose large barriers to development on the project parcel. In contrast, the proposed plan poses several public benefits that may make development for the project parcel more feasible than previous identified project plans. The FIA identified some of the primary long-term public benefits associated with the proposed plan which include:
▪ The car-friendly retail infrastructure will help to activate the corner of North Las Posas and West Mission Boulevard, bringing conveniences and services to an area which is historically industrial; ▪ The proposed use will tie in with the CVS across Mission Boulevard from the project site, as well as with the plans to rezone and commercialize the parcel behind the CVS; ▪ Palomar Station and Marc San Marcos, two multi-family developments near the site, contain 786 households that may have a need for drive-thru convenience retail services and gas station; and
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▪ Palomar College Transit Parking, which is located one block to the east of the project, generates park and ride traffic in need of gas and related conveniences such as the car wash and drive- thru associated with the proposed project.
The proposed plan would accommodate for uses that could provide benefits and services that the community has a specific need for. Changing the land use designation from MU-3 to Commercial (C) would promote development that is potentially more feasible for the location of the project parcel and would change permitted uses to uses that predominantly cater to both residents and visitors.
Quantitative Analysis
Quantitative impacts associated with changing the land use designation from MU-3 to Commercial (C) were analyzed in both the FIA and the EIR. The reports analyzed various economic outcomes associated with the currently approved plan and compared those to the same economic outcomes that could result from the proposed plan and associated land use designation change. The FIA and EIR identified areas where the proposed plan could have a smaller economic payback, including recurring total output and job creation. These economic factors were lower for the proposed plan due to a decrease in the number of development types in the proposed plan compared to the currently approved plan. Furthermore, the proposed plan in conjunction with the land use designation change would be less dense than the currently approved plan resulting in a lower number of overall businesses present on the project parcel. Thus, due to decreases in the development types and in the number of businesses, the proposed plan would result in less job creation compared to the currently approved plan.
Though the currently approved project would yield larger economic benefits in certain areas, the FIA and EIR identified long term economic benefits resulting from the proposed project, including a large increase in overall revenue and total economic output for the community. Changing the current land use designation from MU-3 to Commercial (C) to accommodate the proposed plan would bring long term beneficial fiscal impacts including a large increase in commercial tax revenue.
Table 1 above shows a comparison of the recurring fiscal revenues between the currently approved plan and the proposed plan associated with the change in the parcels land use designation. Under the proposed plan, annual incremental recurring revenues total $79,864. As illustrated below in Table 1, the proposed plan would increase every tax category. Most notably, the proposed plan would result in an estimated $47,056 per year from direct and indirect sales tax compared to $12,008 from direct and indirect sales tax associated with the currently approved plan. This is due to the types of development and uses on the project parcel that could be accommodated by the proposed land use designation change. The types of development allowed by the land use designation change would generate a consistent stream of business and allow uses that tend to show lower vacancy rates than some of the uses identified in the currently approved plan, although the currently approved plan includes a more diversified set of uses.
Table 1 Recurring Fiscal Revenues (City General Fund)
Revenue Category
Approved Plan Proposed Plan
Amount Percent Amount Percent
Secured Property Tax $16,294 38.3% $20,788 26.0%
Unsecured Property Tax $1,629 3.8% $2,079 2.6%
Property Transfer Tax $296 0.7% $377 0.5%
Property In-Lieu of Vehicle License Fee $6,941 16.3% $8,926 11.2% A & S Engineering
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6 Direct and Indirect Sales Tax $12,008 28.2% $47,056 58.9% Franchise Fees $1,534 3.6% $146 0.2%
Licenses and Permits $486 1.1% $46 0.1%
Fines and Forfeitures $112 0.3% $11 0.0%
CFD Revenue $3,251 7.6% $434 0.5%
Total Revenues $42,551 100.0% $79,864 100.0%
Table 1 above shows a comparison of the recurring fiscal costs anticipated by the currently approved plan and the proposed plan. As illustrated in Table 2, the proposed plan would result in a substantial reduction in costs in all categories compared to the currently approved plan. Reduced fiscal costs can be attributed to a number of factors, including reduced occupancy and an overall reduction in services and utilities that are needed to support the proposed plan.
Table 2 Recurring Fiscal Costs (City General Fund)
Categories
Approved Plan Proposed Plan
Amount Percent Amount Percent
Public Works $3,786 15.9% $341 15.9%
Department Services $1,197 5.0% $114 5.0%
Public Safety $12,773 53.7% $1,217 53.8%
Parks and Recreation $267 1.1% $25 1.1%
Other Financing Sources $0 0.0% $0 0.0%
General Government $5,743 24.2% $547 24.2%
Total Revenues $23,766 100.0% $2,264 100.0%
Table 2 above shows a comparison of the annual net fiscal impact for the currently approved project and the proposed plan with land use designation changes. As Table 3 below illustrates, the total recurring general fund revenues increase substantially between the approved plan and the proposed plan while total recurring expenditures (costs) decrease. Thus, the proposed plan would result in a substantial increase in the net fiscal impact compared to the currently approved plan.
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Table 3 Annual Net Fiscal Impact (City General Fund)
Fiscal Impact Approved Plan Proposed Plan
Total Recurring General Fund Revenues $42,551 $79,864
Total Recurring General Fund Expenditures ($23,766) ($2,264) Net Fiscal Impact $18,785 $77,600
Revenue to Expense Ratio 1.79 35.28
1.3 Land Use Analysis
The Land Use Analysis provides an overview of the project’s consistency with the City’s General Plan including the goals and policies outlined in the Land Use and Community Design Element. Project consistency with the City’s Guiding Themes laid out in the General Plan are discussed below along with an analysis of the surrounding community character benefits of changing the land use designation from MU-3 to Commercial (C) and the project being proposed in conjunction with the land use designation change.
