Item B- SP21-0003_Staff Report_Attach B-4- EIR Appx B- Air Quality and GHG — San Marcos City Council, June 27, 2023 (part 1 of 6)

Appendix B
Air Quality and Greenhouse Gas Emissions
Technical Report

Air Quality and Greenhouse Gas Emissions
Technical Report
Gran Vista Project
MARCH 2023
Prepared for:

CITY OF SAN MARCOS
1 Civic Center Drive
San Marcos, California 92069
Prepared by:

605 Third Street
Encinitas, California 92024
Contact: Adam Poll

Printed on 30% post-consumer recycled material.

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Table of Contents
SECTION PAGE NO.

Acronyms and Abbreviations ............................................................................................................................................ iii Executive Summary ........................................................................................................................................................... v 1 Introduction .......................................................................................................................................................... 1

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

1.2 Regional and Local Setting .................................................................................................................... 1

1.3 Project Description ................................................................................................................................. 1 2 Air Quality .............................................................................................................................................................. 3

2.1 Environmental Setting ............................................................................................................................ 3

2.1.1 Climate and Topography........................................................................................................... 3

2.1.2 Air Pollution Climatology ........................................................................................................... 3

2.1.3 Sensitive Receptors .................................................................................................................. 4

2.1.4 Pollutants and Effects .............................................................................................................. 4

2.2 Regulatory Setting .................................................................................................................................. 8

2.2.1 Federal....................................................................................................................................... 8

2.2.2 State .......................................................................................................................................... 8

2.2.3 Local ....................................................................................................................................... 10

2.3 Regional and Local Air Quality ............................................................................................................ 12

2.3.1 San Diego Air Basin Attainment Designation ....................................................................... 12

2.3.2 Local Ambient Air Quality ....................................................................................................... 13

2.4 Significance Criteria and Methodology .............................................................................................. 15

2.4.1 Thresholds of Significance .................................................................................................... 15

2.4.2 Approach and Methodology .................................................................................................. 16

2.5 Impact Analysis .................................................................................................................................... 21

2.6 Mitigation Measures ........................................................................................................................... 29 3 Greenhouse Gas Emissions ............................................................................................................................. 30

3.1 Environmental Setting ......................................................................................................................... 30

3.1.1 Climate Change Overview ...................................................................................................... 30

3.1.2 Greenhouse Gases and other Climate Forcing Substances ............................................... 30

3.1.3 Global Warming Potential ...................................................................................................... 32

3.1.4 Sources of Greenhouse Gas Emissions ............................................................................... 33

3.1.5 Potential Effects of Climate Change ..................................................................................... 34

3.2 Regulatory Setting ............................................................................................................................... 35

3.2.1 Federal.................................................................................................................................... 35

3.2.2 State ....................................................................................................................................... 37

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3.2.3 Local ....................................................................................................................................... 47

3.3 Significance Criteria and Methodology .............................................................................................. 49

3.3.1 Thresholds of Significance .................................................................................................... 49

3.3.2 Approach and Methodology .................................................................................................. 50

3.4 Impact Analysis .................................................................................................................................... 55

3.5 Mitigation Measures ........................................................................................................................... 71 4 References Cited ............................................................................................................................................... 73 5 List of Preparers ................................................................................................................................................ 79

APPENDICES
A CalEEMod Output Files
B Construction HRA Output Files
C Climate Action Plan Consistency Checklist
TABLES
1 Ambient Air Quality Standards ............................................................................................................................ 9 2 San Diego Air Basin Attainment Classification ................................................................................................ 13 3 Local Ambient Air Quality Data ......................................................................................................................... 14 4 San Diego Air Pollution Control District Air Quality Significance Thresholds ................................................. 15 5 Construction Scenario Parameters .................................................................................................................. 17 6 AERMOD Principal Parameters ........................................................................................................................ 18 7 Estimated Maximum Daily Construction Emissions........................................................................................ 23 8 Estimated Project Maximum Daily Operational Emissions ............................................................................. 24 9 Construction Activity Health Risk Assessment Results ................................................................................... 25 10 Greenhouse Gas Emissions Sources in California .......................................................................................... 33 11 Greenhouse Gas Emissions Sources in San Marcos ...................................................................................... 34 12 Estimated Annual Construction GHG Emissions – Proposed Project ............................................................ 57 13 Estimated Annual Operational GHG Emissions – Proposed Project .............................................................. 57 14 Relevant Greenhouse Gas-Related Laws and Regulations ............................................................................ 58

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Acronyms and Abbreviations
Acronym/Abbreviation Definition
g/m3 micrograms per cubic meter
AB Assembly Bill
APN Assessor’s Parcel Number
BAU Business as Usual
CAAQS California Ambient Air Quality Standards
CalEEMod California Emissions Estimator Model
CALGreen California Green Building Standards Code
CalRecycle California Department of Resources Recycling and Recovery Caltrans California Department of Transportation
CAP Climate Action Plan
CARB California Air Resources Board
CEC California Energy Commission
CEQA California Environmental Quality Act
CH4 methane
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
DPM diesel particulate matter
EO Executive Order
EPA U.S. Environmental Protection Agency
g/L grams per liter
GHG greenhouse gas
GWP global warming potential
HCFC hydrochlorofluorocarbon
HFC hydrofluorocarbon
IPCC Intergovernmental Panel on Climate Change
LOS level of service
mg/m3 milligrams per cubic meter
MMT million metric tons
MT metric ton
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NHTSA National Highway Traffic Safety Administration
NO nitric oxide
NO2 nitrogen dioxide
NOx oxides of nitrogen
O2 oxygen (molecular)
O3 ozone
PFC perfluorocarbon

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Acronym/Abbreviation Definition
PM10 coarse particulate matter
PM2.5 fine particulate matter
ppb parts per billion
ppm parts per million
RAQS Regional Air Quality Strategy
RPS Renewables Portfolio Standard
RTP Regional Transportation Plan
SANDAG San Diego Association of Governments
SB Senate Bill
SCS Sustainable Communities Strategy
SDAB San Diego Air Basin
SDAPCD San Diego Air Pollution Control District
SF6 sulfur hexafluoride
SIP State Implementation Plan
SOx sulfur oxides
SR- State Route
TAC toxic air contaminant
VOC volatile organic compound
ZEV Zero Emissions Vehicle
ZNE zero net energy

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Executive Summary
The Gran Vista Project (project) involves construction of up to 120 townhomes on a 7.6-acre site situated at the City of San Marcos’ (City’s) southeastern limits. The project site is located within the San Diego Air Basin (SDAB) and is subject to the guidelines and regulations of the San Diego Air Pollution Control District (SDAPCD).

Air Quality
The air quality impact analysis provides an evaluation of the potential for significant adverse impacts to the ambient air quality due to construction and operational emissions resulting from the project. Construction of the project would result in a tempo rary addition of pollutants to the local airshed caused by soil disturbance, fugitive dust emissions, and combustion pollutants from on-site construction equipment, as well as from off-site trucks hauling construction materials. The analysis concludes that the daily and annual construction emissions would not exceed SDAPCD’s significance thresholds for criteria pollutants and thus would result in a less than significant impact.

Operational emissions for the project were also found to be below SDAPCD’s significance thresholds; therefore, impacts during project operation would be less than significant. Additionally, impacts to sensitive receptors during temporary construction activities and operation of the project were determined to be less than significant. Lastly, project operation would not generate odors at levels that would cause a nuisance ; therefore, impacts would be less than significant.

Greenhouse Gas Emissions
The project’s potential effect on global climate change was evaluated, and emissions of g reenhouse gas (GHG ) were estimated based on the use of construction equipment and vehicle trips associated with construction activities, as well as operational emissions once construction phases are complete. First, t he annual project - generated GHG emissions were estimated to result in approximately 627 metric tons of carbon dioxide equivalent (MT CO 2e) per year as a result of project operations and amortized construction emissions. With a service population of 408, the project would result in 1.5 MT CO2e per person per year, which is less than the significance threshold of 2.1 MT CO 2e per person per year anticipated in the City’s Climate Action Plan (CAP) . As such, t he project was also deemed consistent with the City’s CAP.

Third, the project would be consistent with and would not conflict with the applicable GHG -reducing strategies of the state that implicate the project’s construction and operational components. The project did not have a cumulative impact on the environment when evaluated with the City’s CAP. Therefore, GHG impacts would be less than significant.

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1 Introduction

1.1 Report Purpose and Scope
The purpose of this technical report is to assess the pot ential air quality and greenhouse gas (GHG) emissions impacts associated with construction and operation of the Gran Vista Project (project). This analysis uses the significance thresholds in Appendix G of the California Environmental Quality Act (CEQA) Guidelines (14 CCR 15000 et seq.) and the emissions -based significance thresholds recommended by the San Diego Air Pollution Control District (SDAPCD) and other applicable thresholds of significance.

This introductory section provides a description of the project and the project location. Section 2, Air Quality, describes the air quality –related environmental setting, regulatory setting, existing air quality c onditions, and thresholds of significance and analysis methodology, and presents an air quality impact analysis per Appendix G of the CEQA Guidelines. Section 3, Greenhouse Gas Emissions, follows the same format as Section 2 and similarly describes the GHG emissions-related environmental setting, regulatory setting, existing climate change conditions, and thresholds of significance and analysis methodology, and presents a GHG emissions impact analysis per Appendix G of the CEQA Guidelines. Section 4, References Cited, includes a list of the references cited in this technical report. Section 5, List of Preparers, includes a list of those who prepared this technical report.

1.2 Regional and Local Setting
The site is located in the land use jurisdictions of both the City of San Marcos (City) and the County of San Diego (County); however, it is proposed to be annexed into the City of San Marcos . The site is located at the southeastern portion of the City of San Marcos, bordering the City of Escondido to the east and unincorporated County of San Diego lands to the south.

The City is located within the San Diego Air Basin (SDAB) and is under the jurisdiction of the SDAPCD. The project site is bounded by Las Posas Road along the eastern boundary, W. Mission Road along the southwest boundary, an existing CVS store to the south, and existing single -family residential development to the west/northwest. Nearby land uses in the vicinity of the project site include indus trial and commercial uses to the west on the other side of W. Mission Road, the Santa Fe Hills residential community to the north, and Palomar College approximately half a mile to the east. The project site is comprised of Assessor’s Parcel Numbers (APNs) 219-121-1500 and 219-121-1600.

1.3 Project Description
The residential component of the Project consists of 120 townhomes, a mix of 2 - and 3 -bedroom units. The project includes approximately 148,297 square feet of recreation area on -site and up to 198 squa re feet of private open space per unit. Amenities on site would include tot lots and recreational areas, a dog park, a community garden, and a landscaped pedestrian path along the Las Posas Road frontage. The project would include two points of entry: one off N. Las Posas Road, and the other off of W. Mission Road. A total of 264 parking spaces would be provided for the total residential dwelling units, including 20 guest spaces. The project site is currently zoned for Commercial (C) use with an existing Ge neral Plan designation of Commercial

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and is within the City’s General Plan Neighborhood College area. The project proposes a General Plan and Zoning Amendment to change the land use designation to Specific Plan Area (SPA).

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2 Air Quality

2.1 Environmental Setting

2.1.1 Climate and Topography
The weather of the San Diego region, as in most of Southern California, is influenced by the Pacific Ocean and its semi-permanent high-pressure systems that result in dry, warm summers and mild, occasional ly wet winters. The average summertime high temperature in the region is approximately 74°F, with highs approaching 76°F in August on average. The average wintertime low temperature is approximately 49°F, although record lows have approached 48°F in January. Average precipitation in the local area is approximately 10 inches per year, with the bulk of precipitation falling between December and March (WRCC 2017).

The topography in the San Diego region varies greatly, from beaches on the west to mo untains and desert on the east; along with local meteorology, topography influences the dispersal and movement of pollutants in the air basin.

The mountains to the east prevent dispersal of pollutants in that direction and help trap them in inversion layers.

The interaction of ocean, land, and the Pacific High Pressure Zone maintains clear skies for much of the year and influences the direction of prevailing winds (westerly to northwesterly). Local terrain is often the dominant factor inland, and winds in inland mountainous areas tend to blow through the valleys during the day and down the hills and valleys at night.

2.1.2 Air Pollution Climatology
The SDAB is one of 15 air basins that geographically divide the State of California. The SDAB is currently classified as a federal nonattainment area for ozone (O3) and a state nonattainment area for particulate matter less than or equal to 10 microns (coarse particulate matter (PM10)), particulate matter less than or equal to 2.5 microns ( fine particulate matter (PM2.5)), and O3.

The SDAB lies in the southwest corner of California and comprises the entire San Diego region, covering 4,260 square miles, and it is an area of high air pollution potential. The SDAB experiences warm summers, mild winters, infrequent ra infalls, light winds, and moderate humidity. This usually mild climatological pattern is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds.

The SDAB experiences frequent temperature inversions. Subsidence inver sions occur during the warmer months as descending air associated with the Pacific High Pressure Zone meets cool marine air. The boundary between the two layers of air creates a temperature inversion that traps pollutants. Another type of inversion, a radi ation inversion, develops on winter nights when air near the ground cools by heat radiation and the air aloft remains warm. The shallow inversion layer formed between these two air masses also can trap pollutants. As the pollutants become more concentrated in the atmosphere, photochemical reactions occur that produce O 3, commonly known as smog (CARB 2014a).

Light daytime winds, predominantly from the west, further aggravate the condition by driving air pollutants inland, toward the mountains. During the fall and winter, air quality problems are created due to carbon monoxide (CO)

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and oxides of nitrogen (NOx) emissions. CO concentrations are generally higher in the morning and late evening. In the morning, CO levels are elevated due to cold temperatures and the large number of motor vehicles traveling.

Higher CO levels during the late evenings are a result of stagnant atmospheric conditions trapping CO in the area.

Since CO is produced almost entirely from automobiles, the highest CO concentrations in the SDAB are associated with heavy traffic. Nitrogen dioxide (NO2) levels are also generally higher during fall and winter days.

Under certain cond itions, atmospheric oscillation results in the offshore transport of air from the Los Angeles region to San Diego County. This often produces high O 3 concentrations, as measured at air pollutant monitoring stations within the County. The transport of air pollutants from Los Angeles to San Diego has also occurred within the stable layer of the elevated subsidence inversion, where high levels of O3 are transported.

2.1.3 Sensitive Receptors
Some land uses are considered more sensitive to changes in air qualit y than others, depending on the population groups and the activities involved. People most likely to be affected by air pollution, as identified by the California Air Resources Board ( CARB), include children, the elderly, and people with cardiovascular and chronic respiratory diseases. Sensitive receptors include residences, schools, playgrounds, childcare centers, long-term healthcare facilities, rehabilitation centers, convalescent centers, and retirement homes. The closest existing sensitive receptors in clude single-family residents bordering the western boundary of the project site .

2.1.4 Pollutants and Effects

2.1.4.1 Criteria Air Pollutants
Criteria air pollutants are defined as pollutants for which the federal and state governments have established ambient air quality standards, or criteria, for outdoor concentrations to protect public health. The federal and state standards have been set, with an adequate margin of safety, at levels above which concentrations could be harmful to human health and welfare. These standards are designed to protect the most sensitive persons from illness or discomfort. Pollutants of concern include O 3, NO2, CO, SO2, PM10, PM2.5, and lead. These pollutants, as well as toxic air contaminants (TACs), are discussed in the following text .1 In California, sulfates, vinyl chloride, hydrogen sulfide, and visibility-reducing particles are also regulated as criteria air pollutants.

Ozone. O3 is a strong -smelling, pale blue, reactive, toxic chemical gas consisting of three oxygen atoms. It is a secondary pollutant formed in the atmosphere by a photochemical process involving the sun’s energy and O 3 precursors, such as hydro carbons and NO x. These precursors are mainly NO x and volatile organic compounds (VOCs). The maximum effects of precursor emissions on O 3 concentrations usually occur several hours after they are emitted and many miles from the source. Meteorology and terra in play major roles in O 3 formation, and ideal conditions occur during summer and early autumn, on days with low wind speeds or stagnant air, warm temperatures, and cloudless skies. O3 exists in the upper atmosphere ozone layer (stratospheric ozone) as well as at the Earth’s surface in the troposphere (ozone). O3 in the troposphere causes numerous adverse health effects; short-term exposures (lasting for a few hours) to O3 at levels typically observed in Southern California can result in

1 The descriptions of health effects for each of the criteria air pollutants associated with project construction and operations are based on the U.S. Environmental Protection Agency’s (EPA’s) “Criteria Air Pollutants” (EPA 2016a) and CARB’s “Glossary of Air Pollution Terms” (CARB 2014a).

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breathing pattern changes, reduction of breathing capacity, increased susceptibility to infections, inflammation of the lung tissue, and some immunological changes. These health problems are particularly acute in sensitive receptors such as the sick, the elderly, and young children.

Nitrogen Dioxide. NO2 is a brownish, highly reactive gas that is present in all urban atmospheres. The major mechanism for the formation of NO 2 in the atmosphere is the oxidation of the primary air pollutant nitric oxide (NO), which is a colorless , odorless gas. NO x plays a major role, together with VOCs, in the atmospheric reactions that produce O 3. NOx is formed from fuel combustion under high temperature or pressure. In addition, NOx is an important precursor to acid rain and may affect both terrestrial and aquatic ecosystems. The two major emissions sources are transportation and stationary fuel combustion sources such as electric utility and industrial boilers.

NO2 can irritate the lungs, cause bronchitis and pneumonia, and lower resistance to respiratory infections.

Carbon Monoxide. CO is a colorless, odorless gas formed by the incomplete combustion of hydrocarbon, or fossil, fuels. CO is emitted almost exclusively from motor vehicles, power plants, refineries, industrial boilers, ships, aircraft, and trains. In urban areas such as t he project location, automobile exhaust accounts for the majority of CO emissions. CO is a non -reactive air pollutant that dissipates relatively quickly; therefore, ambient CO concentrations generally follow the spatial and temporal distributions of vehicu lar traffic. CO concentrations are influenced by local meteorological conditions; primarily, wind speed, topography, and atmospheric stability. CO from motor vehicle exhaust can become locally concentrated when surface -based temperature inversions are combined with calm atmospheric conditions, a typical situation at dusk in urban areas from November to February. The highest levels of CO typically occur during the colder months of the year, when inversion conditions are more frequent. In terms of adverse hea lth effects, CO competes with oxygen, often replacing it in the blood, thus reducing the blood’s ability to transport oxygen to vital organs. The results of excess CO exposure can include dizziness, fatigue, and impairment of central nervous system functions.

Sulfur Dioxide. SO2 is a colorless, pungent gas formed primarily from incomplete combustion of sulfur -containing fossil fuels. The main sources of SO 2 are coal and oil used in power plants and industries; as such, the highest levels of SO 2 are generally found near large indu strial complexes. In recent years, SO2 concentrations have been reduced by the increasingly stringent controls placed on stationary source emissions of SO 2 and limits on the sulfur content of fuels. SO 2 is an irritant gas that attacks the throat and lungs and can cause acute respiratory symptoms and diminished lung function in children. When combined with particulate matter, SO 2 can injure lung tissue and reduce visibility and the level of sunlight. SO2 can also yellow plant leaves and erode iron and steel.

Particulate Matter. Particulate matter pollution consists of very small liquid and solid particles, which can include smoke, soot, dust, salts, acids, and metals , floating in the air . Particulate matter can form when gases emitted from industries and mot or vehicles undergo chemical reactions in the atmosphere. PM 2.5 and PM 10 represent fractions of particulate matter. PM2.5 (fine particulate matter) is roughly 1/28 the diameter of a human hair. PM2.5 results from fuel combustion (e.g., from motor vehicles and power generation and industrial facilities), residential fireplaces, and woodstoves. In addition, PM2.5 can be formed in the atmosphere from gases such as sulfur oxides (SOx), NO x, and VOCs. PM10 (respirable particulate matter, or coarse particulate ma tter), is about 1/7 the thickness of a human hair. Major sources of PM 10 include crushing or grinding operations; dust stirred up by vehicles traveling on roads; wood-burning stoves and fireplaces; dust from construction, landfills, and agriculture; wildfires and brush/waste burning; industrial sources; windblown dust from open lands; and atmospheric chemical and photochemical reactions.

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PM2.5 and PM 10 pose a greater health risk than larger -size particles. When inhaled, these tiny particles can penetrate the human respiratory system’s natural defenses and damage the respiratory tract. PM2.5 and PM10 can increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and reduce the body’s ability to fight infections. Very small particles of substances such as lead, sulfates, and nitrates can cause lung damage directly or be absorbed into the bloodstream, causing damage elsewhere in the body.

Additionally, these substances can transport adsorbed gases such as chlorides or ammonium into the lungs, also causing injury. Whereas PM10 tends to collect in the upper portion of the respiratory system, PM2.5 is so tiny that it can penetrate deeper into the lungs and damage lung tissue. Suspended particulates also damage and disc olor surfaces on which they settle, as well as producing haze and reducing regional visibility.

People with influenza, people with chronic respiratory and cardiovascular diseases, and the elderly may suffer worsening illness and premature death as a resul t of breathing particulate matter. People with bronchitis can expect aggravated symptoms from breathing in particulate matter. Children may experience a decline in lung function due to breathing in PM 10 and PM2.5. Other groups considered sensitive are smokers, people who cannot breathe well through their noses, and exercising athletes (because many breathe through their mouths).

Lead. Lead in the atmosphere occurs as particulate matter. Sources of lead include leaded gasoline; the manufacturing of batteries, paints, ink, ceramics, and ammunition; and secondary lead smelters. Prior to 1978, mobile emissions were the primary source of atmospheric lead. Between 1978 and 1987, the phaseout of leaded gasoline reduced the overall inventory of airborne lead by near ly 95%. With the phaseout of leaded gasoline, secondary lead smelters, battery recycling, and manufacturing facilities are becoming lead -emissions sources of greater concern.

Prolonged exposure to atmospheric lead poses a serious threat to human health. Health effects associated with exposure to lead include gastrointestinal disturbances, anemia, kidney disease, and in severe cases, neuromuscular and neurological dysfunction. Of particular concern are low -level lead exposures during infa ncy and childhood. Such exposures are associated with decrements in neurobehavioral performance, including intelligence quotient (IQ) performance, psychomotor performance, reaction time, and growth. Children are highly susceptible to the effects of lead.

Volatile Organic Compounds. Hydrocarbons are organic gases that are formed from hydrogen and carbon , and sometimes other elements. Hydrocarbons that contribute to formation of O3 are referred to and regulated as VOCs.

Combustion engine exhaust, oil refineri es, and fossil -fueled power plants are sources of hydrocarbons. Other sources of hydrocarbons include evaporation from petroleum fuels, solvents, dry-cleaning solutions, and paint.

The primary health effects of VOCs result from the formation of O 3 and its related health effects. High levels of VOCs in the atmosphere can interfere with oxygen intake by reducing the amount of available oxygen through displacement. Carcinogenic forms of hydrocarbons, such as benzene, are considered TACs. There are no separate health standards for VOCs as a group.

2.1.4.2 Non-Criteria Air Pollutants
Toxic Air Contaminants. A substance is considered toxic if it has the potential to cause adverse health effects in humans, including increasing the risk of cancer upon exposure, or acute and/or chronic noncancer health effects.

A toxic substance released into the air is considered a TAC. TACs are identified by federal and state agencies based on a review of availab le scientific evidence. In the S tate of California, TACs are identified through a two -

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step process that was established in 1983 under the Toxic Air Contaminant Identification and Control Act. This two-step process of risk identification and risk management and reduction was designed to protect residents from the health effects of toxic substances in the air. In addition, the California Air Toxics “Hot Spots” Information and Assessment Act, Assembly Bill (AB) 2588, was enacted by the legislature in 1987 to address public concern over the release of TACs into the atmosphere. The law requires facilities emitting toxic substances to provide local air pollution control districts with information that will allow an assessment of the air toxics problem, identification of air toxics emissions sources, location of resulting hotspots, no tification of the public exposed to significant risk, and development of effective strategies to reduce potential risks to the public over 5 years.

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

The California Air Resources Board (CARB) classified “particulate emissions from diesel-fueled engines” (i.e., diesel particulate matter (DPM)) as a TAC in August 1998. DPM is part of a complex mixture that makes up diesel exhaust.

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

Valley Fever. Coccidioidomycosis, more commonly known as “Valley Fever,” is an infection caused by inhalation of the spores of the Coccidioides immitis fungus, which grows in the soils of the southwestern United States. When fungal spores are present, any activity that disturbs the soil, such as digging, grading , or other earth -moving operations, can cause th e spores to become airborne and thereby increase the risk of exposure. The ecologic factors that appear to be most conducive to survival and replication of the spores are high summer temperatures, mild winters, sparse rainfall, and alkaline sandy soils.

Valley Fever is not considered highly endemic to San Diego. Per the San Diego County Health and Human Services Agency, the 10-year average (2008–2017) for Coccidioidomycosis cases in the County of San Diego is 4.5 cases per 100,000 people per year. The project area is wholly contained within the 92069 zip code. For the 92069 zip code, there were 16 cases of Coccidioidomycosis between 2008 and 2017, which is equivalent to a rate of 3.4 cases per 100,000 people (Nelson 2018). Statewide incidences in 2016 were 13.7 per 100,000 people (CDPH 2017).

Even if present at a site, earth-moving activities may not result in increased incidence of Valley Fever. Propagation of Coccidioides immitis is dependent on climatic conditions, with the potential for growth and surface exposure highest following early seasonal rains and long dry spells. Coccidioides immitis spores can be released when filaments are disturbed by earth -moving activities, although receptors must be exposed to and inhale the spores to be at increased risk of developing Valley Fever. Moreover, exposure to Coccidioides immitis does not guarantee that an individual will become ill —approximately 60% of people exposed to the fungal spores are asymptomatic and show no signs of an infection (USGS 2000).

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2.2 Regulatory Setting

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

The NAAQS describe acceptable air quality conditions designed to protect the health and welfare of the citizens of the nation. The NAAQS (other than for O 3, NO 2, SO 2, PM 10, PM 2.5, and those based on annual averages or arithmetic mean) are not to be ex ceeded more than once per year. NAAQS for O 3, NO2, SO2, PM10, and PM2.5 are based on statistical calculations over 1 - to 3-year periods, depending on the pollutant. The Clean Air Act requires the U.S. Environmental Protection Agency ( EPA) to reassess the N AAQS at least every 5 years to determine whether adopted standards are adequate to protect public health based on current scientific evidence. States with areas that exceed the NAAQS must prepare a state implementation plan that demonstrates how those areas will attain the standards within mandated time frames.

2.2.2 State
The federal Clean Air Act delegates the regulation of air pollution control and the enforcement of the NAAQS to the states. In California, the task of air quality management and regulatio n has been legislatively granted to CARB, with subsidiary responsibilities assigned to air quality management districts and air pollution control districts at the regional and county levels. CARB, which became part of the California Environmental Protectio n Agency in 1991, is responsible for ensuring implementation of the California Clean Air Act of 1988, responding to the federal Clean Air Act, and regulating emissions from motor vehicles and consumer products.

CARB has established California ambient air quality standards (CAAQS), which are generally more restrictive than the NAAQS. The CAAQS describe adverse conditions; that is, pollution levels must be below these standards before a basin can attain the standard. Air quality is considered “in attainment” if pollutant levels are continuously below the CAAQS and violate the standards no more than once each year. The CAAQS for O3, CO, SO2 (1-hour and 24 -hour), NO 2, PM 10, and PM 2.5 and visibility -reducing particles are values that are not to be exceeded. All others are not to be equaled or exceeded. The NAAQS and CAAQS are presented in Table 1.

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Table 1. Ambient Air Quality Standards
Pollutant Averaging Time
CAAQS a NAAQS b
Concentration c Primary c,d Secondary c,e
O3 1 hour 0.09 ppm (180 g/m3) — Same as primary
standardf 8 hours 0.070 ppm (137 g/m3) 0.070 ppm (137 g/m3)f NO2g 1 hour 0.18 ppm (339 g/m3) 0.100 ppm (188 g/m3) Same as primary standard Annual arithmetic
mean

0.030 ppm (57 g/m3) 0.053 ppm (100 g/m3)
CO 1 hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3) None
8 hours 9.0 ppm (10 mg/m3) 9 ppm (10 mg/m3)
SO2h 1 hour 0.25 ppm (655 g/m3) 0.075 ppm (196 g/m3) — 3 hours — — 0.5 ppm (1,300
g/m3)
24 hours 0.04 ppm (105 g/m3) 0.14 ppm (for certain
areas)g
—
Annual — 0.030 ppm (for certain
areas)g
—
PM10i 24 hours 50 g/m3 150 g/m3 Same as primary
standard Annual arithmetic
mean
20 g/m3 —
PM2.5i 24 hours — 35 g/m3 Same as primary
standard
Annual arithmetic
mean
12 g/m3 12.0 g/m3 15.0 g/m3
Leadj,k 30-day average 1.5 g/m3 — —
Calendar quarter — 1.5 g/m3 (for certain
areas)k
Same as primary
standard
Rolling 3-month
average
— 0.15 g/m3
Hydrogen
sulfide
1 hour 0.03 ppm (42 µg/m3) — —
Vinyl
chloridej
24 hours 0.01 ppm (26 µg/m3) — —
Sulfates 24- hours 25 µg/m3 — —
Visibility
reducing
particles
8 hour (10:00 a.m.
to 6:00 p.m. PST)
Insufficient amount to
produce an extinction
coefficient of 0.23 per
kilometer due to particles
when the relative
humidity is less than 70%
— —
Source: CARB 2016a.

Notes: CAAQS = California Ambient Air Quality Standards; NAAQS = National Ambient Air Quality Standards; O3 = ozone; ppm = parts per million by volume; g/m3 = micrograms per cubic meter; NO2 = nitrogen dioxide; CO = carbon monoxide; mg/m3= milligrams per cubic meter; SO2 = sulfur dioxide; PM10 = coarse particulate matter; PM2.5 = fine particulate matter. a California standards for O 3, CO, SO 2 (1-hour and 24 -hour), NO 2, suspended particulate m atter—PM10, PM 2.5, and visibility - reducing particles, are values that are not to be exceeded. All others are not to be equaled or exceeded. CAAQS are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.

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b National standards (other than O 3, NO 2, SO 2, particulate matter, and those based on annual averages or annual arithmetic mean) are not to be exceeded more than once a year. The O 3 standard is attained when the fourth-highest 8-hour concentration measured at each site in a year, averaged over 3 years, is equal to or less than the standard. For PM 10, the 24-hour standard is attained when the expected number of days per calendar year with a 24 -hour average concentration above 150 µg/m3 is equal to or less than 1. For PM2.5, the 24-hour standard is attained when 98% of the daily concentrations, averaged over 3 years, are equal to or less than the standard.
c Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.
d National primary standards: the levels of air quality necessary, with an adequate margin of safety to protect the public health. e National secondary standards: the levels of air quality necessary to protect th e public welfare from any known or anticipated adverse effects of a pollutant.
f On October 1, 2015, the primary and secondary NAAQS for O3 were lowered from 0.075 ppm to 0.070 ppm. g To attain the 1 -hour national standard, the 3 -year average of the annual 98th percentile of the 1 -hour daily maximum concentrations at each site must not exceed 100 parts per billion (ppb). Note that the national 1-hour standard is in units of ppb.

California standards are in units of ppm. To directly compare the national 1-hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm. h On June 2, 2010, a new 1 -hour SO 2 standard was established and the existing 24 -hour and annual p rimary standards were revoked. To attain the 1 -hour national standard, the 3 -year average of the annual 99th percentile of the 1 -hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until 1 year after an area is designated for the 2010 standard, except that in areas designated nonattainment of the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved. i On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 g/m3 to 12.0 g/m3. The existing national 24-hour PM2.5 standards (primary and secondary) were retained at 35 g/m3, as was the annual secondary standard of 15 μg/m3. The existing 24-hour PM10 standards (primary and secondary) of 150 g/m3 also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years. j CARB has identified lead and vinyl chloride as TACs with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants. k The national standard for lead was revised on October 15, 2008, to a rolling 3 -month average. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until 1 year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.

2.2.3 Local
San Diego Air Pollution Control District
Although CARB is responsible for the regulation of mobile emission sources within the state, local air quality management districts and air pollution control district s are responsible for enforcing standards and regulating stationary sources. The project is located within the SDAB and is subject to SDAPCD guidelines and regulations. In San Diego County, O 3 and particulate matter are the pollutants of main concern, because exceedances of the CAAQS for those pollutants are experienced here in most years. For this reason, the SDAB has been designated as a nonattainment area for the state PM 10, PM 2.5, and O 3 (1-hour and 8 -hour) standards. The SDAB is also designated as a federal O3 marginal nonattainment area for the 2008 8-hour NAAQS for O3.

SDAPCD and the San Diego Association of Governments (SANDAG) are responsible for developing and implementing the clean air plan for attainment and maintenance of the ambient air quality standards in the SDAB. The Regional Air Quality Strategy (RAQS) for the SDAB was initially adopted in 1991, and is updated every 3 years (most recently in 2016). The RAQS outlines SDAPCD’s plans and control measures designed to attain the CAAQS for O3. The RAQS relies on information from CARB and SANDAG, including m obile and area source emissions, as well as information regarding projected growth in San Diego County and the cities in the County, to project future emissions and then determine from that the strategies necessary for the reduction of emissions through regulatory controls. CARB mobile source emission projections and SANDAG growth projections are based

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on population, vehicle trends, and land use plans developed by the County and the cities in the County as part of the development of their general plans.

The 8-Hour Ozone Attainment Plan for San Diego County indicates that local controls and state programs would allow the region to reach attainment of the federal 8 -hour O 3 standard by 20 18 (SDAPCD 2016). In this plan, SDAPCD relies on the RAQS to demonstrate how the region will comply with the federal O 3 standard. The RAQS details how the region will manage and reduce O 3 precursors (NO x and VOCs) by identifying measures and regulations intended to reduce these contaminants. The control measures identified in the RAQS generally focus on stationary sources; however, the emissions inventories and projections in the RAQS address all potential sources, including those under the authority of CARB and EPA. Incentive programs for reduction of emissions from heavy-duty diesel vehicles, off -road equipment, and school buses are also established in the RAQS. In response to court decisions, some elements in the 8-hour Ozone Attainment Plan for San Diego County required updates. CARB staff prepared the 2018 Updates to the California State Implementation Plan to update SIP elements for nonattainment areas throughout the state as needed. The applicable attainment date for San Diego County is in 2032.

In December 2005, SDAPCD prepared a report titled “Measures to Redu ce Particulate Matter in San Diego County” to address implementation of Senate Bill (SB) 656 in San Diego County (SB 656 required additional controls to reduce ambient concentrations of PM 10 and PM 2.5). In the report, SDAPCD evaluates the implementation of source-control measures that would reduce particulate matter emissions associated with residential wood combustion.

As stated previously, SDAPCD is responsible for planning, implement ing, and enforcing federal and state ambient standards in the SDAB. The following rules and regulations would apply to the project:
▪ SDAPCD Regulation II: Permits; Rule 20.2: New Source Review Non -Major Stationary Sources. Requires new or modified stationary source units (that are not major stationary sources) with the potenti al to emit 10 pounds per day or more of VOC, NO x, SO x, or PM 10 to be equipped with best available control technology (BACT). For those units with a potential to emit above Air Quality Impact Assessments Trigger Levels, the units must demonstrate that such emissions would not violate or interfere with the attainment of any national air quality standard (SDAPCD 1998).
▪ SDAPCD Regulation IV: Prohibitions; Rule 50: Visible Emissions. Prohibits discharge into the atmosphere from any single source of emissions whatsoever any air contaminant for a period or periods aggregating more than 3 minutes in any period of 60 consecutive minutes that is darker in shade than that designated as Number 1 on the Ringelmann Chart, as published by the United States Bureau of Mines, or of such opacity as to obscure an observer’s view to a degree greater than does smoke of a shade designated as Number 1 on the Ringelmann Chart (SDAPCD 1997). ▪ SDAPCD Regulation IV: Prohibitions; Rule 51: Nuisance. Prohibits the discharge, from any source, of such quantities of air contaminants or other materials that cause or have a tendency to cause injury, detriment, nuisance, annoyance to people and/or the public, or damage to any business or property (SDAPCD 1976).
▪ SDAPCD Regulation IV: Prohibitions; Rule 55: Fugitive Dust. Regulates fugitive dust emissions from any commercial construction or demolition activity capable of generating fugitive dust emissions, including active operations, open storage piles, and inactive disturbed areas, a s well as track -out and carry -out onto paved roads beyond a project site (SDAPCD 2009).

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▪ SDAPCD Regulation IV: Prohibitions; Rule 67.0.1: Architectural Coatings. Requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC content of various coating categories (SDAPCD 2015.

City of San Marcos
The City’s General Plan (City of San Marcos 2013a) includes various policies re lated to reducing Air Quality and GHG emissions. Applicable policies include the following:

Land Use and Community Design Element
Policy LU-2.1: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use.

Policy LU-3.1: Require that new development and redevelopment incorporate connections and reduce barriers between neighborhoods, transit corridors, and activity centers within the City.

Mobility Element
Policy M-2.1: Work with new development to design roadways that minimize traffic volumes and/or speed, as appropriate within residential neighborhoods; while maintaining the City’s desire to provide connectivity on the roadway network (City of San Marcos 2013a).

2.3 Regional and Local Air Quality

2.3.1 San Diego Air Basin Attainment Designation
Pursuant to the 1990 Clean Air Act amendments, EPA classifies air basins (or portions thereof) as “attainment” or “nonattainment” for each criteria air pollutant, based on whether the NAAQS have been achieved. Generally, if the recorded concentrations of a pollutant are lower than the standard, the area is classified as “attainment” for that pollutant. If an area exceeds the standard, the area is classified as “nonattainment” for that pollutant. As previously discussed, these standards are set by EPA or CARB for the maximum level of a given a ir pollutant that can exist in the outdoor air without unacceptable effects on human health or the public welfare. If there is not enough data available to determine whether the standard is exceeded in an area, the area is designated as “unclassified” or “unclassifiable.” The designation of “unclassifiable/attainment” means that the area meets the standard or is expected to meet the standard despite a lack of monitoring data. Areas that achieve the standards after a nonattainment designation are re -designated as maintenanc e areas and must have approved maintenance plans to ensure continued attainment of the standards. The California Clean Air Act, like its federal counterpart, call s for the designation of areas as “attainment” or “nonattainment,” but based on the CAAQS rather than the NAAQS. The attainment classifications for the criteria pollutants are outlined in Table 2.

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Table 2. San Diego Air Basin Attainment Classification
Pollutant Federal Designation State Designation
O3 (1-hour) Attainmenta Nonattainment
O3 (8-hour – 1997)
(8-hour – 2008)
Attainment (maintenance)
Nonattainment (moderate)
Nonattainment
NO2 Unclassifiable/attainment Attainment
CO Attainment (maintenance) Attainment
SO2 Not designatedb Attainment
PM10 Unclassifiable/attainment Nonattainment
PM2.5 Unclassifiable/attainment Nonattainment
Lead Unclassifiable/attainment Attainment
Sulfates No federal standard Attainment
Hydrogen sulfide No federal standard Unclassified
Visibility-reducing particles No federal standard Unclassified Vinyl chloride No federal standard No designation
Sources: EPA 2022b (federal); CARB 2022a (state).

Notes: O3 = ozone; NO2 = nitrogen dioxide; CO = carbon monoxide; SO2 = sulfur dioxide; PM 10 = coarse particulate matter; PM 2.5 = fine particulate matter.

Attainment = meets the standards; attainment/maintenance = achieve the standards after a non attainment designation ; nonattainment = does not meet the standards; unclassified or unclassifiable = insufficient data to classify; unclassifiable/attainment = meets the standard or is expected to be meet the standard despite a lack of monitoring data. a The federal 1-hour standard of 0.12 ppm was in effect from 1979 through June 15, 2005. The revoked standard is referenced here because it was employed for such a long period and because this benchmark is addressed in State Implementation Plans (SIPs). b Federal designations for SO2 are on hold by EPA; EPA expects to make the designations by December 2017 (EPA 2016c).

In summary, the SDAB is designated as a nonattainment area for the 2008 8 -hour O 3 NAAQS. The SDAB is designated as a nonattainment area for O3, PM10, and PM 2.5 CAAQS. The portion of the SDAB where the project site is located is designated as attainment or unclassifiable/unclassified for all other criteria pollutants under the NAAQS and CAAQS.

2.3.2 Local Ambient Air Quality
As mentioned above, t he SDAPCD operates a network of ambient air monitoring stations throughout San Diego County that measure ambient concentrations of pollutants and determine whether the ambient air quality meets the CAAQS and the NAAQS. The SDAPCD monitors air quality conditions at 11 locations throughout the SDAB. Camp Pendleton monitoring station is the closest to the project site for O 3 and NO2. The Escondido – East Valley Parkway monitoring station ceased to colle ct data post -2015; thus, due to proximity to the site and similar geographic and climactic characteristics, the San Diego – 11403 Rancho Carmel Drive monitoring station concentrations are considered most representative for the project site. Data at this st ation also was available for CO. The El Cajon – 609 S 1st Street monitoring station was used for SO 2, PM10, and PM2.5. Ambient concentrations of pollutants from 201 8 through 20 20 are presented in Table 3. Air quality within the project region was in compli ance with the CAAQS and NAAQS for NO 2, CO, SO 2, and PM 10 (NAAQS only) during this monitoring period .