Consistency with San Marcos General Plan Goals and Policies Table 4 below illustrates the project ’s consistency and applicability to the goals and policies outlined in the Land Use and Community Design Element. The analysis demonstrates that the proposed project would be consistent with the City General Plan Land Use and Community Design Element.
Table 4 Consistency of Land Use and Community Design General Plan Goals Applicable City General Plan Goals and Policies Project Consistency Goal LU-1: Achieve a balanced distribution and compatible mix of land uses to meet the present and future needs of all residents and the business community.
Policy LU-1.1: Ensure that adjacent land uses
complement one another by considering
compatibility of activities, development patterns
and architectural character elements and access
to various mobility choices
Consistent. The proposed project would align with surrounding land uses that are primarily designated as Commercial (C), Industrial (I), Specific Plan Area (SPA), and/or Public/Institutional (PI), and includes both sit-down and fast-food restaurants, autobody repair shops, pharmacies, gas stations, various types of retail stores, and Palomar College. Commercial development built under the proposed land use designation would align with surrounding development patterns and architectural character, and any future commercial development would be required to follow the City’s design guidelines. Furthermore, development occurring in the C land use designation would be built at a lower density (a maximum FAR of 0.70) than would occur under the MU- 3 land use designation (1.50 FAR)
Policy LU-1.2: Promote commercial uses that
provide a solid economic base and employment
opportunities.
Consistent. The proposed project would amend the current land use designation of MU-3 to a Commercial (C) designation. The project would expand commercial opportunities in the City and would further generate new employment opportunities for the City’s labor pool.
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8 Applicable City General Plan Goals and Policies Project Consistency Policy LU 1.3: Diversify land uses by providing
mixed use land uses in strategic locations within
the City that place housing adjacent to
employment.
Consistent. The proposed project l would redesignate the current land use designation to Commercial (C) in an area with a variety of land uses such as commercial, Industrial (I), Specific Plan Area (SPA), and Public/Institutional (PI). Residential development is located approximately 0.15 miles north of the project site. The proposed project would provide additional commercial and employment opportunities for nearby residents in the nearby neighborhood.
Goal LU-2: Promote development standards and land use patterns that encourage long-term environmental sustainability.
Policy LU-2.3: Require the incorporation of green
building practices, technologies, and strategies
into development projects per code standards.
Consistent. The proposed project would redesignate the current land use to a commercial designation which has a specific set of green building requirements under CALGreen. Project specific development under the land use designation Commercial (C) would be required to comply with the commercial development requirements under the latest CALGreen development standards.
Policy LU-2.5: Promote landscaping (e.g., native,
drought tolerant plants) that minimizes demands
on water supply.
Consistent. The proposed project would change the current land use designation to Commercial (C) which has a specific set of green building requirements under CALGreen. Project specific
development under a commercial land use designation would be required to comply with the mandatory Model Water Efficiency Landscape Ordinance (MWELO) contained with Chapter 2.7, Division 2, Title 23, California Code of Regulations. The MWELO sets forth requirements that aim to reduce overall water usage through the implementation of landscaping and other various methods.
Policy LU-2.7: Promote the instillation of trees to
reduce the urban heat-island effect and green
infrastructure to reduce storm water runoff.
Consistent. The proposed project would amend the current land use designation of MU-3 to Commercial (C). Project specific development under the land use designation of Commercial (C) would be required to comply with CALGreen’s commercial
development requirements regarding shading and tree
implementation in both landscape and hardscape areas.
Goal LU-3: Develop land use patterns that are compatible with and support a variety of mobility opportunities and choices.
Policy LU-3.1: Require that new development and
redevelopment incorporate connections and
reduce barriers between neighborhoods, transit
corridors, and activity centers within the City.
Consistent. The proposed project would change the current land use to a Commercial (C) designation. The project site is located in an area with both residential development and transit corridors nearby. As stated previously, residential development is located approximately 0.15 miles north of the project site. Additionally, the project area is located 0.25 miles east of State Route (SR) 78. The proposed project would expand commercial services in this area, thus reducing barriers between new development and residential neighborhoods and transit corridors.
Policy LU-3.2: Promote street-oriented
development, within mixed-use areas with
parking located behind or next to buildings rather
than in front. Encourage commercial activities
such as wide sidewalks and outdoor dining.
Consistent. The proposed project would change the current land use designation from MU-3 to Commercial (C).The proposed project would promote and expand commercial activities in the project site as it would be re-designated to enable a variety of commercial land uses.
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Applicable City General Plan Goals and Policies Project Consistency Policy LU-3.7: Require new development to
prepare traffic demand management programs.
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial (C). The project site is currently vacant and undeveloped. Project specific development under the proposed land use designation would be required to undergo environmental review and would be further analyzed to identify potential transportation impacts. Mitigation measures would be implemented if deemed potentially significant.
Policy LU-3.8: Review SANDAG’s Regional
Transportation Plan/ Sustainable Communities
Strategy each time the City reviews and updates
its General Plan and any specific plan, strategy,
and zoning, to ensure overall consistency among
all of these plans and strategies and allow for
associated CEQA streamlining and eligibility for
State transportation funding.
Consistent. The proposed project would amend the current land use designation of MU-3 to Commercial (C). The proposed project would require a reevaluation of any applicable local and regional plans, policies, and strategies as the project entails a General Plan Amendment. Project specific development under the proposed land use designation would be required to undergo environmental review and would be further analyzed to identify potential impacts to state, regional, and local policies, programs, and plans.
Goal LU-4: Promote San Marcos as the education center of North County while creating a greater synergy between the business community and its academic institutions.
* Note: No specific policies under this goal directly apply to the project. Therefore, policies for Goal LU-4 will not be analyzed for project consistency.
Goal LU-5: Promote community design that produces a distinctive, high-quality built environment with forms and character that create memorable places and enrich community life.
Policy LU-5.2: Establish a “downtown” as a focal
point for the San Marcos community and an
attraction for North County.
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial (C). The project site is located in the Urban Core Focus Area which acts as a focal point for San Marcos. The proposed project would enable a variety of commercial land uses to be developed and would further expand opportunities for new attractions in the community.
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.
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial (C). The project site is surrounded by urban, built development. Project specific development under the proposed land use designation would be required to undergo environmental review and would be further analyzed to identify potential aesthetic impacts. Mitigation measures would be implemented if impacts are deemed
potentially significant. Additionally, future commercial development would be required to follow the City’s design guidelines and would be built in similar fashion to surrounding commercial development.
Policy LU-5.5: Encourage development of public
spaces and plazas within commercial, mixed-use,
and residential projects that include fire and
water features that can accommodate civic
events and function as community gathering
areas.
Consistent. The proposed project would change the current land use designation to Commercial (C). This would enable a variety of commercial and public land uses to be developed. Accommodation of civic events and function as community gatherings are project development specific. The land use designation of Commercial (C) provides large opportunity for a variety of public functions.
Policy LU-5.7: Architecture shall be enhanced
with high-end building materials, varied roof
lines, and decorative details.
Consistent. The proposed project would amend the current land use designation of MU-3 to Commercial (C). The proposed project would enable a variety of commercial development to be built in the project site. Project specific development would be built according to the California Building Code (CBC) along with the City’s design guidelines to ensure architectural safety and design consistency with surrounding development.
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10 Applicable City General Plan Goals and Policies Project Consistency Policy LU-5.8: Ensure that automobile-oriented
businesses have pedestrian –friendly exterior
design.
Consistent. The proposed project would change the land use designation from U-3 to Commercial (C). Project specific development under the proposed land use designation would be required to comply with CALGreen’s commercial design guidelines such as bicycle parking and storage. Additionally, commercial development built would be required to comply with City design guidelines along with the City’s Municipal Code.
Goal LU-6: Maintain a supportive business climate and a healthy, sustainable economy to retain and attract high quality businesses and create additional employment opportunities.
Policy LU-6.1: Pursue a variety of funding
approaches, including grants, impact fees,
assessments, and transportation funds to support
public services, municipal programs, and capital
investments that support City businesses.
Consistent. The proposed project would change the current land use designation to Commercial (C). Project specific development under this land use designation would be required to pay City development impact fees that are used to support essential public and municipal services.
Policy LU-6.2: Encourage businesses and existing
employers to remain and expand in San Marcos.
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial (C). A commercial land use designation would generate new employment opportunities for the City and surrounding land uses, including nearby residential neighborhoods and Palomar College. Commercial land uses enable a variety of development and business types to be established, providing opportunity for a diversified and expanded workforce in the City.
Policy LU-6.4: Encourage and support the
renovation and reuse of underutilized or vacant
parcels/buildings/shopping centers.
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial (C). The project site is currently vacant and undeveloped. Any future commercial development would be directly contributing to the City’s goal of reuse by developing on underutilized and/or vacant land.
Policy LU-6.5: Support ongoing marketing efforts
that encourage job growth and attract residents
outside of the City to shop and visit San Marcos.
Consistent. The proposed project would change the current land use designation to a Commercial (C) land use designation. This would allow a variety of commercial land uses to be developed on the project site. Specific project development built under the proposed land use designation would generate a variety of employment opportunities and provides opportunities for numerous types of commercial and public spaces that may attract residents from outside of the City.
Policy LU-6.7: Promote development and
revitalization of revenue-generating land uses in
areas designated for commercial and industrial
uses that will support business and employment
growth.
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial (C). Specific project development under this designation would directly support business and employment growth as commercial land uses
provided a variety of employment opportunities for the City.
Furthermore, the project site is located in the City’s
Business/Industrial neighborhood and surrounding development primarily consists of commercial and industrial land uses. Project specific development under this designation would further expand the area’s commercial presence and its employment base.
Policy LU-6.8: Protect the sales tax base in the
commercial core and State Route 78 light
industrial corridor by limiting non-retail uses, or
offsetting lost sales tax by another beneficial
action or measure, such as an in-lieu fee for loss
of retail sales based on compatible retail uses in
the area.
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial (C). The proposed project would expand permitted commercial uses on the project site beyond what is currently permitted under the land use designation of MU-3. Thus, the proposed project would help generate an additional commercial sales tax base and would further support the existing local sales tax base in the surrounding community.
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Applicable City General Plan Goals and Policies Project Consistency Policy LU-6.9: Ensure high architectural standards
and aesthetic design quality particularly for
redevelopment along the State Route 78 corridor
and within the commercial core of the
community.
Consistent. The proposed project would change the current land use designation from MU-3 to Commercial (C). The project site is located approximately 0.25 miles east of SR 78 and is surrounded by commercial land uses. Project specific development under the proposed land use designation would be required to undergo environmental review and would be further analyzed to identify potential impacts to City aesthetics. Mitigation measures would be implemented if deemed potentially significant. Additionally, all project specific development built under the proposed land use designation would be required to comply with the City’s design guidelines and development code to ensure consistency with surrounding architecture and building design.