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Table 3. Local Ambient Air Quality Data
Averaging Time Unit
Agency/
Method
Ambient
Air
Quality
Standard
Measured Concentration
by Year Exceedances by Yea r
201 8 2019 2020 2018 2019 2020
Ozone (O 3) – Camp Pendleton
Maximum 1-hour
concentration
ppm State 0.12 0.084 0.075 0.094 0 0 0
Maximum 8-hour
concentration
ppm State 0.070 0.069 0.065 0.074 0 0 3
Federal 0.070 0.068 0.064 0.074 0 0 3
Nitrogen Dioxide (NO 2) – Camp Pendleton
Maximum 1-hour
concentration
ppm State 0.18 0.048 0.053 0.058 0 0 0
Federal 0.100 0.048 0.053 0.058 0 0 0
Annual
concentration
ppm State 0.030 — 0.005 0.006 — — —
Federal 0.053 0.006 0.005 0.006 — — —
Carbon Monoxide (CO) – San Diego – 11403 Rancho Carmel Dr ive Maximum 1-hour
concentration
ppm State 20 1.9 4.1 3.3 0 0 0
Federal 35 1.9 4.1 3.3 0 0 0
Maximum 8-hour
concentration
ppm State 9.0 1.4 2.5 1.7 0 0 0
Federal 9 1.4 2.5 1.7 0 0 0
Sulfur Dioxide (SO 2) – El Cajon – Lexington Elementary School Maximum 1-hour
concentration
ppm Federal 0.075 0.003 0.0008 0.002 0 0 0
Maximum 24-hour
concentration
ppm Federal 0.14 0.0004 0.0003 0.0004 0 0 0
Annual
concentration
ppm Federal 0.030 0.0001 0.0001 0.0001 — — —
Coarse Particulate Matter (PM 10)a – El Cajon – Lexington Elementary School Maximum 24-hour
concentration
g/m3 State 50 44.7 37.4 55.0 0.0
(0)

0.0 (0)

0.0 (0)
Federal 150 43.0 38.7 55.0 0.0
(0)

0.0 (0)

0.0 (0)
Annual
concentration
g/m3 State 20 ND ND ND — — —
Fine Particulate Matter (PM 2.5 )a – El Cajon – Lexington Elementary School Maximum 24-hour
concentration
g/m3 Federal 35 36.2 23.8 38.2 — — —
Annual
concentration
g/m3 State 12 9.6 8.6 10.3 — — —
Federal 12.0 9.6 8.6 10.3 — — —
Sources: CARB 2022b; EPA 2022b.

Notes: ppm = parts per million by volume; ND = insufficient data available to determine the value; — = not available; g/m3 = micrograms per cubic meter.

Data taken from CARB iADAM (http://www.CARB.ca.gov/adam) and EPA AirData (http://www.epa.gov/airdata/) represent the highest concentrations experienced over a given year.

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Daily exceedances for particulate matter are estimated days because PM 10 and PM 2.5 are not monitored daily. All other criteria pollutants did not exceed federal or state standards during the years shown. There is no federal standard for 1 -hour ozone, annual PM10, or 24-hour SO2, nor is there a state 24-hour standard for PM2.5.

The Camp Pendleton monitoring station is located at 21441 W B Street, Camp Pendleton, California.

The San Diego – 11403 Rancho Carmel Drive monitoring station is located at 11403 Rancho Carmel Drive, San Diego, California.

The El Cajon-Lexington Elementary School monitoring station is located at 533 First Street, El Cajon, California. a Measurements of PM 10 and PM 2.5 are usually collected every 6 days and every 1 to 3 days, respectively. Number of days exceeding the standards is a mathematical estimate of the number of days concentrations would have been greater than the level of the standard had each day been monitored. The numbers in parentheses are the measured number of samples that exceeded the standard.

2.4 Significance Criteria and Methodology

2.4.1 Thresholds of Significance
Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.) provides guidance for evaluating whether a development project may result in significant impacts. Based on Appendix G of the CEQA Guidelines, the project would have a significant impact on air quality if the project would:

1. Conflict with or obstruct implementation of the applicable air quality plan.

2. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard.

3. Expose sensitive receptors to substantial pollutant concentrations.

4. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

Appendix G of the CEQA Guidelines ( 14 CCR 15000 et seq.) indicates that, where available, the significance criteria established by the applicable air quality management district or pollution control district may be relied upon to determine whether the project would have a significant impact on air quality. For purposes of this EIR, reference has been made to thresholds established by SDAPCD in Rule 20.2 for permitted stationary sources.

SDAPCD sets forth quantitative emission thresholds in Rule 20.2 below which a stationary source would not have a significant impact on ambient air quality. While the proposed project is a land use development project (and not a stationary source project), the Rule 20.2 thresholds provide a representative and relevant proxy for purposes of assessing project impacts. Therefore, project-related air quality impacts assessed in this EIR would be considered significant if a ny of the applicable significance thresholds developed by SDAPCD for Rule 20.2, as presented in Table 4, are exceeded. Emissions below the screening-level thresholds would not cause a significant impact. For nonattainment pollutants, if emissions exceed the thresholds shown in Table 4, a project could have the potential to result in a cumulatively considerable net increase in these pollutants and thus could have a significant impact on the ambient air quality.

Table 4. San Diego Air Pollution Control District Air Quality Significance Thresholds Construction Emissions
Pollutant Total Emissions (Pounds per Day)
Respirable particulate matter (PM10) 100
Fine particulate matter (PM2.5) 55
Oxides of nitrogen (NOx) 250
Sulfur oxides (SOx) 250

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Table 4. San Diego Air Pollution Control District Air Quality Significance Thresholds Construction Emissions
Pollutant Total Emissions (Pounds per Day)
Carbon monoxide (CO) 550
Volatile organic compounds (VOC) 137a
Operational Emissions
Pollutant
Total Emissions
Pounds per Hour Pounds per Day Tons per Year
Respirable particulate matter (PM10) — 100 15
Fine particulate matter (PM2.5) — 55 10
Oxides of nitrogen (NOx) 25 250 40
Sulfur oxides (SOx) 25 250 40
Carbon monoxide (CO) 100 550 100
Lead and lead compounds — 3.2 0.6
Volatile organic compounds (VOC) — 137a 13.7
Source: SDAPCD Rules 1501 and 20.2(d)(2).
a VOC threshold based on South Coast Air Quality Management District (SCAQMD) levels per the SCAQMD and the Monterey Bay Air Pollution Control District, which have similar federal and state attainment status to San Diego.

2.4.2 Approach and Methodology

2.4.2.1 Construction
Emissions from construction of the project were estimated using the California Emissions Estimator Model (CalEEMod)2 Version 2020.4.0.

For purposes of estimating project emissions, and based on information provided by the applicant and CalEEMod default values, it was estimated that construction of the project would commence in December 2023 and would last approximately 16 months, ending in March 2025. The analysis contained herein is based on the following parameters (duration of phases is approximate):
▪ Site preparation – 6 days (December 2023)
▪ Grading – 24 days (December 2023 – January 2024)
▪ Paving – 20 days (January 2024 – February 2024)
▪ Building construction – 262 days (February 2024 – February 2025) ▪ Architectural coating – 20 days (February 2025 – March 2025) The construction equipment mix used for estimating the construction emissions of the project is based on CalEEMod default data and is shown in Table 5 . For this analysis, it was estimated that heavy construction equipment would operate 5 days a week during project construction.

2 CalEEMod is a statewide land use emissions computer model designed to provide a uniform platform for government ag encies, land use planners, and environmental professionals to quantify potential criteria air pollutant and GHG emissions from a variety of land use projects.

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Table 5. Construction Scenario Parameters
Construction
Phase
One -Way Vehicle Trips Equipment
Average
Daily
Worker
Trips
Average Daily
Vendor Truck
Trips
Total Haul
Truck Trips Equipment Type Quantity
Usage
Hours
Site preparation 12 4 0 Rubber Tired
Loaders 1 8
Tractors/Loaders/
Backhoes 3 8
Grading 16 4 0 Graders 1 8
Rubber Tired Dozers 1 8
Scrapers 4 8
Tractors/Loaders/
Backhoes 1 8
Paving 16 4 0 Pavers 2 8
Paving Equipment 2 8
Rollers 3 8
Building
Construction
192 54 0 Welders 1 8
Air Compressors 2 8
Cranes 1 4
Forklifts 2 8
Generator Sets 1 8
Skid Steer Loaders 1 4
Tractors/Loaders/
Backhoes 1 4
Architectural
coating
38 4 0
Air Compressors 1 6
Note: See Appendix A for details.

The equipment used in each phase as shown in Table 5 was based on the CalEEMod default equipment mix for each phase of construction. Construction-worker and vendor estimates by construction phase were generated by CalEEMod. Based on the project’s grading plans, the project would be balanced on site. The applicant has committed to us ing offroad construction equipment with EPA Tier 4 Interim certification or better for equipment over 50 horsepower and electric equipment less than 50 horsepower 3.

Health Risk Assessment
As a precautionary measure, a health risk assessment (HRA) was performed to assess the impact of construction on sensitive receptors proximate to the project . This report includes an HRA associated with emissions from construction of the project based on the methodologies prescribed in the Office of Environmental Health H azard Assessment (OEHHA) Air Toxics Hot Spots Program Risk Assessment Guidelines – Guidance Manual for Preparation of

3 In the case that a piece of equipment is not available in Tier 4 Interim, the applicant may upg rade another piece of equipment to better than Tier 4 Interim (i.e. Tier 4 Final) to compensate for the piece of equipment with a lower tier.

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Health Risk Assessments (OEHHA 2015). To implement the OEHHA Guidelines based on Project information, the SDAPCD has developed a three-tiered approach where each successive tier is progressively more refined, with fewer conservative assumptions. The SDAPCD Supplemental Guidelines for Submission of Air Toxics “Hot Spots” Program Health Risk Assessments provides guidance with which to perform HRAs within the SDAB (SDAPCD 2022).

Health effects from carcinogenic air toxics are usually described in terms of cancer risk. The SDAPCD recommends a carcinogenic (cancer) risk threshold of 10 in a million. Additionally, s ome TACs increase non - cancer health risk due to long -term (chronic) exposures. The Chronic Hazard Index is the sum of the individual substance chronic hazard indices for all TACs affecting the same target organ system. The SDAPCD recommends a Chronic Hazard Index significance threshold of 1.0 (project increment). The exhaust from di esel engines is a complex mixture of gases, vapors, and particles, many of which are known human carcinogens. DPM has established cancer risk factors and relative exposure values for long -term chronic health hazard impacts. No short-term, acute relative exposure level has been established for DPM; therefore, acute impacts of DPM are not addressed in this assessment. This HRA evaluated the risk to future residents from diesel emissions from exhaust from onsite construction equipment and diesel haul and vendor trucks.

The dispersion model ing of DPM was performed using the American Meteorological Society/ EPA R egulatory Model (AERMOD), which is the model SDAPCD requires for atmospheric dispersion of emissions. AERMOD is a steady-state Gaussian plume model that incorporates air dispersion based on planetary boundary layer turbulence structure and scaling concepts, including treatment of surface and elevated sources, building downwash, an d simple and complex terrain ( EPA 2015 ). For the Project, AERMOD was run with all sources emitting unit emissions (1 gram per second ) to obtain the “Χ/Q” values. Χ/Q is a dispersion factor that is the average effluent concentration normalized by source strength and is used as a way to simplify the representation of emissions from many sources. The Χ/Q values of ground-level concentrations were determined for construction emissions using AERMOD and the maximum concentrations determined for the 1 -hour and Per iod averaging periods. Principal parameters of this modeling are presented in Table 6.

Table 6. AERMOD Principal Parameters
Parameter Details
Meteorological Data The latest 3-year meteorological data (2010–2012) for the Escondido Station (Station ID 3177) from SDAPCD were downloaded and then input to AERMOD. For cancer or chronic noncancer risk assessments, the average cancer risk of all years modeled was used.

Urban versus Rural
Option
Urban areas typically have more surface roughness, as well as structures and low- albedo surfaces that absorb more sunlight—and thus more heat—relative to rural areas. However, based on the SDAPCD guidelines, the rural dispersion option was selected due to the Project’s proximity to the ocean.

Terrain
Characteristics
The terrain in the vicinity of the modeled Project site is generally flat. The elevation of the modeled site is about 575 feet above sea level. Digital elevation model files were imported into AERMOD so that complex terrain features were evaluated as appropriate.

Elevation Data Digital elevation data were imported into AERMOD, and elevations were assigned to the emission sources and receptors. Digital elevation data were obtained through AERMOD View in the United States Geological Survey’s National Elevation Dataset format with a 10-meter resolution.

Emission Sources
and Release
Air dispersion modeling of DPM from construction equipment was conducted using emissions estimated using the CalEEMod, assuming emissions would occur 8

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Table 6. AERMOD Principal Parameters
Parameter Details
Parameters hours per day, 5 days per week. The Project area was modeled as a series of volume sources.

Source Release
Characterizations
Based on EPA methodology, the modeled line volume sources would result in a release height of 3.4 meters, a plume height of 6.8 meters, and a plume width of

8.6 meters for off-road equipment and diesel trucks (EPA 2015).

Discrete Receptors A uniform Cartesian grid overlaying residential receptors in close proximity to the project with 20-meter resolution was placed. Additional discrete receptors were placed over residences not within the uniform Cartesian grid.

Note: See Appendix B.

Dispersion model plotfiles from AERMOD were then imported into CARB’s Hotspots Analysis and Reporting Program Version 2 to determine health risk, which requires peak 1 -hour emission rates and annual -averaged emission rates for all pollutants for each modeling source. For the residential health risk, the HRA assumes exposure would start in the third trimester of pregnancy . The results of the HRA are provided in Section 2 .5, and detailed results and methodology are provided in Appendix B.

2.4.2.2 Operation
CalEEMod was used to estimate operational emissions from area sources, including emissions from consumer product use, architectural coatings, and landscape maintenance e quipment. Emissions associated with natural gas usage in space heating and water heating are calculated in the building energy use module of CalEEMod, as described in the following text.

Area Sources
Consumer products are chemically formulated products used by household and institutional consumers, including detergents; cleaning compounds; polishes; floor finishes; cosmetics; personal care products; home, lawn, and garden products; disinfectants ; sanitizers; aerosol paints; and automotive specialty product s. Other paint products, furniture coatings, or architectural coatings are not considered consumer products (CAPCOA 2021).

Consumer product VOC emissions are estimated in CalEEMod based on the floor area of residential buildings and on the default factor o f pounds of VOC per building square foot per day. The CalEEMod default values for consumer products were modeled.

VOC off-gassing emissions result from evaporation of solvents contained in surface coatings , such as in paints and primers used during buildin g maintenance. CalEEMod calculates the VOC evaporative emissions from application of surface coatings based on the VOC emission factor, the building square footage, the assumed fraction of surface area, and the reapplication rate. The VOC emission factor i s based on the VOC content of the surface coatings, and SDAPCD’s Rule 67.0.1 (Architectural Coatings) governs the VOC content for interior and exterior coatings (SDAPCD 2015) . The model default reapplication rate of 10% of area per year is assumed.

Consistent with CalEEMod defaults, it is assumed that the surface area for painting equals 2.7 times the floor square footage, with 75% assumed for interior coating and 25% assumed for exterior surface coating (CAPCOA 2021). Consistent with the architectural coat ings used during the construction phase, the applicant will use architectural coatings with a VOC content of 50 grams per liter ( g/L) for internal reapplication, and exterior architectural coatings would have a VOC content of 100 g/L for any reapplication during operation.

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Landscape maintenance includes fuel combustion emissions from equipment such as lawn mowers, rototillers, shredders/grinders, blowers, trimmers, chainsaws, and hedge trimmers. The emissions associated from landscape equipment use are estimated based on CalEEMod default values for emission factors (grams per square foot of nonresidential building space per day) and number of summer days (when landscape maintenance would generally be performed) and winter days. Emissio ns associated with potential landscape maintenance equipment were included to conservatively capture potential project operational emission sources. As a project design feature, the project would not include wood burning stoves or fireplaces.

Energy Source s
As represented in CalEEMod, energy sources would include emissions associated with building electricity and natural gas usage. Electricity use would contribute indirectly to criteria air pollutant emissions; however, the emissions from electricity use ar e only quantified for GHGs in CalEEMod, since criteria pollutant emissions occur at the site of the power plant, which is typically off site.

Operational criteria air pollutant emissions from energy sources include natural gas combustion for appliances and space and water heating. The current Title 24, Part 6 standards, referred to as the 2019 Title 24 Building Energy Efficiency Standards, became effective on January 1, 2020. CalEEMod defaults were assumed for electricity and natural gas. The project is also designed to include energy star appliances.

Mobile Sources
The project would generate air quality emissions from mobile sources (vehicular traffic) as a result of the residents of the project. CalEEMod was used to estimate emissions from proposed vehicul ar sources (refer to Appendix A). The trip generation rates for the project residential land use were adjusted in CalEEMod to match the overall weekday daily trip rate and trip length based on the Traffic Impact Analysis ( CR Associates 2022).

CalEEMod default data, trip modes, fleet mix, and emissions factors were used for the model inputs. CalEEMod default vehicle emission factors and vehicle fleet mix for 2025, as based on the CARB EMFAC201 7 model, were used to estimate emissions associated with vehicular sources. In accordance with 2019 CalGreen requirements, the project would install a listed raceway to accommodate a dedicated 208/240 -volt branch circuit in each residential garage for future installation of an electric vehicle (EV) charger. No quantitati ve credit was taken for this requirement. The 2019 CalGreen Section 4.106.4.2.1 requires the installation of at least one EV space in common use parking. As such, the project is assume to install two EV charging station s in the common use parking.

Due to the projects location and design, the following reduction measures were estimated using a spreadsheet based model (see Appendix A for calculation details):
• CAPCOA Final Handbook: Increase Residential Density (T-1; • CAPCOA Final Handbook: T-18 Provide Pedestrian Network Improvement; • City of San Marcos CAP: Measure T-2 Require Electric Vehicle Charging Stations in New Development; and • City of San Marcos CAP: Measure E -1 Require New Residential Developme nts to Install Alternatively - Fueled Water Heaters.

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2.5 Impact Analysis
Threshold 1: Would the project conflict with or obstruct implementation of the applicable air quality plan? As mentioned in Section 2.2, Regulatory Setting, the SDAPCD is responsible for developing and implementing the clean air plans for attainment and maintenance of the ambient air quality standards in the SDAB—specifically, the SIP and RAQS. 4 SANDAG is responsible for developing forecasts and data that are used by the SDAPCD in preparing the SIP and RAQS. The federal O3 maintenance plan, which is part of the SIP, was adopted in 2012. The SIP includes a demonstration that current strategies and tactics will maintain acceptable air quality in the basin based on the NAAQS. The RAQS was i nitially adopted in 1991 and is updated every 3 years (most recently in 2020). The RAQS outlines SDAPCD’s plans and control measures designed to attain the state air quality standards for O 3. The SIP and RAQS rely on information from CARB and SANDAG, inclu ding mobile and area source emissions, as well as information regarding projected growth in the County as a whole and the cities in San Diego County, to project future emissions and determine the strategies necessary for the reduction of emissions through regulatory controls. CARB mobile source emission projections and SANDAG growth projections are based on population, vehicle trends, and land use plans developed by the County and the cities in the County as part of development of their general plans.

Although the SDAPCD and City do not provide guidance regarding the analysis of impacts associated with air quality plan conformance, the Cou nty’s Guidelines for Determining Significance and Report and Format and Content Requirements – Air Quality doe s discuss c onformance with the RAQS (County of San Diego 2007). The guidance indicates that, if the project, in conjunction with other projects, contributes to growth projections that would not exceed SANDAG’s growth projections for a city, the project would not be i n conflict with the RAQS. If a project includes development that is greater than that anticipated in the local plan and SANDAG’s growth projections, the project might be in conflict with the SIP and RAQS and may contribute to a potentially significant cumulative impact on air quality (County of San Diego 2007).

The project site is currently zoned for Commercial (C) use with an existing General Plan designation of Commercial and is within the City’s General Plan Neighborhood College area. The project proposes a General Plan and Zoning Amendment to change the land use designation to Specific Plan Area (SPA). The City projects an increase of 3,170 housing units between 2020 and 2035 (SANDAG 2013), and the project would only account for 3.8% of the projected housing units to increase in the City between 2020 and 2035 in the SANDAG Series 13 forecast. The project’s proposed GPA/Rezone would be within the growth projections for the City; thus, the project would result in regional growth that is accounted for within the RAQS . Furthermore, at a regional level, the growth is consistent with the underlying growth forecasts in the SIP and RAQS. Therefore, implementation of the proposed project would not conflict with the RAQS or SIP , and potential future development would be consistent with the growth in the region. Impacts would be less than significant.

4 For the purpose of this discussion, the relevant federal air quality plan is the Ozone Maintenance Plan (SDAPCD 2020). The RAQS is the applicable plan for purposes of state air quality planning. Both plans reflect growth projections in the SDAB.

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Threshold 2: Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? In analyzing cumulative impacts from a project, the analysis must specifically evaluate a project’s contribution to the cumulative increase in pollutants for which the air basin is designated as nonattainment for the CAAQS and NAAQS. If a project does not exceed thresholds and is determined to have less -than-significant project-specific impacts, it may still contribute to a significant cumulative impact on air quality if the emissions from the project, in combination with the emissions from other proposed or reasonably foreseeable future projects, are in excess of established thresholds. However, a project would only be considered to have a significant cumulative impact if the project’s contribution accounts for a significant proportion of the cumulative total emissions (i.e., it represents a “cumulatively considerable contribution” to the cumulative air quality impact).