Goal LU-7: Direct and sustain growth and expansion in areas of San Marcos that can support a concentration of a variety of uses and are particularly suitable for multimodal transportation and infrastructure expansion and improvements.
Policy LU-7.2: Coordinate pedestrian, transit and
infrastructure upgrades with infill and
redevelopment opportunities.
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial (C). Project specific development under the proposed land use designation would be required to undergo environmental review and would be further analyzed to identify potential impacts to both transportation and utilities. Mitigation measures would be implemented if impacts are deemed potentially significant.
Goal LU-8: Ensure that existing and future development is adequately serviced by infrastructure and public services Policy LU-8.1: New development shall pay its fair
share of required improvements to public
facilities and services.
Consistent. The proposed project would change the current land use designation to Commercial (C). Project specific development built under the proposed land use designation would be required to pay development impacts fees and any additional City required fees set forth in the City’s Municipal Code.
Goal LU-9: Community Facilities: Establish and maintain community facilities that enhance the quality of life for residents in San Marcos, such as community and senior centers.
Policy LU-9.1: Expand and improve City facilities
and buildings as needed to meet the community’s
needs, based on regular monitoring and
evaluation of their condition and the needs of the
community.
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial (C). The proposed land use designation allows a variety of public and community spaces to be developed on the project site. Future development under this land use designation provides further potential to expand City facilities and buildings to meet the community’s needs.
Goal LU-10: Fire Protection, Emergency Services, and Law Enforcement: Provide effective, high-quality and responsive services.
Note: No specific policies under this goal directly apply to the project. Therefore, policies for Goal LU-10 will not be analyzed for project consistency.
Goal LU-11: Ensure all residents have access to high-quality education.
Note: No specific policies under this goal directly apply to the project. Therefore, policies for Goal LU-11 will not be analyzed for project consistency.
Goal LU-12: Libraries: Provide library resources and services that meet the needs of the community.
Note: No specific policies under this goal directly apply to the project Therefore, policies for Goal LU-12 will not be analyzed for project consistency.
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12 Applicable City General Plan Goals and Policies Project Consistency Goal LU-13: Water Service and Supply: Manage and conserve domestic water resources by reducing water usage and waste on a per capita basis, to ensure an adequate water supply for existing and future residents Policy LU-13.1: Work closely with local and
regional water providers to ensure high quality
water supplies are available for the community.
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial (C). Project specific development under the proposed land use designation would be required to undergo environmental review and would be further analyzed to identify potential impacts to both hydrological resources and utilities. Mitigation measures would be
implemented if impacts are deemed potentially significant.
Goal LU-14: Wastewater: Ensure an adequate wastewater system for existing and future development.
Policy LU-14.1: Work closely with local service
providers to ensure an adequate wastewater
system for existing and future development is in
place.
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial (C). Project specific development under the proposed land use designation would be required to undergo environmental review and would be further analyzed to identify potential impacts to hydrological resources including wastewater systems. Mitigation measures would be implemented if impacts are deemed potentially significant.
Goal LU-15: Flood Control and Storm Water Drainage Facilities: Ensure adequate flood control and storm water drainage is provided to the community
Policy LU-15.3: Avoid, to the extent possible,
development in floodplain and flood prone areas.
Consistent. The proposed project would change the current land use designation to Commercial (C). The project site is not located in a identified floodplain or flood prone area. Project specific development under the proposed land use designation would be required to undergo environmental review and would be further analyzed to identify potential impacts to both hazards/hazardous materials and hydrological resources. Mitigation measures would be implemented if impacts are deemed potentially significant.
Policy LU-15.4: Retain drainage courses in their
natural condition, to the extent possible. Consider
smaller-scale drainage improvements to protect
the environment and avoid disturbing natural
drainage courses; consider detention areas and
raised building pads.
Consistent. The proposed project would amend the current land use designation of MU-3 to Commercial (C). Project specific development under the proposed land use designation would be required to undergo environmental review and would be further analyzed to identify potential impacts to hydrological resources.
Mitigation measures would be implemented if impacts are deemed potentially significant.
Goal LU-16: Solid Waste: Reduce the amount of waste material entering regional landfills with an efficient and innovative waste management program
Policy LU-16.1: Work closely with local service
providers to ensure adequate solid waste
disposal, collection, and recycling services.
Consistent. The proposed project would change the current land use designation to a Commercial (C) designation. Project specific development under the proposed land use designation would be required to undergo environmental review and would be further analyzed to identify potential impacts to utilities including solid waste systems. Mitigation measures would be implemented if impacts are deemed potentially significant.
Goal LU-17: Utilities and Communications: Encourage provision of power and communication systems that provide reliable, effective and efficient service for San Marcos.
Policy LU-17.2: Require all new development and
redevelopment to provide the technology to
support multiple telecommunications facilities
and providers such as multi-media products, wire
- less technologies, and satellite communications
Consistent. The proposed project would amend the current land use designation to Commercial (C). Project specific development under the proposed land use designation would be required to undergo environmental review and would be further analyzed to identify potential impacts to utilities including telecommunication facilities. Mitigation measures would be implemented if impacts are deemed potentially significant.
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Applicable City General Plan Goals and Policies Project Consistency Policy LU-17.3: The City shall prohibit above
ground utility equipment within any of the
pedestrian pathway and street frontage areas. All
above ground utilities shall be placed either
within; “wet closets” within the buildings,
underground vaults, or behind buildings where
they are not visible. The developer shall be
responsible to contact the applicable utility
agencies in advance to coordinate utilities prior to
approval of the final street improvement plans for
both public and private street frontages and prior
to submittal of building permits.