Additionally, for the SDAB, the RAQS serves as the long -term regional air quality planning document for the purpose of assessing cumulative operational emissions to ensure that the SDAB continues to make progress toward NAAQS and CAAQS attainment status. As such, cumulative projects located in the San Diego re gion would have the potential to result in a cumulative impact to air quality if, in combination, they would conflict with or obstruct implementation of the RAQS. Similarly, individual projects that are inconsistent with the regional planning documents upon which the RAQS is based would have the potential to result in cumulative operational impacts if they represent development and population increases beyond regional projections.

The SDAB has been designated as a federal nonattainment area for O 3 and a sta te nonattainment area for O 3, PM10, and PM 2.5. PM10 and PM2.5 emissions associated with construction generally result in “near-field” impacts.

The nonattainment status is the result of cumulative emissions from all sources of these air pollutants and their precursors within the SDAB. As discussed previously, the emissions of all criteria pollutants would be below the significance levels. Construction would be short term and temporary , and o nce construction is completed, construction-related emissions would cease. Operational emissions generated by the project would not exceed the significance thresholds for VOCs, NOx, CO, SO x, PM10, or PM 2.5, and would not cause a significant impact. As such, the project would result in less-than-significant impacts to air quality relative to operational emissions.

Construction of the project would result in the temporary addition of pollutants to the local airshed caused by soil disturbance, fugitive dust emissions, and combustion pollutants from on-site construction equipment, as well as from off-site trucks hauling construction materials. Construction emissions can vary substantially from day to day, depending on the level of activity, the specific type of operation, and for dust, the prevailing weather conditions. Therefore, such emissions levels can only be estimated, with a corresponding uncertainty in precise ambient air quality impacts.

Fugitive dust (PM10 and PM2.5) emissions would primarily result from grading and site preparation activities. NOx and CO emissions would primarily result from the use of construction equipment and motor vehicles.

Construction emissions were calculated using CalEEMod for the estimated worst -case day over the construction period associated with each pha se and reported as the maximum daily emissions estimated during each year of construction (202 3 through 2025). Construction schedule assumptions, including phase type, duration, and sequencing, were based on information provided by the applicant and is int ended to represent a reasonable scenario based on the best information available. A detailed depiction of the construction schedule —including information regarding phasing, equipment u sed during each phase, haul trucks, vendor trucks, and worker vehicles—is included in Section 2.4.2.1, Construction, of this report. The information contained in Appendix A (CalEEMod Output Files) was used for the CalEEMod inputs.

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Implementation of the project would generate temporary air pollutant emissions from entrained dus t, off -road equipment, vehicle emissions, architectural coatings, and asphalt pavement application. Entrained dust results from the exposure of earth surfaces to wind from the direct disturbance and movement of soil, resulting in PM 10 and PM2.5 emissions. The project is subject to SDAPCD Rule 55, Fugitive Dust Control. This rule requires that the project take steps to restrict visible emissions of fugitive dust beyond the property line. Compliance with Rule 55 would limit fugitive dust (PM 10 and PM 2.5) that may be generated during grading and construction activities. To account for dust control measures in the calculations, it was assumed that the active sites would be watered at least two times daily, resulting in an approximately 55% reduction of PM. Compl iance with Rule 55 would be required as a standard condition of project approval or for issuance of a grading permit.

Exhaust from internal combustion engines used by construction equipment, hauling trucks (dump trucks), vendor trucks (delivery trucks), and worker vehicles would result in temporary emissions of NO x, VOC, CO, SOx, PM10, and PM2.5. Application of architectural coatings, such as exterior/interior paint and other finishes, would also produce VOC emissions; however, the contractor is required to procure architectural coatings from a supplier in compliance with the requirements of SDAPCD Rule 67.0.1, Architectural Coatings. This rule requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC content of various coating categories (SDAPCD 2015). The project would comply with SDAPCD Rule 67.0.1 through the incorporation of low - VOC architectural coatings. The VOC content assumed for the analysis was 50 g/L for interior coatings and 100 g/L for exterior coatings.

Table 7 shows the estimated maximum daily construction emissions associated with the construction of the project. Details of the emissions calculations are provided in Appendix A of this document.

Table 7. Estimated Maximum Daily Construction Emissions Year
VOC NO x CO SO x PM 10 PM 2.5
Pounds per Day
2023 1.36 21.59 43.15 0.08 5.39 1.92
2024 1.36 21.59 43.12 0.08 5.39 1.92
2025 48.50 11.21 19.58 0.05 2.02 0.08
Maximum daily emissions 48.50 21.59 43.15 0.08 5.39 1.92 Emission threshold 75 250 550 250 100 55
Threshold exceeded? No No No No No No
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = particulate matter with an aerodynamic diameter equal to or less than 10 microns; PM2.5 = particulate matter with an aerodynamic diameter equal to or less than

2.5 microns.

See Appendix A for output files and modeling details.

The values shown are the maximum summer or winter daily emissions results from CalEEMod and provided in Appendix A. The maximum emissions assumes compliance with SDAPCD Rule 67.0.1, Architectural Coatings, and SDAPCD Rule 55, Fugitive Dust Control.

As shown in Table 7, daily construction emissions would not exceed the significance thresholds for VOC, NO x, CO, SOx, PM10, or PM2.5.

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Following the completion of construction activities, the project would generate VOC, NOx, CO, SOx, PM10, and PM2.5 emissions from mobile sources, including vehicular traffic generated by residents of the project; area sources, including the use of landscaping equipment and consumer products; and from architectural coatings.

Table 8 presents the maximum daily emissions associated with the operation of the project after all construction has been completed. The values shown for motor vehicles and area sources are the maximum summer or winter daily emissions results from CalEEMod.

Table 8. Estimated Project Maximum Daily Operational Emissions Emission Source
VOC NO x CO SO x PM 10 PM 2.5
pounds per day
Area 3.17 0.11 9.89 0.00 0.06 0.06
Energy 0.03 0.22 0.09 0.00 0.02 0.02
Mobile 2.03 1.77 15.18 0.03 3.02 0.82
Total 5.23 2.10 25.16 0.03 3.10 0.90
Emission threshold 55 250 550 250 100 55
Threshold exceeded? No No No No No No
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = particulate matter with an aerodynamic diameter equal to or less than 10 microns; PM2.5 = particulate matter with an aerodynamic diameter equal to or less than

2.5 microns.

See Appendix A for output files and modeling details.

As shown in Table 8, the dai ly operational emissions from the project would not exceed the significance thresholds for VOC, NOx, CO, SOx, PM10, or PM2.5.

Regarding long-term cumulative operational emissions in relation to consistency with local air quality plans , the SIP and RAQS serve as the primary air quality planning documents for the state and SDAB, respectively. T he SIP and RAQS rely on SANDAG growth projections based on population, vehicle trends, and land use plans developed by the cities and the County as part of the development of their general plans. Development that is consistent with the growth anticipated by local plans would be consistent with the SIP and RAQS and would result in emissions that are accounted for. Projects that conform to the permitted land use, or result in a less emissions - intensive use, and are therefore accounted for in the SIP and RAQS , would not be considered to result in cumulatively considerable impacts from operational emissions. As stated previously, the project would result in fewer emissions than buildout of the existing permitted land use that was anticipated by the RAQS and therefore would not result in significant regional emissions that are not accounted for within the RAQS. As a result, the project would not result in a cumulatively considerable contribution to regional O3 concentrations or other criteria pollutant emissions. Therefore, the project’s cumulative impacts would be less than significant.

Threshold 3: Would the project expose sensitive receptors to substantial pollutant concentrations? Air quality varies as a direct function of the amount of pollutants emitted into the atmosphere, the size and topography of the air basin, and the prevailing meteorological conditions. Air quality problems arise when the rate of pollutant emissions exceeds the rate of dispersion. Reduced visibility, eye irritation, and adverse health impacts upon those persons termed “sensitive receptors” are the most serious hazards of e xisting air quality conditions in the area. Some land uses are considered more sensitive to changes in air quality than others, depending on the population groups and the activities involved. People most likely to be affected by air pollution,

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as identifie d by CARB, include children, the elderly, athletes, and people with cardiovascular a nd chronic respiratory diseases; however, for the purposes of this analysis, residents are also considered sensitive receptors.

As such, s ensitive receptors include residen ces, schools, playgrounds, childcare centers, athletic facilities, long - term healthcare facilities, rehabilitation centers, convalescent centers, and retirement homes.

Health Impacts of Toxic Air Contaminants
In addition to impacts from criteria pollutants, project impacts may include emissions o f pollutants identified by the state and federal government as TACs or hazardous air pollutants. State law has established the framework for California’s TAC identification and control program, which is generally more stringent than the federal program and aimed at TACs that ar e a problem in California. The state has formally identified more than 200 substances as TACs, including the federal hazardous air pollutants, and is adopting appropriate control measures for sources of these TACs. The greatest potential for TAC emissions during construction would be diesel particulate emissions from heavy -duty equipment operations and heavy -duty trucks, and the associated health impacts to sensitive receptors. The following measures are required by state law to reduce diesel particulate emissions:
▪ Fleet owners of mobile construction equipment are subject to the CARB Regulation for In -use Off-road Diesel Vehicles (Title 13 California Code of Regulations, Chapter 9, Sect ion 2449), the purpose of which is to reduce DPM and criteria pollutant emissions from in-use (existing) off-road diesel-fueled vehicles. ▪ All commercial diesel vehicles are subject to Title 13, Section 2485 of the California Code of Regulations, limiting engine idling time. Idling of heavy-duty diesel construction equipment and trucks during loading and unloading shall be limited to 5 minutes; electric auxiliary power units should be used whenever possible.

The greatest potential for TAC emissions during construction would be DPM emissions from heavy-duty equipment operations and heavy -duty trucks during construction of the project and the as sociated health impacts to sensitive receptors.

However, as a precautionary measure, an HRA was performed to evaluate the risk from diesel exhaust emissions on existing sensitive receptors and future onsite receptors from construction activities. The HRA methodology was described in Section 2.4.2.1, and the detailed assessment is provided in Appendix B. Table 9 summarizes the results of the HRA for proposed project construction.

Table 9. Construction Activity Health Risk Assessment Results Impact Paramete r Units Project Impact
CEQA
Threshold Level of Significance
Cancer Risk Per Million 5.9 10.0 Less than Significant
HIC Not Applicable 0.005 1.0 Less than Significant
Source: Appendix B.

Notes: CEQA = California Environmental Quality Act; HIC = Chronic Hazard Index.

The results of the HRA demonstrate that the TAC exposure from construction diesel exhaust emissions would result in cancer risk on site below the 10 in 1 million threshold, as well as Chronic Hazard Index less than 1.0. Therefore, TAC emissions from construction of the proposed project would not expose sensitive receptors to substantial pollutant concentrations and would result in a less than significant impact. Upon completion of construction, the project would not generate substantial TAC emissions. As such, impacts would be less than significant during operation.

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Health Impacts of Carbon Monoxide
Exposure to high concentrations of CO can result in dizziness, fatigue, chest pain, headaches, and impairment of central nervous system functions. Mobile -source impacts, including those related to CO, occur on two scales.

Regionally, project-related construction travel would add to regional trip generation and increase the vehicle miles traveled within the local airshed and the SDAB. Locally, construction traffic would be added to the roadway system in the vicinity of the project site. Although the SDAB is currently an attainment area for CO, there is a potential for the formation of microscale CO “hotspots” to occur immediately around points of congested traffic.

Hotspots can form if such traffic occurs during periods of poor atmospheric ventilation, is composed of a large number of vehicles cold -started and operating at pollution -inefficient speeds, and/or is operating on roadways already crowded with non -project traffic. Because of continued improvement in vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO hotspots in the SDAB is steadily decreasing. The SDAB is a CO maintenance area (western and central part of the SDAB only).

The Governor’s Office of Planning and Research and the California Natural Resources Agency have issued new CEQA Guidelines for analyzing transportation impacts. By July 1, 2020, all CEQA lead agencies must analyze a project’s transportation impacts using vehicle -miles traveled. Vehicle -miles traveled measures the distances vehicles will travel to and from a project, rather than congestion levels at intersections (LOS, graded on a scale of A–F). To account for this shift from LOS to vehicle -miles traveled – such that vehicle congestion is no longer modeled and available – but to nonetheless evaluate the potential for CO hotspots for the hypothetical development scenario, this SCEA utilizes CO modeling analyses performed by the South Coast Air Quality Management District (SCAQMD) relative to 1-hour and 8-hour concentrations as follows.

The SCAQMD conducted CO modeling for the 2003 Air Quality Management Plan (Appendix V of SCAQMD 2003) for the four worst-case intersections in the South Coast Air Basin: (1) Wilshire Boulevard and Veteran Avenue, (2) Sunset Boulevard and Highland Avenue, (3) La Cienega Boulevard and Century B oulevard, and (4) Long Beach Boulevard and Imperial Highway. At the time the 2003 Air Quality Management Plan was prepared, the intersection of Wilshire Boulevard and Veteran Avenue was the most congested intersection in Los Angeles County, with an average daily traffic volume of about 100,000 vehicles per day. Using CO emission factors for 2002, the peak modeled CO 1 -hour concentration was estimated to be 4.6 ppm at the intersection of Wilshire Boulevard and Veteran Avenue.

A daily traffic volume of 100,0 00 vehicles (as considered in the SCAQMD modeling) as a result of the proposed project, would be at least double the traffic volumes of nearby intersections ( CR Associates 2022 ). However, if “peak” modeled 1-hour concentration from SCAQMD’s analysis of 100,000 vehicle traffic volumes of the 4.6 ppm were added to the maximum 1 -hour CO concentration from 2018 through 2020 at the San Diego – 11403 Rancho Carmel Drive monitoring station (see Table 3, Local Ambient Air Quality Data) of 4.1 ppm (in 2019), the 1- hour CO concentration in the project area would total 8.7 ppm. This “worst case scenario” – modeling at least double the traffic compared to that experienced in the proposed project area – would still result in 1 -hour CO concentrations well below the CAAQS 1-hour CO threshold of 20 ppm.

Concerning 8 -hour concentrations, SCAQMD modeled future year 8 -hour CO concentrations at the Central Los Angeles monitoring site of 4.6 ppm in 2020. Adding the 4.6 ppm to the maximum 8 -hour CO concentration from 2018 through 2020 at the San Diego – 11403 Rancho Carmel Drive monitoring station of 2.5 ppm (in 2019) would result in a total 8 -hour CO concentration of 7.1 ppm. Again, this “worst case scenario” 8 -hour CO

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concentration assuming traffic counts far above that experie nced in the proposed project area would still be well below the CAAQS 8-hour threshold of 9.0 ppm.

Said another way, CO concentrations at congested intersections would not exceed the 1-hour or 8-hour CO CAAQS unless projected daily traffic would cause area traffic volumes to exceed 100,000 vehicles per day. The proposed project would not increase daily traffic volumes at any study intersection to more than 100,000 vehicles per day (CR Associates 2022). Therefore, the proposed project is not anticipated to create a CO hotspot. As such, impacts to sensitive receptors with regard to potential CO hotspots resulting from the project and hypothetical development scenario’s contribution to cumulative traffic -related air quality impacts would be less than significant.

Health Impacts of Criteria Air Pollutants
Construction and operation of the project would not result in emissions that exceed the SDAPCD significance thresholds for any criteria air pollutants including VOC, NO x, CO, SOx, PM10, or PM2.5. Regarding VOCs, some VOCs would be associated with motor vehicles and construction equipment, while others are associated with architectural coatings, the emissions of which would not result in the exceedances of the SDAPCD significance thresholds as shown in Table 3, Local Ambient Air Quality Data . Generally, the VOCs in architectural coatings are of relatively low toxicity. Additionally, the project would use low-VOC architectural coatings that would comply with SDAPCD Rule 67.0 .1, which restricts the VOC content of coatings for both construction and operational applications (SDAPCD 2015).

In addition, VOCs and NO x are precursors to O 3, for which the SDAB is designated as nonattainment with respect to the NAAQS and CAAQS ( the SDAB is designated by the EPA as an attainment area for the 1-hour O 3 NAAQS standard). The health effects associated with O 3, as discussed in Section 2.2, are generally associated wit h reduced lung function. The contribution of VOCs and NO x to regional ambient O 3 concentrations is the result of complex photochemistry. The increases in O 3 concentrations in the SDAB due to O 3 precursor emissions tend to be found downwind from the source location to allow time for the photochemical reactions to occur. However, the potential for exacerbating excessive O 3 concentrations would also depend on the time of year that the VOC emissions would occur because exceedances of the O3 ambient air quality standards tend to occur between April and October when solar radiation is highest.

The holistic effect of a single project’s emissions of O 3 precursors is speculative due to the lack of quantitative methods to assess this impact. Nonetheless, the VOC and NOx emissions associated with project construction could minimally contribute to regional O 3 concentrations and the associated health impacts. Due to the minimal contribution during construction and operation health impacts would be considered less than significant.

Similar to O3, construction of the project would not exceed the SDAPCD significance thresholds for PM10 or PM2.5 and would not contribute to exceedances of the NAAQS and CAAQS for particulate matter. Due to the minimal contribution of particulate matter during construction and operation, health impacts would be considered less than significant.

Regarding nitrogen dioxide, a ccording to the construction emissions analysis, construction of the project would not contribute to exceedances of the NAAQS and CAAQS for NO2. As described in Section 2.2, NO2 and NOx health impacts are associated with respiratory irritation, which may be experienced by nearby receptors during the periods of heaviest use of off -road construction equipment. Off-road construction equipment would be operating

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at various portions of the site and would not be concentrated in one portion of the site at any one time.

Construction of the project would not require any stationary emission sources that would create substantial, localized NOx impacts. Therefore, health impacts would be considered less than significant.

In summary , construction and operation of the project wo uld not result in exceedances SDAPCD significance thresholds for criteria pollutants. The VOC and NOx emissions, as described previously, would minimally contribute to regional O 3 concentrations and the associated health effects. In addition to O 3, NO x emissions would not contribute to potential exceedances of the NAAQS and CAAQS for NO 2. As shown in Table 3, the existing NO 2 concentrations in the area are well below the NAAQS and CAAQS standards. Thus, the project’s operational NO x emissions are not expected to result in exceedances of the NO 2 standards or contribute to the associated health effects. PM10 and PM2.5 would not contribute to potential exceedances of the NAAQS and CAAQS and would not obstruct the SDAB from coming into attainment for these pollutants and would not contribute to significant health effects associated with particulates . Therefore, health impacts associated with criteria air pollutants would b e considered less than significant.

Valley Fever Exposure
As discussed in Section 2.1.4, Pollutants and Effects, Valley Fever is not highly endemic to San Diego County, and within San Diego County, the incidence rate in the project area is below the County average and the statewid e average. Construction of the project would comply with SDAPCD Rule 55, which limits the amount of fugitive dust generated during construction. Strategies the Project would implement to comply with SDAPCD Rule 55 and control dust include watering two times per day and limiting speed on unpaved roads to 15 miles per hour.

Based on the low incidence rate of Coccidioidomycosis in San Diego County, and the project’s implementation of dust control strategies, it is not anticipated that earth-moving activities during project construction would result in exposure of nearby sensitive receptors to Valley Fever. Therefore, the project would have a less than significant impact with respect to Valley Fever exposure for sensitive receptors.

Threshold 4: Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Odors would be generated from vehicles and/or equipment exhaust emissions during construction of the project.

Odors produced during construction would be attributable to concentrations of unburned hydrocarbons from tailpipes of construction equipment and architectural coatings. Such odors would disperse rapidly from the project site and generally occur at magnitudes that would not affect substantial numbers of people. Therefore, impacts associated with odors during construction would be considered less than significant.

Land uses and industrial operations associated with odor complaints include agricultural uses, wast ewater treatment plants, food-processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding (CARB 2005). The project would not engage in any of these activities. Moreover, t ypical odors generated from operation of t he project would primarily include vehicle exhaust generated by residents, as well as through the periodic use of landscaping or maintenance equipment. Therefore, the project would result in an odor impact that is considered to be less than significant.

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2.6 Mitigation Measures
The project would not result in significant impacts; therefore, no mitigation is required.

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3 Greenhouse Gas Emissions

3.1 Environmental Setting

3.1.1 Climate Change Overview
Climate change refers to any significant change in measures of climate, such as temperature, precipitation, or wind patterns, lasting for an extended period of time (decades or longer). The Earth's temperature depends on the balance between energy entering and leaving the planet’s system. Many factors, both natural and human, can cause changes in Earth’s energy balance, including variations in the sun ’s energy reaching Earth, changes in the reflectivity of Earth’s atmosphere and surface, and changes in the greenhouse effect, which affects the amount of heat retained by Earth’s atmosphere (EPA 2017a).

The greenhouse effect is the trapping and build -up of heat in the atmosphere (troposphere) near the Earth’s surface. The greenhouse effect traps heat in the troposphere through a threefold process as follows: Short -wave radiation emitted by the Sun is absorbed by the Earth; the Earth emits a portion of this energy in the form of long - wave radiation; and GHGs in the upper atmosphere absorb this long -wave radiation and emit it into space and toward the Earth. The greenhouse effect is a natural process that contributes to regulating the Earth’s temperature and creates a pleasant, livable environment on the Earth. Human activities that emit additional GHGs to the atmosphere increase the amount of infrared radiation that gets absorbed before escap ing into space, thus enhancing the greenhouse effect and causing the Earth’s surface temperature to rise.

The scientific record of the Earth’s climate shows that the climate system varies naturally over a wide range of time scales and that in general, clim ate changes prior to the Industrial Revolution in the 1700s can be explained by natural causes, such as changes in solar energy, volcanic eruptions, and natural changes in GHG concentrations. Recent climate changes, in particular the warming observed over the past century, however, cannot be explained by natural causes alone. Rather, it is extremely likely that human activities have been the dominant cause of that warming since the mid -twentieth century and is the most significant driver of observed climate change (IPCC 2013; EPA 2017a). Human influence on the climate system is evident from the increasing GHG concentrations in the atmosphere, positive radiative forcing, observed warming, and improved understanding of the climate system (IPCC 2013). The atmos pheric concentrations of GHGs have increased to levels unprecedented in the last 800,000 years, primarily from fossil fuel emissions and secondarily from emissions associated with land use changes (IPCC 2013). Continued emissions of GHGs will cause further warming and changes in all components of the climate system, which is discussed further in Section 3.1.5, Potential Effects of Climate Change.

3.1.2 Greenhouse Gases and other Climate Forcing Substances A GHG is any gas that absorbs infrared radiation in the atmosphere; in other words, GHGs trap heat in the atmosphere. GHGs include, but are not limited to, carbon dioxide (CO 2), methane (CH 4), nitrous oxide (N 2O), O3, water vapor, hydrofluorocarbons (HFCs), hydrochlorofluorocarbons (HCFCs), perfluorocarbons (PFCs), and sulfur

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hexafluoride (SF6).5 Some GHGs, such as CO 2, CH4, and N 2O, occur naturally and are emitted to the atmosphere through natural processes and human activities. Of these gases, CO 2 and CH 4 are emitted in the greatest quantities from human activities. Manufactured GHGs, which have a much greater heat-absorption potential than CO2, include fluorinated gases, such as HFCs, HCFCs, PFCs, and SF 6, which are associated with certain industrial products and processes. A summary of the most common G HGs and their sources is included in the following text.6 Also included is a discussion of other climate forcing substances.

Carbon Dioxide. CO2 is a naturally occurring gas and a by -product of human activities and is the principal anthropogenic GHG that affects the Earth’s radiative balance. Natural sources of CO 2 include respiration of bacteria, plants, animals, and fungus; evaporation from oceans; volcanic out-gassing; and decomposition of dead organic matter. Human activities tha t generate CO 2 are from the combustion of fuels such as coal, oil, natural gas, and wood and changes in land use.

Methane. CH4 is produced through both natural and human activities. CH 4 is a flammable gas and is the main component of natural gas. Methane is produced through anaerobic (without oxygen) decomposition of waste in landfills, flooded rice fields, animal digestion, decomposition of animal wastes, production and distribution of natural gas and petroleum, coal production, and incomplete fossil fuel combustion.

Nitrous Oxide. N2O is produced through natural and human activities, mainly through agricultural activities and natural biological processes, although fuel burning and other processes also create N 2O. Sources of N 2O include soil cultivation practices (microbial processes in soil and water), especially the use of commercial and organic fertilizers, manure management, industrial processes (such as in nitric acid production, nyl on production, and fossil-fuel-fired power plants), vehicle emissions, and using N2O as a propellant (such as in rockets, racecars, and aerosol sprays).

Fluorinated Gases. Fluorinated gases (also referred to as F -gases) are powerful synthetic GHGs emitted from many industrial processes. Fluorinated gases are commonly used as substitutes for stratospheric ozone-depleting substances (e.g., CFCs, HCFCs, and halons). The most prevalent fluorinated gases include the following:
▪ Hydrofluorocarbons: HFCs are compou nds containing only hydrogen, fluorine, and carbon atoms. HFCs are synthetic chemicals used as alternatives to ozone -depleting substances in serving many industrial, commercial, and personal needs. HFCs are emitted as by -products of industrial processes an d are used in manufacturing.
▪ Perfluorocarbons: PFCs are a group of human -made chemicals composed of carbon and fluorine only.

These chemicals were introduced as alternatives, with HFCs, to the ozone depleting substances. The two main sources of PFCs are p rimary aluminum production and semiconductor manufacturing. Since PFCs have stable molecular structures and do not break down through the chemical processes in the lower atmosphere, these chemicals have long lifetimes, ranging between 10,000 and 50,000 years.

5 California Health and Safety Code, Section 38505, identifies seven GHGs that CARB is responsible for monitoring and regulating to reduce emissions: CO2, CH4, N2O, SF6, HFCs, PFCs, and nitrogen trifluoride (NF3). 6 The descriptions of GHGs are summarized from IPCC Second Assessment Report (IPCC 1995), IPCC Fourth Assessment Report (IPCC 2007), CARB’s Glossary of Terms Used in GHG Inventories (CARB 2015a), and EPA’s Glossary of Climate Change Terms (EPA 2016d).

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▪ Sulfur Hexafluoride: SF6 is a colorless gas soluble in alcohol and ether and slightly soluble in water. SF6 is used for insulation in electric power transmission and distribution equipment, semiconductor manufacturing, the magnesium industry, and as a tracer gas for leak detection. ▪ Nitrogen Trifluoride: Nitrogen trifluoride ( NF3) is used in the manufacture of a variety of electronics, including semiconductors and flat panel displays.

Chlorofluorocarbons. CFCs are synthetic chemicals that have been used as cleaning solvents, refrigerants, and aerosol propellants. CFCs are chemically unreactive in the lower atmosphere (troposphere) and the production of CFCs was prohibited in 1987 due to the chemical destruction of stratospheric O3.

Hydrochlorofluorocarbons. HCFCs are a large group of compounds, whose structure is very close to that of CFCs — containing hydrogen, fluorine, chlorine, and carbon atoms—but including one or more hydrogen atoms. Like HFCs, HCFCs are used in refrigerants and propellants. HCFCs were also used in place of CFCs for some applications; however, their use in general is being phased out.

Black C arbon. Black carbon is a component of fine particulate matter, which has been identified as a leading environmental risk factor for premature death. It is produced from the incomplete combustion of fossil fuels and biomass burning, particularly from older diesel engines and forest fires. Black carbon warms the atmosphere by absorbing solar radiation, influences cloud formation, and darkens the surface of snow and ice, which accelerates heat absorption and melting. Black carbon is a short -lived species that varies spatially, which makes it difficult to quantify the global warming potential. DPM emissions are a major source of black carbon and are TACs that have been regulated and controlled in California for several decades to protect public health. In relati on to declining DPM from CARB’s regulations pertaining to diesel engines, diesel fuels, and burning activities, CARB estimates that annual black carbon emissions in California have reduced by 70% between 1990 and 2010, with 95% control expected by 2020 (CARB 2014b).

Water Vapor. The primary source of water vapor is evaporation from the ocean, with additional vapor generated by sublimation (change from solid to gas) from ice and snow, evaporation from other water bodies, and transpiration from plant leaves. Water vapor is the most important, abundant, and variable GHG in the atmosphere and maintains a climate necessary for life.

Ozone. Tropospheric O3, which is created by photochemical reactions involving gases from both natural sources and human activities , acts as a GHG. Stratospheric O3, which is created by the interaction between solar ultraviolet radiation and molecular oxygen (O 2), plays a decisive role in the stratospheric radiative balance.

Depletion of stratospheric O 3, due to chemical reactions tha t may be enhanced by climate change, results in an increased ground-level flux of ultraviolet-B radiation.

Aerosols. Aerosols are suspensions of particulate matter in a gas emitted into the air through burning biomass (plant material) and fossil fuels. Aerosols can warm the atmosphere by absorbing and emitting heat and can cool the atmosphere by reflecting light.

3.1.3 Global Warming Potential
Gases in the atmosphere can contribute to climate change both directly and indirectly. Direct effects occur when the gas itself absorbs radiation. Indirect radiative forcing occurs when chemical transformations of the substance produce other GHGs, when a gas influences the atmospheric lifetimes of other gases, and/or when a gas affects

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atmospheric processes that alter the radiative balance of the Earth (e.g., affect cloud formation or albedo) (EPA 2017b). The Intergovernmental Panel on Climate Change ( IPCC) developed the global warming potential (GWP) concept to compare the ability of each GHG to trap heat in the atmosphere relative to another gas. The GWP of a GHG is defined as the ratio of the time -integrated radiative forcing from the instantaneous releas e of 1 kilogram of a trace substance relative to that of 1 kilogram of a reference gas (IPCC 2014). The reference gas used is CO 2; therefore, GWP-weighted emissions are measured in MT CO2e.

The CalEEMod ( Version 2020.4.0) assumes that the GWP for CH 4 is 2 5 (so emissions of 1 MT of CH 4 are equivalent to emissions of 25 MT of CO 2), and the GWP for N2O is 298, based on the IPCC Fourth Assessment Report (IPCC 2007).

3.1.4 Sources of Greenhouse Gas Emissions
Anthropogenic GHG emissions worldwide in 2019 (the m ost recent year for which data is available) totaled approximately 52.4 million metric tons (MMT) of CO 2e, excluding land use change and forestry (PBL 2020). Six countries—China, the United States, the Russian Federation, India, Japan, and Brazil —and the E uropean community accounted for approximately 62% of the total global emissions, or approximately 32.5 MMT CO2e (PBL 2020).

Per the EPA Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 –2019, total United States GHG emissions were approximately 6, 558.3 MMT CO 2e in 2019 (EPA 2021) . Overall, from 1990 to 2019, total emissions of CO2 increased by 142.4 MMT CO 2e (2.8%), while total emissions of CH 4 decreased by 117.2 MMT CO2e (15.1%) and emissions of N 2O increased by 4.5 MMT CO 2e (1.0%). During the sam e period, aggregate weighted emissions of hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF 6), and nitrogen trifluoride (NF 3) rose by 86.0 MMT CO 2e (86.3%). From 1990 to 2019, HFCs increased by 128.1 MMT CO2e (275.4%), PFCs decreased by 19.8 MMT CO2e (81.5%), SF6 decreased by 22.9 MMT CO2e (79.5%), and NF3 increased by 0.6 MMT CO2e (1,162.7%).

According to California’s 2000–2019 GHG emissions inventory (2021 edition), California emitted 418.2 MMT CO2e in 2019, including emis sions resulting from out -of-state electrical generation (CARB 2021). The sources of GHG emissions in California include transportation, industrial uses, electric power production from both in-state and out-of- state sources, commercial and residential uses, agriculture, high-GWP substances, and recycling and waste . The California GHG emission source categories and their relative contributions in 2019 are shown in Table 10.

Table 10. Greenhouse Gas Emissions Sources in California Source Category Annual GHG Emissions (MMT CO 2e) Percent of Total a Transportation 166.1 40%
Industrial uses 88.2 21%
Electricity generationb 58.8 14%
Residential and commercial uses 43.8 10%
Agriculture 31.8 8%
High global warming potential substances 20.6 5%
Recycling and waste 8.9 2%
Totals 418.2 100%
Source: CARB 2021.

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Notes: GHG = greenhouse gas; MMT CO2e = million metric tons of carbon dioxide equivalent per year.

Emissions reflect 2019 California GHG inventory.
a Percentage of total has been rounded and total may not sum due to rounding. b Includes emissions associated with imported electricity, which account for 21.7 MMT CO2e.

The City prepared a GHG emissions inventory for year 2012 in the 2020 CAP. The emissions by source category are shown in Table 11.

Table 11. Greenhouse Gas Emissions Sources in San Marcos Source Category Annual GHG Emissions (MT CO 2e) Percent of Total a On-Road Transportation 322,000 54%
Electricity 162,000 27%
Natural Gas 75,000 12%
Solid Waste 15,000 3%
Off-Road Transportation 14,000 2%
Water 9,000 1%
Wastewater 3,000 1%
Totals 599,000 100%
Source: City of San Marcos 2013b.

Notes: GHG = greenhouse gas; MT CO2e = metric tons of carbon dioxide equivalent per year.

Emissions reflect the City’s 2012 GHG inventory.
a Percentage of total has been rounded and total may not sum due to rounding.

3.1.5 Potential Effects of Climate Change
Globally, climate change has the potential to affect numerous environmental resources through uncertain impacts related to future air temperatures and precipitation patterns. The 2014 IPCC Synthesis Report indicated that warming of the climate system is un equivocal, and many of the observed changes since the 1950s are unprecedented. Signs that global climate change has occurred include warming of the atmosphere and ocean, diminished amounts of snow and ice have, and rising sea levels (IPCC 2014).

In California, climate change impacts have the potential to affect sea level rise, agriculture, snowpack and water supply, forestry, wildfire risk, public health, and electricity demand and supply (CCCC 2006). The primary effect of global climate change has been a 0 .2°C (0.36°F) rise in average global tropospheric temperature per decade, determined from meteorological measurements worldwide between 1990 and 2005. Scientific modeling predicts that continued emissions of GHGs at or above current rates would induce more extreme climate changes during the twenty-first century than were observed during the twentieth century. A warming of about 0.2°C (0.36°F) per decade is projected, and there are identifiable signs that global warming could be taking place.

Although climate change is driven by global atmospheric conditions, climate change impacts are felt locally. A scientific consensus confirms that climate change is already affecting California. The average temperatures in California have increased, leading to more extre me hot days and fewer cold nights; shifts in the water cycle have been observed, with less winter precipitation falling as snow, and both snowmelt and rainwater running off earlier in the year; sea levels have risen; and wildland fires are becoming more fr equent and intense due to dry seasons that start earlier and end later (CAT 2010).

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An increase in annual average temperature is a reasonably foreseeable effect of climate change. Observed changes over the last several decades across the western United Sta tes reveal clear signals of climate change.

Statewide average temperatures increased by about 1.7°F from 1895 to 2011, and warming has been greatest in the Sierra Nevada (CCCC 2012). By 2050, California is projected to warm by approximately 2.7°F above 200 0 averages, a threefold increase in the rate of warming over the last century. By 2100, average temperatures could increase by 4.1°F to 8.6°F, depending on emissions levels. Springtime warming —a critical influence on snowmelt—will be particularly pronounce d. Summer temperatures will rise more than winter temperatures, and the increases will be greater in inland California, compared to the coast. Heat waves will be more frequent, hotter, and longer. There will be fewer extremely cold nights (CCCC 2012). A de cline of Sierra Nevada snowpack, which accounts for approximately half of the surface water storage in California, by 30% to as much as 90% is predicted over the next 100 years (CAT 2006).

Model projections for precipitation over California continue to show the Mediterranean pattern of wet winters and dry summers with seasonal, year -to-year, and decade-to-decade variability. For the first time, however, several of the improved climate models shift toward drier conditions by the mid -to-late twenty -first cent ury in Central California, and most notably, in Southern California. By the late century, all projections show drying, and half of them suggest 30-year average precipitation will decline by over 10% below the historical average (CCCC 2012).

3.2 Regulatory Setting

3.2.1 Federal
Infrastructure Investment and Jobs Act . On November 6, 2021, Congress passed the Bipartisan Infrastructure Deal (Infrastructure Investment and Jobs Act), a once-in-a-generation investment in our nation’s infrastructure and competitiveness. This Bipartisan Infrastructure Deal will rebuild America’s roads, bridges and rails, expand access to clean drinking water, ensure every American has access to high -speed internet, tackle the climate crisis, advance environmental justice, and invest in communities that have too often been left behind. The legislation will help ease inflationary pressures and strengthen supply chains by making long overdue improvements for our nation’s ports, airports, rail, and roads. It will drive the creation of good-paying union jobs and grow the economy sustainably and equitably so that everyone gets ahead for decades to come. Combined with the President’s Build Back Framework, it will add on average 1.5 million jobs per year for the next 10 years. It will improve transportation options for millions of Americans to reduce energy use and GHG emission s. It will increase investment in electric vehicle chargers and renewable energy production.

Executive Order on Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability. President Biden will sign an executive order that demonstrates how t he United States will leverage its scale and procurement power to lead by example in tackling the climate crisis. The executive order will reduce emissions across federal operations, invest in American clean energy industries and manufacturing, and create clean, healthy, and resilient communities. The President’s executive order directs the federal government to use its scale and procurement power to achieve five ambitious goals:
• 100 percent carbon pollution-free electricity (CFE) by 2030, at least half of which will be locally supplied clean energy to meet 24/7 demand;

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• 100 percent zero-emission vehicle (ZEV) acquisitions by 2035, including 100 percent zero-emission light- duty vehicle acquisitions by 2027;
• Net-zero emissions from federal procurement no later than 2050, including a Buy Clean policy to promote use of construction materials with lower embodied emissions; • A net-zero emissions building portfolio by 2045, including a 50 percent emissions reduction by 2032; and • Net-zero emissions from overall feder al operations by 2050, including a 65 percent emissions reduction by 2030.

Massachusetts v. EPA. In Massachusetts v. EPA (April 2007), the U.S. Supreme Court directed the EPA administrator to determine whether GHG emissions from new motor vehicles cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to make a reasoned decision. In December 2009, the administrator signed a final rule with the following tw o distinct findings regarding GHGs under Section 202(a) of the federal Clean Air Act:
▪ The Administrator found that elevated concentrations of GHGs —CO2, CH 4, N 2O, HFCs, PFCs, and SF 6—in the atmosphere threaten the public health and welfare of current and f uture generations. This is the “endangerment finding.”
▪ The Administrator further found the combined emissions of GHGs—CO2, CH4, N2O, and HFCs—from new motor vehicles and new motor vehicle engines contribute to the GHG air pollution that endangers public health and welfare. This is the “cause or contribute finding.”
These two findings were necessary to establish the foundation for regulation of GHGs from new motor vehicles as air pollutants under the Clean Air Act.

Energy Independence and Security Act. The Energy Independence and Security Act of 2007 (December 2007), among other key measures, would do the following, which would aid in the reduction of national GHG emissions:

1. Increase the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard requiring fuel producers to use at least 36 billion gallons of biofuel in 2022.

2. Set a target of 35 miles per gallon for the combined fleet of cars and light trucks by model year 2020 and direct National Highway Traffic Safety Adm inistration (NHTSA) to establish a fuel economy program for medium- and heavy-duty trucks and create a separate fuel economy standard for work trucks.

3. Prescribe or revise standards affecting regional efficiency for heating and cooling products and procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances.

Federal Vehicle Standards.

In August 2016, EPA and NHTSA a nnounced the adoption of the phase two program related to the fuel economy and GHG standards for medium- and heavy-duty trucks. The phase two program will apply to vehicles with model year 2018–2027 for certain trailers, and model years 2021–2027 for semi-trucks, large pickup trucks, vans, and all types and sizes of buses and work trucks. The final standards are expected to lower CO 2 emissions by

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approximately 1.1 billion MT and reduce oil consumption by up to 2 billion barrels over the lifetime of the vehicles sold under the program (EPA and NHTSA 2016).

On September 27, 2019, EPA and NHTSA published the “Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule Part One: One National Program.” (84 Fed. Reg. 51,310), which became effective November 26, 2019 . The Part One Rule revokes California’s authority to set its own GHG emissions standards and set zero -emission vehicle mandates in California. The Part One Rule also impacted some of the underlying assumptions in the CARB EMFAC2014 and EMFAC2017 models fo r criteria air pollutant emissions from gasoline light -duty vehicles, which CARB released off -model adjustment factors for EMFAC’s criteria air pollutants estimation on November 20, 2019, primarily for use in federal Clean Air Act conformity demonstration analyses. CARB expects Part Two of these regulations to be adopted by the EPA and NHTSA later in the fall of 2019. However, because CARB does not know the full impacts of these rules until Part Two is released, no off -model adjustments factors are available for GHG emissions at this time. In addition, the EMFAC off -model adjustments have not yet been incorporated into CalEEMod. This issue is evolving as California and 22 other states, as well as the District of Columbia and two cities, filed suit against th e EPA over the vehicle waiver revocation on November 15, 2019 and a petition for reconsideration of the rule was filed on November 26, 2019 by California and 22 other states, the District of Columbia, and four cities. On April 22, 2021, NHTSA issued a noti ce of proposed rulemaking that would repeal those portions of SAFE 1 (including the regulatory text and interpretive statements in the preamble) that found California’s GHG and ZEV mandates preempted by EPCA. One day after NHTSA issued its notice, EPA anno unced its parallel action on SAFE 1. On December 21, 2021, after reviewing all the public comments submitted on NHTSA’s April 2021 Notice of Proposed Rulemaking, NHTSA finalizes the CAFE Preemption rulemaking to withdraw its portions of the so-called SAFE I Rule.

3.2.2 State
The statewide GHG emissions regulatory framework is summarized below by category: state climate change targets, building energy, renewable energy and energy procurement, mobile sources, solid waste, water, and other state regulations and goals. The following text describes executive orders, legislation, regulations, and other plans and policies that would directly or indirectly reduce GHG emissions and/or address climate change issues.

State Climate Change Targets
Executive Order S-3-05. Executive Order (EO) S-3-05 (June 2005) established the following statewide goals: GHG emissions should be reduced to 2000 levels by 2010, GHG emissions should be reduced to 1990 levels by 2020, and GHG emissions should be reduced to 80% below 1990 levels by 2050.