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial (C). Project specific development under the proposed land use designation would be required to undergo environmental review and would be further analyzed to identify potential impacts to utilities. Mitigation measures would be implemented if impacts are deemed
potentially significant.
Policy LU-17.4: Require utility location to be
shown on all site development plans at the time
of development/ project application.
Consistent. The proposed project would change the current land use designation to Commercial (C). Project specific development would be required to comply with the City’s procedural policies and submit utility plans at the time of development/project application.
Consistency with San Marcos General Plan Guiding Themes This section provides an overview of the City’s General Plan “Guiding Themes” that were enacted as part of the 2012 San Marcos General Plan. Table 5 below illustrates each “Guiding Theme” and the project ’s consistency and applicability in relation to each theme. As shown in the table, the project would be consistent with the City’s General Plan “Guiding Themes.” Table 5 Consistency of General Plan Guiding Themes
Goal Goal Language Project Consistency
Guiding Theme 1 Creating a Vibrant
Destination City
Consistent. The conversion of the land use designation from MU-3 to Commercial (C)would allow for a wide variety of commercial and public services to be developed on the project site. Providing options for commercial development and services helps contribute to the creation of a more vibrant city with a diverse range of activities and services to engage in.
Guiding Theme 2 A strong Local
Economy and
Employment Base
Consistent. The proposed project would enable a wider variety of commercial and public services to be developed and would generate diverse employment options on the project site. The project site is located in the Business/Industrial Neighborhood in the City. The City identifies this neighborhood as a primary commercial and industrial hub of the City due to the proximity of downtown and Palomar College. The development of commercial spaces on the project site would further expand the Business/Industrial Neighborhood’s commercial job sector providing opportunities for nearby residents and students that attend Palomar College.
Guiding Theme 3 Connecting People
to Places
Consistent. The conversion of the land use designation from MU-3 to Commercial (C) would permit a variety of commercial, recreational, and public gathering spaces on the project site. These uses would help expand and further connect people to surrounding places such as Palomar College, and would provide nearby residents new opportunities for shopping, services, or other commercial uses.
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14 Goal Goal Language Project Consistency
Guiding Theme 4 An Educational and
Academic Hub
Consistent. Though the conversion of the current land use designation to a Commercial (C) designation would not specifically permit educational or academic uses, the proposed land use designation would provide a variety of uses that would support students in the area. Uses such as restaurants and fast food centers, retail stores, convenience/drug stores, pharmacies, financial institutions, and other essential services would be permitted and would act as support services to students that attend Palomar College and the San Marcos Unified School District.
Guiding Theme 5 A City with Choices Consistent. The proposed project would change the site’s land use designation from MU-3 to Commercial (C). Under the proposed land use designation, a variety of commercial uses would be permitted including; general retail, markets, commercial services, restaurants, hardware, home improvements centers, financial institutions, lodging, and commercial recreation. Given the variety of permitted uses under the commercial land use designation, the project would help to expand commercial choices in the surrounding neighborhood.
Guiding Theme 6 Sustaining
Environmental
Quality
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial (C). Commercial development built under this land use designation would be required to comply with CALGreen’s commercial development requirements and standards. This includes requirements pertaining to water, energy, transportation, and overall building design. Thus, the project would expand the City’s environmental sustainability efforts through the implementation of various measures pertaining to sustainable building and design.
Guiding Theme 7 Building a Greener
Community
Consistent. The conversion of the land use designation from MU-3 to Commercial (C) would permit varied commercial development to be built on the project site. All commercial developments constructed under this land use designation would comply with CALGreen’s commercial development requirements and standards. CALGreen sets forth requirements and design guidelines that pertain to “green building” and high efficiency buildings specifically aimed towards commercial uses. Thus, the project would further the City’s green building initiative.
Guiding Theme 8 A Healthy and Safe
Community
Consistent. The proposed project would change the current land use designation of MU-3 to Commercial ©. Several commercial uses not currently allowed on the site are permitted under the Commerci©(C) land use designation that would expand the vision of a healthy and safe community, including; outdoor recreation facilities, indoor recreation facilities, and fitness/health facilities.
Guiding Theme 9 Continuing Our
Agricultural
Heritage
Consistent. ©Agricultural uses are not permitted in the Co©rcial (C) land use designation. However, the proposed land use designation change would permit a wide variety of commercial uses such as grocery markets, and farmers markets that would help continue and expand the City’s agricultural heritage and its resources.
General Plan Impact Analysis
General Plan Impact Analysis 15
Surrounding Community Character
Surrounding Land Uses
The proposed project is located in an area with surrounding development that primarily consists of Industrial, Commercial (C), Specific Plan Area (SPA), Public Institutional (PI), and Mixed-Use (MU-3) designated property. Figure 2 below shows the surrounding land uses of the project. Land uses immediately north of the project site consist primarily of commercial uses including pharmacies, sit- down and take-out restaurants, and gas stations. Palomar College is also located to the north of the site. Land uses immediately west of the project site consist of commercial and industrial uses such as various retail stores, autobody shops, and material manufacturing. Land uses immediately east of the project site consist of commercial uses such as fast-food restaurants and educational facilities associated with Palomar College. Land uses immediately south of the project site include additional commercial and industrial uses such as auto-related service centers and manufacturing facilities.