Assembly Bill 32. In furtherance of the goals established in EO S -3-05, the legislature enacted AB 32 (Núñez and Pavley). The bill is referred to as the California Global Warming Solutions Act of 2006 (September 27, 2006). AB 32 provided initial direction on creating a comprehensive multiyear program to limit California’s GHG emissions at 1990 levels by 2020 and initiate the transformations required to achieve the state’s long -range climate objectives.

Executive Order B -55-18. EO B -55-18 (September 2018) establishes a statewide policy for the state to achieve carbon neutrality as soon as possible, and no later t han 2045, and achieve and maintain net negative emissions thereafter. The goal is an addition to the existing statewide targets of reducing the state’s GHG emissions. CARB will work with

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relevant state agencies to ensure that future scoping plans identify and recommend measures to achieve the carbon neutrality goal.

California Air Resources Board’s Climate Change Scoping Plan . One specific requirement of AB 32 was for CARB to prepare a scoping plan for achieving the maximum technologically feasible and cost -effective GHG emission reductions by 2020 (Health and Safety Code Section 38561[a]), and to update the plan at least once every 5 years. In 2008, CARB approved the first scoping plan. The Climate Change Scoping Plan: A Framework for Change (Scoping Plan ) included a mix of recommended strategies that combined direct regulations, market -based approaches, voluntary measures, policies, and other emission reduction programs calculated to meet the 2020 statewide GHG emissions limit and initiate the transformatio ns needed to achieve the state’s long -range climate objectives. The key elements of the Scoping Plan include the following (CARB 2008):

1. Expanding and strengthening existing energy efficiency programs, as well as building and appliance standards.

2. Achieving a statewide renewable energy mix of 33%.

3. Developing a California cap-and-trade program that links with other Western Climate Initiative partner programs to create a regional market system and caps sources contributing 85% of California’s GHG emissions.

4. Establishing targets for transportation-related GHG emissions for regions throughout California, and pursuing policies and incentives to achieve those targets.

5. Adopting and implementing measures pursuant to existing state laws and policies, including California’s clean car standards, goods movement measures, and the Low Carbon Fuel Standard (17 CCR 95480 et seq.).

6. Creating targeted fees, including a public goods charge on water use, fees on high GWP gases, and a fee to fund the administrative costs of the State of California’s long-term commitment to AB 32 implementation.

The Scoping Plan also identified local governments as essential partners in achieving California’s goals to reduce GHG emissions because they have broad influence and, in some cases, exclus ive authority over activities that contribute to significant direct and indirect GHG emissions through their planning and permitting processes, local ordinances, outreach and education efforts, and municipal operations. Specifically, the Scoping Plan encou raged local governments to adopt a reduction goal for municipal operations , and for community emissions to reduce GHGs by approximately 15% from then levels (2008) by 2020. Many local governments developed community - scale local GHG reduction plans based on this Scoping Plan recommendation.

In 2014, CARB approved the first update to the Scoping Plan. The First Update to the Climate Change Scoping Plan: Building on the Framework (First Update) defined the state’s GHG emission reduction priorities for the nex t 5 years, and laid the groundwork to start the transition to the post-2020 goals set forth in EO S-3-05 and EO B-16- 2012. The First Update concluded that California is on track to meet the 2020 target but recommended a 2030 mid-term GHG reduction target be established to ensure a continuum of action to reduce emissions. The First Update recommended a mix of technologies in key economic sector s to reduce emissions through 2050 , including energy demand reduction through efficiency and activity changes; large -scale electrification of on -road vehicles, buildings, and industrial machinery; decarbonizing electricity and fuel supplies; and the rapid market penetration of efficient and clean energy technologies. As part of the First Update, CARB recalculated the state’s 1990 emissions level, using more recent GWPs identified by the IPCC, from 427 MMT CO 2e to 431 MMT CO 2e (CARB 2014).

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In 2015, as directed by EO B-30-15 (discussed below), CARB began working on an update to the Scoping Plan to incorporate the 2030 target of 40% below 1990 levels by 2030 to keep California on its trajectory toward meeting or exceeding the long -term goal of reducing GHG emis sions to 80% below 1990 levels by 2050 as set forth in EO S-3-05. The governor called on California to pursue a new and ambitious set of strategies, in line with the five climate change pillars from his inaugural address, to reduce GHG emissions and prepar e for the unavoidable impacts of climate change. In the summer of 2016, the legislature affirmed the importance of addressing climate change through passage of SB 32.

In December 2017, CARB adopted California’s 2017 Climate Change Scoping Plan (2017 Scoping Plan) for public review and comment (CARB 2017b). The 2017 Scoping Plan builds on the successful framework established in the initial Scoping Plan and First Update while identifying new, technologically feasible and cost-effective strategies that will serve as the framework to achieve the 2030 GHG target as established by SB 32 and define the state’s climate change priorities to 2030 and beyond. The strategies’ commitments include implementing renewable energy and energy efficiency strategies (including the mandates of SB 350), increasing stringency of the Low Carbon Fuel Standard, implementing measures identified in the Mobile Source and Freight Strategies, implementing measures identified in the proposed Short -Lived Climate Pollutant Reduction Strategy, and increasing stringency of SB 375 targets. To fill the gap in additional reductions needed to achieve the 2030 target, it recommends continuing the Cap- and-Trade Program.

For local governments, the 2017 Scoping Plan replaced the initial Scoping Plan’s 1 5% reduction goal with a recommendation to aim for a community-wide goal of no more than 6 MT CO 2e per capita by 2030, and no more than 2 MT CO 2e per capita by 2050, which are consistent with the state’s long -term goals. These goals are also consistent with the Under 2 Memorandum of Understanding (Under 2 2016) and the Paris Agreement, which are developed around the scientifically based levels necessary to limit global warming to below 2°C. The 2017 Scoping Plan recognized the benefits of local government G HG planning (e.g., through CAPs) and provide d more information regarding tools CARB is working on to support those efforts. It also recognize d the CEQA streamlining provisions for project-level review where there is a legally adequate CAP.

The Scoping Plan recommends strategies for implementation at the statewide level to meet the goals of AB 32, SB 32, and the executive orders, and establishes an overall framework for the measures that will be adopted to reduce California’s GHG emissions. A project is con sidered consistent with the statutes and executive orders if it meets the general policies in reducing GHG emissions to facilitate the achievement of the state’s goals and does not impede attainment of those goals. A project would be consistent if it will further the objectives and not obstruct their attainment.

CARB presently is preparing the 2022 Scoping Plan Update , which will assess progress towards achievement of the state’s 2030 reduction target and lay out a path for the state’s achievement of carbon neutrality by 2045.

CARB has held a number of public workshops to provide information on the plan update and solicit feedback from stakeholders. A draft plan has not yet been released for public review and comment.

Executive Order B-30-15. EO B-30-15 (April 2015) identified an interim GHG reduction target in support of targets previously identified under EO S -3-05 and AB 32. EO B -30-15 specifically set an interim target goal of reducing statewide GHG emissions to 40% below 1990 levels by 2030 t o keep California on its trajectory toward meeting or exceeding the long-term goal of reducing statewide GHG emissions to 80% below 1990 levels by 2050, as set forth in EO S-3-05. To facilitate achievement of this goal, EO B-30-15 called for an update to CARB’s Scoping Plan to express the 2030 target in terms of MMT CO 2e. The executive order also called for state agencies to continue

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to develop and implement GHG emissions reduction programs in support of the reduction targets. Sector -specific agencies in tr ansportation, energy, water, and forestry were required to prepare GHG reduction plans by September 2015, followed by a report on action taken in relation to these plans in June 2016. EO B-30-15 did not require local agencies to take any action to meet the new interim GHG reduction target.

Senate Bill 32 and Assembly Bill 197 . SB 32 and AB 197 (enacted in 2016) are companion bills that set a new statewide GHG reduction targets , made changes to CARB’s membership and increase d legislative oversight of CARB’s climate change -based activities , and expand ed dissemination of GHG and other air -quality-related emissions data to enhance transparency and accountability. More specifically, SB 32 codified the 2030 emissions reduction goal of EO B -30-15 by requiring CARB to ensure that statewide GHG emissions are reduced to 40% below 1990 levels by 2030. AB 197 established the Joint Legislative Committee on Climate Change Policies, consisting of at least three members of the Senate and three members of the Assembly to prov ide ongoing oversight over implementation of the state’s climate policies. AB 197 also added two members of the Legislature to CARB as nonvoting members; requires CARB to make available and update (at least annually via its website) emissions data for GHGs, criteria air pollutants, and TACs from reporting facilities; and requires CARB to identify specific information for GHG emissions reduction measures when updating the Scoping Plan.

Senate Bill 605 and Senate Bill 1383 . SB 605 (2014) required CARB to comp lete a comprehensive strategy to reduce emissions of short -lived climate pollutants in the state, and SB 1383 (2016) required CARB to approve and implement that strategy by January 1, 2018. SB 1383 also establishe d specific targets for the reduction of short-lived climate pollutants (40% below 2013 levels by 2030 for CH 4 and HFCs, and 50% below 2013 levels by 2030 for anthropogenic black carbon), and provide d direction for reductions from dairy and livestock operations and landfills. The Short -Lived Climate Pollutants Reduction Strategy was approved by CARB in March 2017, and lays out a range of options to reduce short -lived climate pollutant emissions in California, including regulations, incentives, and other market-supporting activities.

Building Energy
Title 24, Part 6. Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and regulate California’s building standards. Although not initially promulgated to reduce GHG emissions, Part 6 of Title 24 specifically established Building Energy Efficiency Standards that are designed to ensure new and existing buildings in California achieve energy efficiency and preserve outdoor and indoor environmental quality. These energy efficiency standards are reviewed every few years by the Building Standards Commission and CEC, and revised if necessary (California Public Resources Code [PRC] Section 25402[b][1]). The regulations receive input from members of industry and the public, with the goal of “reducing of wasteful, uneconomic, inefficient, or unnecessary consumption of energy” (PRC Section 25402). These regulations are carefully scrutinized and analyzed for technological and economic feasibility (PRC Section 25402[d]) and cost effectiveness (PRC Sections 25402[b][2] and [b][3]). As a result, these standards save energy, increase electricity supply reliability, increase indoor comfort, avoid the need to construct new power plants, and help preserve the environment.

The 2019 Title 24 standards are the currently applicable building energy efficiency standards, and became effective on January 1, 2020. The 2019 Title 24 Building Energy Efficiency Standards will further reduce energy used and associated GHG emissions compared to prior standards. In general, single-family residences built to the 2019 standards are anticipated to use approximately 7% less energy due to energy efficiency measures than those built to the 2016 standards; once rooftop solar electricity generation is factored in, single-family residences built under the 2019 standards will use approximately 53% less energy than those under the 2016 standards (CEC 2018). Nonresidential buildings built

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to the 2019 standards are anticipated to use an estimated 30% less energy than those built to the 2016 standards (CEC 2018). The project is subject to the nonresidential standards due to the number of stories. The project’s apartments and affordable flats are subject to the nonresidential standards while the rowhomes and villas are subject to the residential standards.

On August 11, 2021, the CEC adopted the 2022 Energy Code. In December 2021, it was approved by the California Building Standards Commission for inclusion into the California Building Standards Code. The 2022 Energy Code encourages efficient electric heat pumps, e stablishes electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more. Buildings whose permit applications are applied for on or after January 1, 2023, must comply with the 2022 Energy Code.

Title 24, Part 11. In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as California’s Green Building Standards (CALGreen), and establishes minimum mandatory standards and voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California E nergy Code requirements), water conservation, material conservation, and interior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground-up, new construction of commercial, low-rise residential and state-owned buildings, schools, and hospitals. The CALGreen 2019 standards, which are the current standards, became effective January 1, 2020.

Title 20. Title 20 of the California Code of Regulations requires manufacturer s of appliances to meet state and federal standards for energy and water efficiency. Performance of appliances must be certified through the CEC to demonstrate compliance with standards. New appliances regulated under Title 20 include refrigerators, refrigerator-freezers, and freezers; room air conditioners and room air -conditioning heat pumps; central air conditioners; spot air conditioners; vented gas space heaters; gas pool heaters; plumbing fittings and plumbing fixtures; fluorescent lamp ballasts; lamps; emergency lighting; traffic signal modules; dishwaters; clothes washers and dryers; cooking products; electric motors; low voltage dry -type distribution transformers; power supplies; televisions and consumer audio and video equipment; and battery charge r systems. Title 20 presents protocols for testing for each type of appliance covered under the regulations, and appliances must meet the standards for energy performance, energy design, water performance, and water design. Title 20 contains three types of standards for appliances: federal and state standards for federally regulated appliances, state standards for federally regulated appliances, and state standards for non-federally regulated appliances.

Assembly Bill 1109. Enacted in 2007, AB 1109 require d the CEC to adopt minimum energy efficiency standards for general -purpose lighting to reduce electricity consumption by 50% for indoor residential lighting and by 25% for indoor commercial lighting.

SB 1. SB 1 (Murray) (August 2006) established a $3 billion rebate program to support the goal of the state to install rooftop solar energy systems with a generation capacity of 3,000 megawatts through 2016. SB 1 added sections to the Public Resources Code, inclu ding Chapter 8.8 (California Solar Initiative), that require building projects applying for ratepayer -funded incentives for photovoltaic systems to meet minimum energy efficiency levels and performance requirements. Section 25780 established that it is a g oal of the state to establish a self-sufficient solar industry. The goals included establishing solar energy systems as a viable mainstream option for homes and businesses within 10 years of adoption, and placing solar energy systems on 50% of new

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homes within 13 years of adoption. SB 1, also termed “Go Solar California,” was previously titled “Million Solar Roofs.”
California AB 1470 (Solar Water Heating). This bill established the Solar Water Heating and Efficiency Act of 2007. AB 1470 makes findings and declarations of the Legislature relating to the promotion of solar water heating systems and other technologies that reduce natural gas demand. AB 1470 defines several terms for purposes of the act. The bill required a commission to evaluate the data avail able from a specified pilot program, and to design and implement a program of incentives for the installation of 200,000 solar water heating systems in homes and businesses throughout the state by 2017.

Renewable Energy and Energy Procurement. SB 1078 (200 2) established the Renewables Portfolio Standard (RPS) program, which requires an annual increase in renewable generation by the utilities. Initially, the RPS required utilities to obtain 20% of their power from renewable sources by 2010. SB X1-2 (2011) su bsequently expanded the RPS by establishing that 33% of the total electricity sold to retail customers in California per year by December 31, 2020, and in subsequent years, be secured from qualifying renewable energy sources. SB 350 (2015) further expanded the RPS by establishing that 50% of the total electricity sold to retail customers in California per year by December 31, 2030, be secured from qualifying renewable energy sources. And SB 100 (2018) further accelerated the RPS, requiring achievement of a 50% RPS by December 31, 2026, and a 60% RPS by December 31, 2030. SB 100 also established a new state policy goal that calls for eligible renewable energy resources and zero -carbon resources to supply 100% of electricity retail sales and 100% of electricity procured to serve all state agencies by December 31, 2045.

Under the program, a renewable electrical generation facility is one that uses biomass, solar thermal, photovoltaic, wind, geothermal, fuel cells using renewable fuels, small hydroelectric gener ation of 30 megawatts or less, digester gas, municipal solid waste conversion, landfill gas, ocean wave, ocean thermal, or tidal current, and that meets other specified requirements with respect to its location.

Mobile Sources
CARB’s Mobile Source Strategy. On May 16, 2016, CARB released the 2016 Mobile Source Strategy that demonstrates how the state can simultaneously meet air quality standards, achieve GHG emission reduction targets, decrease health risk from transportation em issions, and reduce petroleum consumption over the next fifteen years. The actions contained in the 2016 Mobile Source Strategy will deliver broad environmental and public health benefits, as well as support much needed efforts to modernize and upgrade tra nsportation infrastructure, enhance system-wide efficiency and mobility options, and promote clean economic growth in the mobile sector. The 2016 Mobile Source Strategy would also result in a 45 percent reduction in GHG emissions, and a 50 percent reduction in the consumption of petroleum-based fuels (CARB 2016).

On October 28, 2021, CARB received and heard the 2020 Mobile Source Strategy, which continues and builds upon the foundation established by the 2016 Mobile Source Strategy. The 2020 Mobile Source Strategy, if implemented, would achieve a 76 percent reduction in GHG emissions from 2020 levels from mobile sources by 2045, as largely attributable to transitioning towards a zero-emissions fleet. Moving forward, CARB anticipates that the programs and concepts in the 2020 Mobile Source Strategy will be incorporated into other aspects of CARB’s regulatory and planning frameworks.

State Vehicle Standards. AB 1493 (July 2002) was enacted in response to the transportation sector accounting for more than one -half of California’s CO 2 emissions. AB 1493 required CARB to set GHG emission standards for

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passenger vehicles, light-duty trucks, and other vehicles determined by the state board to be vehicles that are primarily used for noncommercial personal transportati on in the state. AB 1493 required that CARB set GHG emission standards for motor vehicles manufactured in 2009 and all subsequent model years. CARB adopted the standards in September 2004.

As explained under the “Federal Vehicle Standards” description abo ve, the EPA and NHTSA approved the SAFE Vehicles Rule Part One and Two, which revoked California’s authority to set its own GHG emissions standards and set zero-emission vehicle mandates in California. Because the EPA rule is the subject of pending legal challenges, and because President Biden issued an executive order to review Part One and Part Two, this analysis used the best available information at this time, as set forth in EMFAC and assumed in CalEEMod.

The Advanced Clean Cars program (January 2012) is an emissions-control program for model years 2015 through 2025. The program combines the control of smog - and soot-causing pollutants and GHG emissions into a single coordinated package. The package includes elements to reduce smog -forming pollution, reduce GHG emissions, promote clean cars, and provide the fuels for clean cars. To improve air quality, CARB implemented new emission standards to reduce smog -forming emissions beginning with 2015 model year vehicles. It is estimated that by 2025, cars will emit 75% less smog -forming pollution than the average new car sold in 2012. To reduce GHG emissions, CARB, in conjunction with the EPA and NHTSA, adopted new GHG standards for model year 2017 to 2025 vehicles; the new standards are estimated to reduce GHG emissions by 34% in 2025. The zero -emissions vehicle (ZEV) program will act as the focused technology of the Advanced Clean Cars program by requiring manufacturers to produce increasing numbers of ZEVs and plug -in hybrid electric vehicles in the 2018 to 20 25 model years.

Executive Order S-1-07. Issued on January 18, 2007, EO S -1-07 sets a declining Low Carbon Fuel Standard for GHG emissions measured in CO 2e grams per unit of fuel energy sold in California. The initial target of the Low Carbon Fuel Standard was to reduce the carbon intensity of California passenger vehicle fuels by at least 10% by 2020. The Low Carbon Fuel Standard was subsequently amended in 2018 to require a 20% reduction in carbon intensity by 2030. This new requirement aligns with the Ca lifornia’s overall 2030 target of reducing climate changing emissions to 40% below 1990 levels by 2030, set by SB 32. CARB has adopted implementing regulations for both the 10% and 20% carbon intensity reduction targets.

Senate Bill 375 . SB 375 (2008) addresses GHG emissions associated with the transportation sector through regional transportation and sustainability plans. SB 375 required CARB to adopt regional GHG reduction targets for the automobile and light -truck sector for 2020 and 2 035. Regional metropolitan planning organizations are then responsible for preparing a Sustainable Communities Strategy (SCS) within their Regional Transportation Plan (RTP). The goal of the SCS is to establish a forecasted development pattern for the regi on that, after considering transportation measures and policies, will achieve, if feasible, the GHG reduction targets. If an SCS is unable to achieve the GHG reduction target, a metropolitan planning organization must prepare an Alternative Planning Strate gy demonstrating how the GHG reduction target would be achieved through alternative development patterns, infrastructure, or additional transportation measures or policies.

Pursuant to California Government Code Section 65080(b)(2)(K), a n SCS does not reg ulate the use of land; supersede the land use authority of cities and counties; or require that a city’s or county’s land use policies and regulations, including those in a general plan, be consistent with it. Nonetheless, SB 375 makes regional and local planning agencies responsible for developing those strategies as part of the federally required metropolitan transportation planning process and the state-mandated housing element process.

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In 2010, CARB adopted the SB 375 targets for the regional metropoli tan planning organizations. The targets adopted for SANDAG in 2010 are a 7% reduction in per -capita passenger-vehicle GHG emissions by 2020 and a 13% reduction by 2035, measured relative to 2005 GHG emissions. In 2018, CARB adopted the second round of SB 3 75 reduction targets, and increased SANDAG’s 2020 target to a 15% reduction in per -capita passenger- vehicle GHG emissions, and the 2035 target to a 19% reduction using the same 2005 baseline.

Senate Bill 350. In 2015, SB 350 – the Clean Energy and Pollution Reduction Act – was enacted into law. As one of its elements, SB 350 establishes a statewide policy for widespread electrification of the transportation sector, recognizing that such electrification is required for achievement of the state’s 2030 and 205 0 reduction targets (see California Public Utilities Code, Section 740.12).

AB 1236. AB 1236 (October 2015) (Chiu) required a city, county, or city and county to approve an application for the installation of electric vehicle charging stations, as defined, through the issuance of specified permits unless the city or county makes specified written findings based on substantial evidence in the record that the proposed installation would have a specific, adverse impact upon the public health or safety, and the re is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact. AB 1236 provided for appeal of that decision to the planning commission, as specified. The bill provided that the implementation of consistent statewide standards to achieve the timely and cost -effective installation of electric vehicle charging stations is a matter of statewide concern. The bill required electric vehicle charging stations to meet specified standards. AB 1236 required a city, county, or city and count y with a population of 200,000 or more residents to adopt an ordinance, by September 30, 2016, that created an expedited and streamlined permitting process for electric vehicle charging stations. The bill also required a city, county, or city and county wi th a population of fewer than 200,000 residents to adopt this ordinance by September 30, 2017.

Executive Order B-16-12. EO B-16-12 (2012) directs state entities under the Governor’s direction and control to support and facilitate development and distributi on ZEVs. On a statewide basis, EO B -16-12 also establishes a GHG emissions reduction target from the transportation sector equaling 80% less than 1990 levels by 2050. In furtherance of this executive order, the Governor convened an Interagency Working Grou p on ZEVs that has published multiple reports regarding the progress. It ordered CARB, CEC, the California Public Utilities Commission, and other relevant agencies to work with the Plug -In Electric Vehicle Collaborative and the California Fuel Cell Partnership to establish benchmarks to help achieve goals by 2015, 2020, and 2025. This directive did not apply to vehicles that have special performance requirements necessary for the protection of the public safety and welfare.

Executive Order N-79-20. EO N-79-20 (2020) sets the goal for the State that 100 percent of in-state sales of new passenger cars and trucks will be zero -emission by 2035 . EO -N-79-20 also sets goals for transition to 100 percent zero emission all medium- and heavy-duty vehicles by 2045, zero emission drayage trucks by 2035, and zero emission off -road vehicles and equipment by 2035, where feasible. Among other directives to further this executive order, for passenger cars and trucks, the Governor directed CARB to develop and propose regulat ions requiring increasing volumes of new zero-emission vehicles sold in the State towards the target of 100 percent of in-state sales by 2035. The Governor also directed the Governor’s Office of Business and Economic Development to develop a Zero-Emissions Vehicle Market Development Strategy, which was completed in February 2021 7. The executive order also directs updates and assessments to ensure zero-emission vehicle infrastructure is in place to support the levels of electric vehicle adoption required by the order.

7 https://static.business.ca.gov/wp-content/uploads/2021/02/ZEV_Strategy_Feb2021.pdf

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Small Offroad Engines
The CARB approved a measure on December 9, 2021 that will require most newly manufactured small off -road engines such as those found in leaf blowers, lawn mowers and other equipment be zero emission starting in 2024. Portable generators, including those in recreational vehicles, would be required to me et more stringent standards in 2024 and meet zero-emission standards starting in 2028.

Solid Waste
AB 939 and AB 341. In 1989, AB 939, known as the Integrated Waste Management Act ( PRC Sections 40000 et seq.), was passed because of the increase in waste st ream and decrease in landfill capacity. The statute established the California Integrated Waste Management Board, which oversees a disposal reporting system. AB 939 mandated a reduction of waste being disposed of where jurisdictions were required to meet d iversion goals of all solid waste through source reduction, recycling, and composting activities of 25% by 1995 and 50% by 2000.

AB 341 (Chapter 476, Statutes of 2011 [Chesbro]) amended the California Integrated Waste Management Act of 1989 to include a provision declaring that it is the policy goal of the state that not less than 75% of solid waste generated be source-reduced, recycled, or composted by 2020, and annually thereafter. In addition, AB 341 required the California Department of Resources Recycling and Recovery (CalRecycle) to develop strategies to achieve the state’s policy goal.

CalRecycle conducted several general stakeholder workshops and several focused workshops, and in August 2015 published a discussion document titled AB 341 Report to the Legislature, which identified five priority strategies that CalRecycle believed would assist the state in reaching the 75% goal by 2020, legislative and regulatory recommendations, and an evaluation of program effectiveness (CalRecycle 2012).

SB 1383. Beginning in 2022, SB 1383 requires every jurisdiction to provide organic waste collection services to all residents and businesses. Jurisdictions can select from a variety of organic waste collection services to match their unique communities and local infrastructure, while producing clean streams of organic feedstock that can be recycled into high-quality, marketable recycled products, including compost, renewable natural gas, electricity, and paper.

Jurisdictions will educate all residents and businesses about collection requirements, including what materials to put in curbside bins. Education to residents and businesses may vary by jurisdiction and educational content may be provided electronically, through hard copy materials, or through direct outreach.

Water
Executive Order B-29-15. In response to the ongoing drought in California, EO B -29-15 (April 2015) set a goal of achieving a statewide reduction in potable urban water usage of 25% relative to water use in 2013. The term of the executive order extended through February 28, 2016, although many of the directives have since become permanent water-efficiency standards and requirements. The executive order includes specific directives that set strict limits on water usage in the state. In response to EO B-29-15, the California Department of Water Resources modified and adopted a revised version of the Model Water Efficient Landscape Ordinance that, among other changes, significantly increase d the requirements for landscape water use efficiency and broaden ed its applicability to include new development projects with smaller landscape areas.

EO B-37-16. Issued May 2016, EO B -37-16 directed the State Water Resources Control Board to adjust emergency water conservation regulations through the end of January 2017 to reflect differing water supply

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conditions across the state. The State Water Resources Control Board also developed a proposal to achieve a mandatory reduction of potable urban water usage that builds off the mandatory 25% reduction called for in EO B- 29-15. The State Water Resources Control Board and Department of Water Resources will develop new, permanent water use targets that build on the existing state law requirements that the state achieve 20% reduction in urban water usage by 2020. EO B-37-16 also specifies that the State Water Resources Control Board permanently prohibit water -wasting practices such as hosing off sidewalks, driveways, and other hardscapes; washing automobiles with hoses not equipped with a shut -off nozzle; using non -recirculated water in fountain s and other decorative water feature s; watering lawns in a manner that causes runoff, or within 48 hours after measurable precipitation; and irrigating ornamental turf on public street medians.

Other State Regulations and Goals
SB 97. SB 97 (Dutton) (August 2007) directed the Governor’s Office of Planning and Research to develop guidelines under CEQA for the mitigation of GHG emissions. The California Natural Resources Agency (CNRA) then adopted the CEQA Guidelines amendments in December 2009, which became effective in March 2010. The CEQA Guidelines were subsequently amended in 2018, which changes became effective on December 28, 2018.

Under the amended CEQA Guidelines, a lead agency has the discretion to determine whether to use a quantitative or qualitative analysis or apply performance standards to determine the significance of GHG emissions resulting from a particular project (14 CCR 15064.4 [a]). The CEQA Guidelines provide that a lead agency should also consider the extent to which a project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]). The CEQA Guidelines also allow a lead agency to consider feasible means of m itigating the significant effects of GHG emissions, including reductions in emissions through the implementation of project features; off-site measures, including offsets that are not otherwise required; measures in an existing plan or mitigation program; measures that sequester GHGs; etc. (14 CRR 15126.4[c]) . The adopted amendments do not establish a GHG emission s threshold, instead allowing a lead agency to develop, adopt, and apply its own thresholds of significance or those developed by other agencies o r experts (14 CCR 15064.7). The CEQA Guidelines also permit using environmental standards – i.e., an applicable and relevant quantitative, qualitative or performance requirement found in an ordinance, resolution, rule, regulation, order, plan or other environmental requirement that has been adopted for the purpose of environmental protection – as a threshold of significance to promote consistency in significance determinations (14 CCR 15064.7 [d]).

With respect to GHG emissions, the CEQA Guidelines state in Section 15064.4(a) that lead agencies should “make a good faith effort, to the extent possible on scientific and factual data, to describe, calculate or estimate” GHG emissions. The CEQA Guidelines note that an agency may identify emiss ions by either quantify ing the emissions resulting from a project or by relying on “qualitative analysis or other performance -based standards” (14 CCR 15064.4 [a]). Section 15064.4(b) states that the lead agency should focus on the reasonably foreseeable incremental contribution of the project’s emissions to the effects of climate change. The analysis should consider a timeframe appropriate for the project, and must reasonably reflect evolving scientific knowledge and state regulatory schemes (14 CCR 15064.4[b]).

Section 15183.5 of the CEQA Guidelines allows agencies to tier from qualified GHG reduction plans developed in accordance with subsection (b). Specifically, the GHG reduction plan must quantify greenhouse gas em issions, both existing and projected over a specified time period, resulting from activities within a defined geographic area; establish a level, based on substantial evidence, below which the contribution to greenhouse gas emissions

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from activities covered by the plan would not be cumulatively considerable; identify and analyze the greenhouse gas emissions resulting from specific actions or categories of actions anticipated within the geographic area; specify measures or a group of measures, including perf ormance standards, that substantial evidence demonstrates, if implemented on a project -by-project basis, would collectively achieve the specified emissions level; establish a mechanism to monitor the plan’s progress toward achieving the level and to require amendment if the plan is not achieving specified levels; and be adopted in a public process following environmental review.

Executive Order S-13-08. EO Order S -13-08 (November 2008) is intended to hasten California’s response to the impacts of global climate change, particularly sea-level rise. Therefore, the executive order directs state agencies to take specified actions to assess and plan for such impacts. The final 2009 California Climate Adaptation Strategy report was issued in December 2009 (CNRA 20 09b), an update, Safeguarding California: Reducing Climate Risk, followed in July 2014 (CNRA 2014) as well as in 2018, Safeguarding California Plan: 2018 Update California’s Climate Adaptation Strategy (CNRA 2018). The draft 2021 California Climate Adaptat ion Strategy was released for public comment on October 18, 2021 and closed on November 17, 2021 . To assess the state’s vulnerability, the report summarizes key climate change impacts to the state for the following areas: agriculture, biodiversity and habi tat, emergency management, energy, forestry, ocean and coastal ecosystems and resources, public health, transportation, and water.

3.2.3 Local

SANDAG RTP/SCS
SANDAG completed and adopted its 2050 RTP/SCS in October 2011. In November 2011, CARB, by resolut ion, accepted SANDAG’s GHG emissions quantification analysis and determination that, if implemented, the SCS would achieve CARB’s 2020 and 2035 GHG emissions reduction targets for the region.

In October 2015, SANDAG adopted San Diego Forward: The Regional Plan (SANDAG 2015). Like the 2050 RTP/SCS, San Diego Forward: Regional Plan meets CARB’s 2020 and 2035 reduction targets for the region (SANDAG 2015). In December 2015, CARB, by resolution, accepted SANDAG’s GHG emissions quantification analysis and determination that, if implemented, the SCS would achieve CARB’s 2020 and 2035 GHG emissions reduction targets for the region.

The 2021 Regional Plan, adopted by SANDAG on December 10, 2021, provides a long-term blueprint for the San Diego region that seeks to meet regulatory requirements, address traffic congestion, and create equal access to jobs, education, healthcare, and other community resources (SANDAG 2021). The plan is the result of years of planning, data analysis, and community engagement to reimagin e the San Diego region with a transformative transportation system, a sustainable pattern of growth and development, and innovative demand and management strategies.

The 2021 Regional Plan includes a Sustainable Communities Strategy (SCS), as required by C alifornia Senate Bill 375 (Steinberg, 2008) (SB 375), for the San Diego region. This SCS describes coordinated transportation and land use planning that exceeds the state’s target for reducing per capita GHG emissions set by CARB. The state - mandated target is a 19% reduction—compared with 2005—in per capita GHG emissions from cars and light -duty trucks by 2035. The 2021 Regional Plan achieves a 20% reduction by then.

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The 2021 Regional Plan also puts forth a forecasted development pattern that is driven by r egional goals for sustainability, mobility, housing affordability, and economic prosperity.

City of San Marcos Climate Action Plan. The City adopted its currently applicable CAP on December 8, 2020 (City of San Marcos 2020b). The CAP acts as a roadmap to address challenges of climate change within the City. The CAP builds on the efforts and strategies identified in the City’s 2013 CAP and esta blishes GHG emission reduction targets and identifies achievable, locally based actions to reduce GHG emissions from municipal and community activities. The CAP includes a baseline GHG emissions inventory for 2012, GHG emissions forecasts for 2020 and 2030 , local GHG emissions reduction strategies and measures to help the City achieve the 2030 target, climate adaptation measures for the City, and implementation and monitoring mechanisms to ensure the City’s measures and targets are achieved. The CAP establi shes GHG emissions reduction goals of 4% below 2012 levels by 2020 and 42% below 2012 levels by 2030 (City of San Marcos 2020b).

The CAP was prepared in accordance with the requirements within CEQA Guidelines Section 15183.5, and the CAP Consistency Check list is used in this analysis to evaluate the proposed project’s significance with respect to GHG emissions. As provided in the Checklist, projects that are consistent with the CAP “may rely on the CAP for the cumulative impact analysis of GHG emissions” and “may be determined not to be cumulatively considerable” (City of San Marcos 2020b) City of San Marcos General Plan . The City’s General Plan (City of San Marcos 2012) includes various policies related to reducing GHG emissions. Applicable policies inclu de the following:

Land Use and Community Design Element
Goal LU-1: Achieve a balanced distribution and compatible mix of land uses to meet the present and future needs of all residents and the business community.

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.

Goal LU-2 Promote development standards and land use patterns that encourage long -term environmental sustainability.

Policy LU-2.1: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use.

Policy LU-2.3: Require the incorporation of green building practices, technologies, and strategies into development projects per code standards
Policy LU -2.5: Promote landscaping (e.g., native, drought tolerant plants) that minimizes demands on water supply.

Policy LU-2.7: Promote the instillation of trees to red uce the urban heat -island effect and green infrastructure to reduce storm water runoff.

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.

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Mobility Element
Policy M-1.3: Require new developments to prepare and implement Transportation Demand Management (TDM) programs to minimize vehicle trip generation and promote alternative modes of travel within the City.

Goal M-3: Promote and encourage use of alternative transportation modes, including transit, bicycles, neighborhood electric vehicles (NEVs), and walking, within the City.

Policy M-3.1: Develop an integrated, multimodal circulation system that accommodates transit, bicycles, pedestrians, and vehicles; provides opportunities to reduce air pollution and GHG emissions; and reinforces the role of the street as a public space that unites the City.

Conservation and Open Space Element
Goal COS-4: Improve regional air quality and reduce greenhouse gas emissions that contribute to climate change.

Policy COS-4.5: Encourage energy conservation and the use of alternative energy sources within the community.

Policy COS-4.6: Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure and equipment.

As detailed in response to Threshold #2 below, the project would be consistent with the applicable goals and policies pertaining to greenhouse gasses.

3.3 Significance Criteria and Methodology

3.3.1 Thresholds of Significance
The State of California has developed guidelines to address the significance of greenhouse gas emissions impacts that are containe d in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). Appendix G provides that a project would have a significant environmental impact if it would:

1. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impac t on the environment

2. Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

Neither the State of California nor the SDAPCD has adopted emission -based thresholds of significance for GHG emissions under CEQA.

The CEQA Guidelines provide that in determining the significance of impacts from GHG emissions, an agency may consider the extent to which the project complies with a local plan for the reduction or mitigation of GHG emissions. (See CEQA Guidelines Sections 15064.4(b)(3), 15183.5.). As indicated above, the City has adopted such a plan. Accordingly, for purposes of GHG Threshold 1, the project’s GHG emissions are assessed by evaluating the project’s consistency with the CAP, which is discussed below in detail.

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For purposes of GHG Threshold 2, the project is assessed based on its potential to conflict with the City’s CAP, SANDAG’s Regional Plan, and CARB’s Scoping Plan. The Regional Plan and Scoping Plan goals and measures are analyzed against the project as part of the consistency analysis. The potential for the project to conflict with these plans is addressed in detail below.

City of San Marcos Climate Action Plan Significance Criteria The City adopted an updated CAP on December 8, 2020. The CAP outlines strategies and measures that the City will undertake to achieve its proportional share of State GHG emissions reduction targets. The CAP is a plan for the reduction of GHG emissions in accordanc e with California Environmental Quality Act (CEQA) Guidelines Section 15183.5. Pursuant to CEQA Guidelines Sections 15064(h)(3), 15130(d), and 15183(b), a project’s incremental contribution to a cumulative GHG emissions effect may be determined not to be c umulatively considerable if it complies with the requirements of the CAP. The City has also developed a CAP Consistency Checklist (Checklist), in conjunction with the CAP, to provide a streamlined review process for proposed new development projects that are subject to discretionary review and trigger environmental review pursuant to CEQA.

A GHG screening threshold of 500 MT CO 2e per year is established for new development projects in order to determine if a project would need to demonstrate consistency wit h the CAP through the Checklist. Projects that are projected to emit fewer than 500 MT CO 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. For proposed projects at or above the screening threshold of 500 MT CO 2e, applicants are required to complete the CAP Consistency Checklist, which is meant to provide a streamlined review process for proposed new development projects that are subject to discretionary review and require environmental review pursuant to CEQA. A properly completed Checklist documents how a proposed project complies with the CAP, and in so doing, demonstrates that the project’s contribution to climate chan ge impacts is not cumulatively considerable. The City also developed a service population threshold for the CAP to show that projects are consistent with GHG reduction measures. The City determined that a GHG threshold of 2.1 MT CO 2e per service population per year (SP/yr) would be consistent with GHG emissions within the CAP.

3.3.2 Approach and Methodology

3.3.2.1 Construction
CalEEMod Version 2020.4.0 was used to estimate potential project -generated GHG emissions during construction. Construction of the project would result in GHG emissions primarily associated with use of off -road construction equipment, on-road hauling and vendor (material delivery) trucks, and worker vehicles. All details for construction criteria air pollutants discussed in Section 2. 4.2, Approach and Methodology (including Section

2.4.2.1, Construction), are also applicable for the estimation of construction-related GHG emissions. As such, see Section 2. 4.2.1 for a discussion of project-generated construction emissions calculation methodology and assumptions.

Existing Land Use Designation
To compare the GHG emissions intensity of the proposed project and the land use built under the existing land use designation , the following section summarizes the construction methodology for the existing land use designation. Construction assumptions, including timing, phasing, equipment type and quantity, a nd worker and

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vendor truck trips, were based on the maximum allowed buildout of the existing land use designation for the site.

For the Commercial (C) zoning, consistent with existing land use alternative, it would include a 69,000 square feet of grocery store and gas station uses, as well as 23,000 square feet of office space. This alternative would include 276 parking spaces. An assumption of 10 fueling positions (5 pumps) was made for calculation purposes.

Default values provided by CalEEMod were used where zoning information was not available. For purposes of estimating GHG emissions, it was assumed that construction of the land use built under the existing land use designation would commence in December 20238 and would end in December 2024. Construction of the land use built under the existing land use designation is anticipated to occur in five phases. Accordingly, five phases consisting of site preparation, grading, building construction, paving, and architectural coating were assumed. The analysis contained herein is based on the following assumptions (the duration of phases is approximate):
▪ Site Preparation: 1 week (December 2023)
▪ Grading: 1 week (December 2023)
▪ Building Construction: 11 months (December 2023 – November 2024) ▪ Paving: 1 month (November 2024)
▪ Architectural Coating: 1 month (December 2024)
The construction equipment mix used for estimating the construction emissions of the existing land use designation is based on CalEEMod defaults and is shown in Table 1 2, Construction Scen ario Assumptions – Existing Land Use Designation. For worker and vendor truck trips, the default CalEEMod assumptions for one -way trips were rounded up to the nearest even number to account for whole round trips. For this analysis, it was generally assumed that heavy construction equipment would operate 5 days a week (22 days per month) during project construction. Grading activities were anticipated to be minimal for the land use built under the existing land use designation; therefore, no haul trucks would be required to import or export material.

Table 12. Construction Scenario Assumptions – Existing Land Use Designation Construction Phase
One -Way Trips
Equipment Quantity
Hours
Per Day
Daily
Workers
Daily
Vendor
Trucks
Total
Haul
Trucks
Site Preparation 18 0 0 Rubber Tired Dozers 3 8
Tractors/Loaders/Backhoes 4 8
Grading 16 0 0 Excavators 1 8
Graders 1 8
Rubber Tired Dozers 1 8
Tractors/Loaders/Backhoes 3 8
Building Construction 76 34 0 Cranes 1 7
Forklifts 3 8

8 The analysis assumes a construction start date of June 2023, which represents the earliest date construction would initiate (although unlikely). Assuming the earliest start date for construction represents the worst -case scenario for emissions because equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in -use off-road equipment and heavy-duty trucks, as well as fleet turnover replacing older equipment and vehicles in later years.

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Table 12. Construction Scenario Assumptions – Existing Land Use Designation Construction Phase
One -Way Trips
Equipment Quantity
Hours
Per Day
Daily
Workers
Daily
Vendor
Trucks
Total
Haul
Trucks
Generator Sets 1 8
Tractors/Loaders/Backhoes 3 7
Welders 1 8
Paving 20 0 0 Cement and Mortar Mixers 2 6
Pavers 1 8
Paving Equipment 2 6
Rollers 2 6
Tractors/Loaders/Backhoes 1 8
Architectural Coating 16 0 0 Air Compressors 1 6
Note: See Appendix A.