The current land use designation MU-3 allows a maximum floor area ratio (FAR) of 1.50 to accommodate higher density mixed-use developments. Development immediately surrounding the project site is lower density in nature due to the presence of commercial and industrial designated properties with FAR standards of under 1.0. The exception to this is a parcel located east of the project site that has a land use designation of Planned Industrial (PI), which carries a FAR standard of 3.0. The proposed project would enable a variety of commercial land uses to be developed with a maximum FAR of 0.70, consistent with surrounding land uses and densities.
Community Neighborhoods
The City’s General Plan identifies eight unique neighborhoods within the City. Each neighborhood consists of different land uses and development that are most appropriate for that community. The eight neighborhoods are as follows:
▪ Burnham/Discovery Community
▪ Business/Industrial District
▪ College Area Neighborhood
▪ Lake San Marcos Neighborhood
▪ Questhaven/La Costa Meadows Neighborhood
▪ Richland Neighborhood
▪ Richmar Neighborhood
▪ Twin Oaks Valley Neighborhood
The project site is located in the eastern portion of the Business/Industrial District. Surrounding neighborhoods include the Lake San Marcos Neighborhood to the south, Barhman/Discovery Community to the east, Richmar Neighborhood to the northeast, and the College Area Neighborhood to the north. The western edge of the Business/Industrial District abuts the eastern edge of the City of Vista. Within the surrounding community neighborhoods, land uses primarily include residential, commercial, industrial, and light industrial.
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16 Figure 2 Surrounding Land Uses
General Plan Impact Analysis
General Plan Impact Analysis 17
Per the City General Plan’s Land Use and Community Design Element, “the eastern half of the Business/Industrial District contains commercial land uses and industrial land uses” (City of San Marcos 2012). This vision for the Business/Industrial District would be upheld by the proposed project as it would change the current land use designation to a commercial designation of Commercial (C). The project would expand commercial services in the area, providing additional commercial opportunities to the Business/Industrial District, including Palomar College, and nearby residences. The project would ultimately align with the vision of the Business/Industrial District and surrounding neighborhoods.
Land Use Designation Change Analysis
The Land Use and Community Design Element establishes 25 land use designations. These land use designations have been established to address:
▪ Development trends affecting the City’s near- and long-term futures; ▪ Focus areas associated with major industrial uses, shopping and employment centers, and access to transportation facilities; and
▪ Community interests and desires expressed during the General Plan update process.
The City uses a land use classification system to regulate what can be built in specific locations within the City to protect the health, safety, and welfare of the community.
Existing Land Use Designation
The project site is currently designated as Mixed-Use Non-residential (MU-3). Under the City’s General Plan, MU-3 has a maximum FAR of 1.50 and integrates a blend of permitted uses that cater to both the public and private sectors. Typical uses permitted under the MU-3 designation include retail, commercial services, administrative and office uses, institutional and government uses, business support and financial uses, restaurants, and health care facilities. MU-3 is typically pedestrian oriented, and focuses retail and other active services at street level. Under the City’s Land Use Element, residential uses are not permitted under MU-3 and a Specific Plan is required for development.
Proposed Land Use Designation
The proposed project would consist of changing the land use designation ©to Commercial (C).
Under the City’s General Plan, Commercial (C) has a maximum density of 0.70 FAR. Per the Land Use and Community Design Element, typical uses under the Commercial (C) land use designation include general retail, markets, commercial services, restaurants, hardware, home improvements centers, financial institutions, lodging, and commercial recreation. Developments under this land use designation are typically one-story developments with larger massing due to a lower density of 0.70 FAR.
Analysis of Proposed Land Use Designation
The proposed plan includes the construction of a 2,000 square foot car wash bay, 1,000 square foot equipment room, a 3,800 square foot drive-thru AM-PM food mart, and a 1,000 square foot retail space, as well as a 6,192 square foot canopy to cover gas station pumps, 16,130 square feet of landscaped area, and 41 uncovered parking spots. The proposed plan is not allowed under the property’s current land use designation. Changing the current land use would enable a wider variety of commercial uses to be built on the current project site, including the uses contained in the A & S Engineering
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18 proposed project. There are several benefits to ©the proposed land use change given the proximity to City residents, students, and other commercial services. Benefits include a potential expansion of the City’s the employment base, the creation of additional connections in the community, support for nearby academic institutions, more public commercial choices, and the expansion of recreational and community gathering opportunities.
Generates Public Employment
©The expansion of commercial services would generate a new employment base in the City that could provide greater opportunity for people to work and contribute to the City’s local economy.
The FIA prepared by DTA Finance in June 2022 analyzed employment impacts under both the currently approved plan and the proposed plan in conjunction with ©the land use designation change. The FIA identified a decrease in overall job creation associated project the proposed project compared to the currently approved project. As discussed above under Section 1.1, Public Benefits Analysis, the decrease in overall job creation can be attributed to the reduction in the number of development types and the overall decrease in the number of businesses. The proposed plan would result in a large increase in tax revenues to the City compared to the approved plan, which would allow for the City to reinvest those taxes into benefits for the community, such as possible employment opportunities. In addition, as indicated under Section 1.1, there may not be the current demand to build the uses previously approved, and thus changing the land use designation to allow for a different types of commercial uses would allow for employment choices that may not occur under the approved project.
Creates New Connections
The proposed project would expand further opportunities for people to interact in additional public spaces. As stated above, MU-3 allows for both public and private uses, including administrative and office uses, institutional uses, and government uses, which in nature only cater to certain groups of people in the community. The proposed land use change would create additional commercial opportunity and encourage a larger group of residents and visitors to visit the project site, as well as other services and uses in the surrounding neighborhood.
Supports Academic Institutions
As stated previously, Palomar College is located near the project site, approximately 0.25 miles northeast. The proposed project expands the opportunity for essential public commercial uses and services to be built on the project site, including restaurants and fast food centers, retail stores, convenience/drug stores, pharmacies, financial institutions, and other essential services. These uses would act as support services to students that attend Palomar College and the San Marcos Unified School District.
The proposed plan includes a drive-thru AM-PM food mart, additional retail space, and a gas station pumps. The proposed project would support academic institutions by providing additional quick food service and gas station services for both faculty and students at nearby schools.
Expands Recreational Opportunities
The proposed project would expand permitted recreational activities that are not currently permitted under the mixed-use land use designation. However, the proposed project includes a gas station that provides fuel for vehicles, including recreational vehicles.
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General Plan Impact Analysis 19
Creates Public Choice
The current MU-3 land use designation permits institutional and government uses, administrative and office uses, and business support that in nature are oriented more towards the private sector.
The proposed change to a commercial land use designation would permit uses that predominantly cater to the general public, including visitors. Thus, a commercial land use designation would provide additional choices for people to both visit and work at. The proposed project would provide the public with additional choices in food, fueling services, and retail options, helping to add more choices in the project vicinity for both residents and visitors.
1.4 Infrastructure and Community Services Impact
Analysis
The proposed plan in conjunction with changing the land use designation from MU-3 to Commercial (C) is required to undergo environmental review under the California Environmental Quality Act (CEQA). Potential project impacts were analyzed within an Initial Study-Mitigated Negative Declaration (IS-MND) that was released for public review between October 24, 2022 and November 23, 2022. To protect the current status and ensure future capacity of public services in the surrounding community, an analysis of potential impacts on these community services is necessary.
Below is an analysis of essential community services and the potential impacts the project may have on these services.
Public Utilities
Water Services (Potable and Wastewater)
The project site is currently designated as Mixed Use Non-Residential (MU-3). A land use designation of MU-3 has a maximum FAR of 1.5 and allows a variety of land uses including retail, commercial, administrate and office, institutional and government, business support and financial, restaurants, and health care facilities. The proposed project would change the land use designation from MU-3 to Commercial (C). A land use designation of Commercial (C) in the City of San Marcos has a maximum FAR of 0.70 and allows for land uses such as general retail, markets, commercial services, restaurants, hardware, home improvement centers, financial institutions, lodging, and commercial recreation. In general, these land uses are less dense, necessitating less water and wastewater services than certain land uses that are allowed under a land use designation of MU-3.
As stated above under Surrounding Land Uses, the project would be compatible with surrounding land uses and land use designations. Therefore, commercial development built in the project site would have demands similar in nature to existing water and wastewater demands.
The City of San Marcos is serviced by the Vallecitos Water District, which provides both potable water and wastewater services. Future development would be required to comply with all policies and regulations of both the City and the Vallecitos Water District, including the Vallecitos Water District Urban Water Management Plan (UWMP). Additionally, project specific development would be required to comply with the Vallecitos Water District Water, Wastewater, and Recycled Water Master Plan to reduce impacts on wastewater capacity. The IS-MND for the proposed plan identified less than significant impacts to water quality, groundwater supplies, drainage patterns, and flooding. Impacts regarding conflicts with any water quality control or management plan were identified to have no impact.
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20 Solid Waste
The MU-3 land use designation has a maximum FAR of 1.5 to permit higher density uses. The project would change the land use designation to Commercial (C) which has a lower maximum FAR of 0.70, as commercial land uses are in nature less dense. Though dependent on the specific development project ultimately realized on the project site, the proposed land use designation change would likely generate less solid waste than what would be seen on the project site.
The City of San Marcos is serviced by EDCO Recycling and Waste Collection for solid waste. EDCO transports collected waste to the Escondido Transfer Station, where it is then transferred to the Sycamore Sanitary Landfill located in Santee. The Sycamore Landfill has a permitted capacity of 5,000 tons/day and a remaining capacity of 113,972,637 cubic yards (California Department of Resources Recycling and Recovery [CalRecycle] 2021). The IS-MND identified that the proposed plan under the land use designation change would generate an estimated 26 tons of waste per year (approximately 0.07 ton per day), which is less than 0.001 percent of the permitted daily capacity at the Sycamore Landfill. Therefore, impacts would be less than significant as the proposed plan would not generate solid waste in excess of the capacity of the Sycamore Landfill.
Telecommunications
The City of San Marcos is serviced by several telecommunications providers such as AT&T, Cox Communications, Direct TC, DISH Network, DISH Latino, Frontier Communications, and Time Warner Spectrum. The proposed land use change would have a minimal effect on telecommunication services, considering the proposed does not contain residential units and would likely not increase the reliance on telecommunication facilities. Additionally, a land use change from MU-3 to Commercial (C) would eliminate the potential for certain uses such as offices and government spaces that in nature rely heavier on telecommunication services. Commercial development built under the project would be similar in nature to surrounding commercial development and would likely not require telecommunication services uncharacteristic of other commercial developments nearby.
The IS-MND identified that the project would not involve any components requiring telecommunications infrastructure and would not involve the relocation of existing telecommunications facilities. Therefore, the would be no impact to telecommunications as a result of the proposed plan in conjunction with changing the land use designation.
Public Services
Schools
The San Marcos Unified School District (SMUSD) consists of 22 schools ranging from elementary to high school. The change in land use designation would strictly enable commercial development to be built on the project site. The additional commercial services would generate employment opportunities; primarily for local residents of San Marcos. This includes employment opportunities for high school students in the SMUSD, along with Palomar College located approximately 0.25 miles northeast of the project site. The project would not add residents to the City and would not contribute to a higher number of students in the school district and local colleges. The proposed plan would solely provide additional commercial support services as well as potential employment services for nearby educational institutions.
General Plan Impact Analysis
General Plan Impact Analysis 21
A commercial land use designation would also provide additional retail and commercial services to all nearby schools. Additional services such as restaurants and fast food centers, retail stores, convenience/drug stores, pharmacies, financial institutions, and other essential services could be enabled under the proposed land use change and would further support surrounding educational institutions. Residential development would not be permitted under this land use designation, with the exception of residential care facilities and transitional/support housing.
The proposed plan associated with changing the land use designation from MU-3 to Commercial (C) was analyzed within an IS-MND to analyze any potential impacts to the City’s school system. The San Marcos Unified School District provides facilities serving grade levels elementary through high school and adult education (San Marcos Unified School District 2021). The proposed project would involve the construction of a fuel station, convenience store, and automated car wash on a vacant lot. The proposed plan would not involve new residential development. Likewise, the project would not generate substantial numbers of new employees within the city that could lead to unanticipated population growth. Thus, the IS-MND identified no impact on the City’s school system under the proposed project.
Police
The proposed plan was analyzed within an IS-MND to analyze any potential impacts to the City’s police system. The City of San Marcos partners with the San Diego County Sheriff’s Department to provide law enforcement and police services. The nearest police station is the San Diego County Sheriff’s station located at 182 Santar Place, approximately four miles (driving distance) east from the project site. Because the proposed plan would not result in a substantial increase in population or employment in the city, the proposed project would not result in substantial changes to police response times or service ratios. However, However, since the development of this project would contribute to the incremental increase in demand for police protection services city-wide.
Therefore, the IS-MND identified a mitigation measure, which includes a community facility district fee. The IS-MND found the proposed plan to result in a less than significant impact to police services.
Fire
Fire protection services for the City are serviced by the San Marcos Fire Department. The proposed project would not permit residential uses to be built in the project site with the exception of residential care facilities and transitional/supportive housing. As such, the project would not be adding residents and directly increasing population growth in the City which would necessitate greater capacity in the City’s fire protection facilities.
The proposed plan was analyzed within an IS-MND to analyze any potential impacts to the City’s fire system. The project site is located approximately 1.6 miles west (driving distance) of the San Marcos Fire Station No. 1, which would likely be the station serving the proposed project site in an emergency. The proposed plan would develop a new fuel station, food mart, and car wash on a previously vacant site. As identified in Chapter 17.64 of the San Marcos Municipal Code, the City of San Marcos has adopted the 2019 California Fire Code and the 2015 International Fire Code. The proposed project would be built consistent with the 2019 California Fire Code and the 2015 International Fire Code. However, due to fire services being located within a Community Facilities District, the IS-MND has set forth a mitigation measure, including a Community Facilities District Fee, requiring the applicant to submit and annex to the applicable Community Facilities District or A & S Engineering
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22 pay an in-lieu fee due to the proposed new development. The IS-MND identified the proposed plan to have a less than significant impact on fire services.
Transportation
The City of San Marcos has an extensive transportation network with the General Plan identifying ten different roadway classifications and three different street typologies. The City places heavy emphasis on multi-modal transportation, as apparent by the various street, bicycle, pedestrian, bus, and rail routes located throughout the City.
The project site is located along West Mission Boulevard and North Las Posas Road. North Las Posas Road is classified as a six-lane arterial roadway with Class II or Class III bicycle facilities and sidewalks. West Mission Boulevard is classified as a four-lane arterial with enhanced bicycle/pedestrian facilities. The proposed project does not contain residential development and would not generate additional vehicular trips that can be associated with an increase in residents.
However, the Commercial (C) land use designation would likely shift commercial patterns as residents are provided with additional choices. Given the size and scope of the proposed project, these shifts would be minimal.
Impacts to transportation and traffic are highly dependent on the specific development project.
Potential impacts of the proposed plan were analyzed within an IS-. Based on the VMT analysis presented in Appendix F of CEQA, the project is screened out from a detailed VMT analysis using the screening criteria outlined in the City’s guidelines since it meets the criteria of being a locally serving retail facility with the total project land use density less than 50,000 square feet of gross floor area.
Furthermore, the proposed plan affiliated with changing the land use designation was identified in the IS-MND to have no design features that would obstruct the City’s transportation system and increase public hazards. The IS-MND identified the proposed plan to have less than a significant impact on VMT and creating new hazards. Additionally, the IS-MND identified the proposed plan having no impact on emergency access or any of the City’s transportation plans and policies.
Recreation
The City of San Marcos has approximately 290 acres of parkland consisting of 24 community parks, 13 neighborhood parks, and 3 recreation centers. Additionally, the City has an extensive trail system, with approximately 63 miles of trails for hiking, biking, running, and equestrian use. As stated previously, a land use designation change to Commercial (C) would not permit the construction and development of residential housing. Therefore, the proposed project would not add residents to the City , and would not directly increase the demand for recreational facilities.
The proposed plan was analyzed within an IS-MND. Within the City of San Marcos, there is approximately 270 acres of parkland. Because residents can easily access open space and recreational opportunities in the city and because the project would not substantially increase the number of permanent residents in the city, the project would not create unanticipated demand on city parks or cause substantial deterioration of existing parks such that new park facilities would be needed. Thus, the IS-MND identified the proposed project having no impact on recreational facilities in the City.