3.3.2.2 Operation
Existing Land Use Designation
Similar to construction, emissions from the operational phase of the existing land use designation and project were estimated using CalEEMod. Operational year 20 30 was assumed consistent with Appendix D of the City’s CAP (City of San Marcos 2020).

Area Sources
CalEEMod was used to estimate operational emissions from area sources, including emissions from landscape maintenance equipment. Emissions associated with natural gas usage in space heating and water heating were calculated in the building energy use module of CalEEMod, as described in the following text.

Landscape maintenance includes fuel combustion emissions from equipment such as lawn mowers, rototillers, shredders/grinders, blowers, trimmers, chainsaws, and hedge trimmers. The emissions associated with landscape equipment use were estimated based on CalEEMod default values for emission factors (grams per square foot of building space per day) and number of summer days (when landscape maintenance would generally be performed) and winter days. Based on CalEEMod d efaults for the County, the average annual number of summer days is estimated at 180 days (CAPCOA 2021).

Energy Sources
CalEEMod default values for electricity use and natural gas consumption for each land use type ( industrial park) were applied for the e xisting land use designation . The energy use from commercial and industrial land uses is calculated in CalEEMod based on the Commercial End -Use Survey (CAPCOA 2021). Energy use in buildings (both natural gas and electricity) is divided by CalEEMod into end-use categories subject to Title 24 requirements (end uses associated with the building envelope, such as the HVAC system, water heating system, and integrated

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lighting) and those not subject to Title 24 requirements (such as appliances, electronics, and m iscellaneous “plug-in” uses).

Operational GHG emissions from energy sources include natural gas combustion for appliances and space and water heating. The current Title 24, Part 6 standards, referred to as the 2019 Title 24 Building Energy Efficiency Standards, became effective on January 1, 2020. The current version of CalEEMod assumes compliance with the 2019 Title 24 Building Energy Efficiency Standards (CAPCOA 2021).

CalEEMod default energy intensity factors (CO2, CH4, and N2O mass emissions per kilowatt hour) for SDG&E were based on the value for SDG&E’s energy mix in 20 21. As explained in Section 3.2.2, SB X1 -2 established a target of 33% from renewable energy sources for all electricity providers in California by 2020, and SB 350 calls for further development of renewable energy, with a target of 50% by 2030. SB 100 revised this target to 60% by 2030. Consistent with the City’s CAP, the GHG intensity for 2030 was assumed to be 44 pounds per megawatt - hour for SDG&E (City of San Marcos 2020). In accordan ce with the City’s CAP Measure E -2, the existing land use designation was assumed to install 2 watts of solar photovoltaics for every square food of gross floor area. This resulted in 184 kilowatts of solar. The production of the solar photovoltaic system was estimated using the National Renewable Energy Laboratories (NREL)’s PVWatts calculator (NREL 2022).

Mobile Sources
The land use built under the existing land use designation would generate GHG emissions from mobile sources (vehicular traffic) as a resu lt of trucks , customers, and employee vehicles. CalEEMod was used to estimate emissions from proposed vehicular sources (refer to Appendix A). CalEEMod default data, including trip rates, trip modes, trip lengths, fleet mix, and emissions factors, were use d for the model inputs. CalEEMod default vehicle emission factors and vehicle fleet mix for 20 30, as based on CARB ’s EMFAC2017 model, were used to estimate emissions associated with vehicular sources. Consistent with Measure T -2 of the City’s CAP, 5% of th e proposed parking spaces (14) were assumed to be EV charging stations.

Solid Waste
The land use built under the existing land use designation would generate solid waste and therefore would result in CO 2e emissions associated with landfill off -gassing. Cal EEMod default values were used to estimate GHG emissions associated with solid waste.

Water and Wastewater
Supply, conveyance, treatment, and distribution of water for the land use built under the existing land use designation require the use of electricity, which result in associated indirect GHG emissions. Similarly, wastewater generated by the land use built under the existing land use designation requires the use of electricity for conveyance and treatment, along with GHG emissions generated during wast ewater treatment. Water consumption estimates for both indoor and outdoor water use relied on CalEEMod default assumptions.

Proposed Project
CalEEMod Version 20 20.4.0 was used to estimate potential project -generated operational GHG emissions from vehicular sources, area sources (natural gas combustion and landscape maintenance), electrical generation (including electrical generation associated with water supply and was tewater treatment), and solid waste.

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Emissions from each category—area sources, energy sources, mobile sources, solid waste, and water supply and wastewater treatment—are discussed in the following text with respect to the project. For additional details, see Section 2.4.2.2, Operation, for a discussion of operational emission calculation methodology and assumptions, specifically for area, energy (natural gas), and mobile sources. Consistent with Appendix D of the City’s CAP, Operational Year 2030 was assumed consistent with the CAP horizon year (City of San Marcos 2013b).

Area Sources
CalEEMod was used to estimate GHG emissions from the project’s area sources, which include operation of gasoline-powered landscape maintenance equipment, which produce minima l GHG emissions. See Section

2.4.2.2 for a discussion of landscaping equipment emissions calculations. Consumer product use and architectural coatings result in VOC emissions, which are analyzed in air quality analysis only, and little to no GHG emissions. No wood hearths or stoves would be included in the project design; therefore, they were not included in the CalEEMod analysis. It should be noted that CalEEMod 2020.4.0 does not account for the recent SORE regulations and thus is considered conservative.

Energy Sources
Operational GHG emissions from energy sources would include natural gas combustion for appliances and space heating. The current Title 24, Part 6 standards, referred to as the 2019 Title 24 Building Energy Efficiency Standards, became effective on January 1, 2020. The current version of CalEEMod assumes compliance with the 2019 Title 24 Building Energy Efficiency Standards (CAPCOA 20 21). This is conservative and does not reflect the building standards in 2030 as building standards decrease energy use over time.

CalEEMod default energy intensity factors (CO 2, CH 4, and N 2O mass emissions per kilowatt hour) for SDG&E are based on the value for SDG&E’s energy mix in 2021. As explained in Section 3.2.2, SB X1 -2 established a target of 33% from renewable energy sources for all electricity providers in California by 2020 , and SB 350 calls for further development of renewable energy, with a target of 50% by 2030. SB 100 updated this goal with a 60% renewable energ y target by 2030. Consistent with the City’s CAP, the GHG intensity for 2030 was assumed to be 44 pounds per megawatt-hour for SDG&E (City of San Marcos 2020).

As discussed in Section 2.4.2.2, the project would include alternatively fueled water heaters i n accordance with the City’s CAP Measure E -1. When using the CAP’s GHG reduction methodology as shown in Appendix A, the net GHG reduction (emissions avoided from natural gas minus emissions from electricity) would be 84 MT CO 2e per year. However, this exceeds the total GHG emissions from natural gas from the project as estimated in CalEEMod.

Therefore, using the Energy Information Administration’s estimate of 46% of residential natural gas use being attributed to water heating, this amount was applied to t he CalEEMod GHG estimate to account for the reduction from alternatively fueled water heaters (EIA 2015).

Mobile Sources (Motor Vehicles)
CalEEMod was used to estimate mobile source emissions from the project. See Section 2.4.2.2 for a discussion of mobile source emissions calculations. The operational year was adjusted to 2030 consistent with the City’s CAP Guidance Appendix D (City of San Marcos 2020).

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Solid Waste
The project would generate solid waste and therefore would result in CO2e emissions associated with landfill off- gassing. CalEEMod default values for solid waste generation were used to estimate GHG emissions associated with solid waste.

Water and Wastewater
Supply, conveyance, treatment, and distribution of water for the project require the use of electricity, which would result in associated indirect GHG emissions. Similarly, wastewater generated by the project requires the use of electricity for conveyance and treatment, along with GHG emissions generated during wastewater t reatment.

Water consumption estimates for both indoor and outdoor water use and associated electricity consumption from water use and wastewater generation were estimated using CalEEMod default values. The project is designed to include low-flow fixtures and water-efficient irrigation systems consistent with CAP measure W-1.

3.4 Impact Analysis
This section evaluates the GHG emissions impacts associated with the project. The significance criteria described in Section 3.3.1, Thresholds of Significance, were used to evaluate impacts associated with the construction and operation of the project.

Threshold 1: Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Threshold 2: Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
City of San Marcos’ Climate Action Plan Consistency
This section first presents a comparison of the existing land use designation GHG emissions and compares them to the projects. This section then evaluates the proposed project’s impacts to GHG in accordance with the City’s 2020 CAP Consistency Checklist. As discussed in Section 3.3.1, the City’s numerical GHG threshold of 2.1 MT/SP/yr is used to evaluate the projects consistency with the City’s CAP and determine its impact with respect to GHG emissions. The projects construction and operational GHG emission s are quantified below in accordance with the methodology presented in Section 3.3.2 and compared to the City’s threshold.

Existing Land Use Designation
Construction Emissions
Construction of the existing land use designation would result in GHG emissions that are primarily associated with use of off -road construction equipment, on -road vendor trucks, and worker vehicles. CalEEMod was used to calculate the GHG emissions based on the construction scenario described in Section 3.3.2.1, Construction, and Appendix A. Construction of the existing land use designation is anticipated to commence in December 2023, lasting a total of approximately 11 months. On-site sources of GHG emissions include off-road equipment and off-

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site sources include on -road vehicles (hau l trucks, vendor trucks, and worker vehicles). Table 13 presents construction emissions for the existing land use designation from on-site and off-site emission sources.

Table 13. Estimated Annual Construction GHG Emissions – Existing Land Use Designation
Year
CO 2 CH 4 N2O CO 2e
Metric Tons
2023 33.41 0.01 0.00 33.76
2024 402.57 0.07 0.01 407.95
Total 441.71
Emissions amortized over 30 years 14.72
Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent.

See Appendix A for complete results.

As shown in Table 13, the estimated total GHG emissions during construction of the existing land use designation would be approximately 442 MT CO 2e. Construction GHG emissions of the existing land use desig nation amortized over 30 years would be 15 MT CO 2e per year. Amortized construction emissions are added to operational emissions to be compared to the proposed project for this assessment.

Operational Emissions
Operation of the existing land use designatio n would generate GHG emissions through area sources; motor vehicle trips to and from the project site; energy use (natural gas and generation of electricity consumed by the existing land use designation ); solid waste disposal; and generation of electricity associated with water supply, treatment, and distribution and wastewater treatment. CalEEMod was used to calculate the annual GHG emissions based on the operational assumptions described in Section 3.3.2.2, Operation. The estimated operational emissions of the existing land use designation are presented in Table 14.

Table 14. Estimated Annual Operational GHG Emissions – Existing Land Use Designation
Emission Source
CO 2 CH 4 N2O CO 2e
Metric Tons
Area 0.01 0.00 0.00 0.01
Energy 167.08 0.00 0.00 167.78
Mobile1 3,181.44 0.31 0.19 3,245.70
Waste 84.43 4.99 0.00 209.18
Water 6.47 0.33 0.01 17.10
Total 3,639.77
Amortized construction emissions 14.72
Total with amortized construction emissions 3,654.49
Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent. 1 Mobile emissions include reductions from EV charging stations.

See Appendix A for complete results.

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As shown in Table 14, estimated annual GHG emissions from the exi sting land use designation would be approximately 3,640 MT CO2e per year. With amortized construction emissions, the annual operational emissions would be 3,655 MT CO2e per year.

Proposed Project
Construction Emissions
Construction of the proposed project would result in GHG emissions that are primarily associated with use of off - road construction equipment, on -road vendor trucks, and worker vehicles. Table 15 presents construction emissions for the proposed project from construction-related sources.

Table 15. Estimated Annual Construction GHG Emissions – Proposed Project Year
CO 2 CH 4 N2O CO 2e
Metric Tons
2023 57.99 0.02 0.00 58.49
2024 549.96 0.06 0.02 558.00
2025 66.17 0.01 0.00 67.14
Total 683.63
Emissions amortized over 30 years 22.79
Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent.

See Appendix A for complete results.

As shown in Table 15, the estimated total GHG emissions during construction of the proposed project would be approximately 684 MT CO2e. Construction GHG emissions amortized over 30 years would be 23 MT CO 2e per year. Amortized construction emissions are added to operational emissions to be compared to the City’s threshold.

Operational Emissions
Operation of the proposed project would generate GHG emissions through area sources; motor vehicle trips to and from the project site; energy use (natural gas and generation of electricity consumed by the project); solid waste disposal; and generation of electricity associ ated with water supply, treatment, and distribution and wastewater treatment. The estimated operational emissions of the proposed project are presented in Table 16.

Table 16. Estimated Annual Operational GHG Emissions – Proposed Project Emission Source
CO 2 CH 4 N2O CO 2e
Metric Tons
Area 1.46 0.00 0.00 1.49
Energy 36.62 0.00 0.00 36.77
Mobile1 517.81 0.04 0.03 526.46
Waste 11.26 0.67 0.00 27.91
Water 5.48 0.20 0.00 12.01

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Table 16. Estimated Annual Operational GHG Emissions – Proposed Project Emission Source
CO 2 CH 4 N2O CO 2e
Metric Tons
Total 604.64
Amortized construction emissions 22.79
Total with amortized construction emissions 627.43
Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent.

See Appendix A for complete results.
1 Includes reduction from EV chargers as discussed in Section 2.4.2.2.

As shown in Table 16, estimated annual GHG emissions from the proposed project would be approximately 605 MT CO2e per year. With amortized construction emissions, the annual operational emissions would be 627 MT CO2e per year. This would be less than the existing designated land use estimate of 3,655 MT CO2e per year.

Service Population
Using the land use by Master Geographic Reference Area (MGRA) file obtained from the SANDAG activity based reginal travel demand model, the number of multi -family households and corresponding household population within the City of San Marcos was reviewed. The values for the base year (2016) of the 2021 Regional Plan and the Series 14 land use forecast were used. It was found that the average household size for multi -family households in San Marcos is approximately 3.4 (SANDAG 2022) . Using this household ratio of 3.4, development of 1 20 residential dwelling units at the project site would generate approximately 408 people.

Summary
As outlined above, the proposed project would result in an estimated 627 MT CO2e per year, including amortized construction GHG emissions. With an estimated service population of 408 persons, the project would result in 1.5 MT CO2e/SP/yr. The project would result in GHG emissions that would not exceed the City’s significance threshold of 2.1 MT CO 2e/SP/yr. Therefore, implementation of the proposed project would be consistent with the City’s 2020 CAP and impacts to GHG emissions would be less than significant.

Consistency with Statewide Greenhouse Gas Reduction Strategies The project’s consistency with state wide GHG reduction strategies is summarized in detail in Table 17 through consideration of the project’s various construction and operational components and their relationship to specified laws and regulations designed to reduce GHG emissions from such com ponents .

Table 17. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project Building Components/Facility Operations
Roofs/Ceilings/Insulation CALGreen Code
(Title 24, Part 11)
The proposed project must comply with efficiency
standards regarding roofing, ceilings, and insulation. For

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Table 17. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project California Energy
Code
(Title 24, Part 6)
example:

Roofs/Ceilings: New construction must reduce roof heat
island effects per CALGreen Code Section 106.11.2,
which requires use of roofing materials having a
minimum aged solar reflectance, thermal emittance
complying with Section A5.106.11.2.2 and
A5.106.11.2.3 or a minimum aged Solar Reflectance
Index as specified in Tables A5.106.11.2.2, or
A5.106.11.2.3. Roofing materials must also meet solar
reflectance and thermal emittance standards contained
in Title 20 Standards.

Roof/Ceiling Insulation: There are also requirements for the installation of roofing and ceiling insulation. (See Title 24, Part 6 Compliance Manual at Section 3.2.2.)
Flooring CALGreen Code The proposed project must comply with efficiency standards regarding flooring materials. For example, for 80% of floor area receiving “resilient flooring,” the flooring must meet applicable installation and material requirements contained in CALGreen Code Section 5.504.4.6.

Window and Doors
(Fenestration)
California Energy
Code
The proposed project must comply with fenestration
efficiency requirements. For example, the choice of
windows, glazed doors, and any skylights for the project must conform to energy consumption requirements
affecting size, orientation, and types of fenestration
products used. (See Title 24, Part 6 Compliance Manual, Section 3.3.)
Building Walls/Insulation CALGreen Code
California Energy
Code
The proposed project must comply with efficiency
requirements for building walls and insulation.

Exterior Walls: Must meet requirements in current edition of California Energy Code, and comply with Sections
A5.106.7.1 or A5.106.7.2 of CALGreen Code for wall
surfaces, as well as Section 5.407.1, which required
weather-resistant exterior wall and foundation envelope as required by California Building Code Section 1403.2.

Construction must also meet requirements contained in
Title 24, Part 6, which vary by material of the exterior walls. (See Title 24, Part 6 Compliance Manual, Part

3.2.3.)
Demising (Interior) Walls: Mandatory insulation
requirements for demising walls (which separate
conditioned from non-conditions space) differ by the type of wall material used. (Id. at 3.2.4.)
Door Insulation: There are mandatory requirements for
air infiltration rates to improve insulation efficiency; they

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Table 17. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project differ according to the type of door. (Id. at 3.2.5.)
Flooring Insulation: There are mandatory requirements
for insulation that depend on the material and location of the flooring. (Id. at 3.2.6.)
Finish Materials CALGreen Code The proposed project must comply with pollutant control requirements for finish materials. For example, materials including adhesives, sealants, caulks, paints and coatings, carpet systems, and composite wood products must meet
requirements in CALGreen Code to ensure pollutant control. (CALGreen Code Section 5.504.4.)
Wet Appliances
(Toilets/Faucets/Urinals,
Dishwasher/Clothes Washer,
Spa and Pool/Water Heater)
CALGreen Code
California Energy
Code
Appliance
Efficiency
Regulations (Title
20 Standards)
Wet appliances associated with the proposed project
must meet various efficiency requirements. For example:

Spa and Pool: Use associated with the project is subject to appliance efficiency requirements for service water
heating systems and equipment, spa and pool heating
systems and equipment. (Title 24, Part 6, Sections
110.3, 110.4, 110.5; Title 20 Standards, Sections
1605.1(g), 1605.3(g); see also California Energy Code.) Toilets/Faucets/Urinals: Use associated with the project is subject to new maximum rates for toilets, urinals, and faucets effective January 1, 2016:
▪ Showerheads maximum flow rate 2.5 gpm at 80 psi
▪ Wash fountains 2.2 x (rim space in inches/20) gpm
at 60 psi
▪ Metering faucets 0.25 gallons/cycle
▪ Lavatory faucets and aerators 1.2 gpm at 60 psi
▪ Kitchen faucets and aerators 1.8 gpm with optional
temporary flow of 2.2 gpm at 60 psi
▪ Public lavatory faucets 0.5 gpm at 60 psi
▪ Trough-type urinals 16 inches length
▪ Wall mounted urinals 0.125 gallons per flush
▪ Other urinals 0.5 gallons per flush
(Title 20 Standards, Sections 1605.1(h),(i) 1065.3(h),(i).) Water Heaters: Use associated with the project is subject to appliance efficiency requirements for water heaters. (Title 20 Standards, Sections 1605.1(f), 1605.3(f).)
Dishwasher/Clothes Washer: Use associated with the
project is subject to appliance efficiency requirements for dishwashers and clothes washers. (Title 20 Standards,
Sections 1605.1(o),(p),(q), 1605.3(o),(p),(q).)
Dry Appliances
(Refrigerator/Freezer, Heater/
Air Conditioner, Clothes Dryer)
Title 20 Standards
CALGreen Code
Dry appliances associated with the proposed project
must meet various efficiency requirements. For example:

Refrigerator/Freezer: Use associated with the proposed

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Table 17. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project project is subject to appliance efficiency requirements for refrigerators and freezers. (Title 20 Standards,
Sections 1605.1(a), 1605.3(a).)
Heater/Air Conditioner: Use associated with the
proposed project is subject to appliance efficiency
requirements for heaters and air conditioners. (Title 20 Standards, Sections 1605.1(b),(c),(d),(e),
1605.3(b),(c),(d),(e) as applicable.)
Clothes Dryer: Use associated with the proposed project is subject to appliance efficiency requirements for clothes dryers. (Title 20 Standards, Section 1605.1(q).)
CALGreen Code Installations of HVAC, refrigeration and fire suppression equipment must comply with CALGreen Code Sections

5.508.1.1 and 508.1.2, which prohibits CFCs, halons, and certain HCFCs and HFCs.

Lighting Title 20 Standards Lighting associated with the proposed project will be subject to energy efficiency requirements contained in
Title 20 Standards.

General Lighting: Indoor and outdoor lighting associated with the proposed project must comply with applicable
appliance efficiency regulations (Title 20 Standards,
Sections 1605.1(j),(k),(n), 1605.3(j),(k),(n).)
Emergency lighting and self-contained lighting: the
proposes project must also comply with applicable
appliance efficiency regulations (Title 20 Standards,
Sections 1605.1(l), 1605.3(l).)
Traffic Signal Lighting: For any necessary proposed
project improvements involving traffic lighting, traffic signal modules and traffic signal lamps will need to
comply with applicable appliance efficiency regulations (Title 20 Standards, Sections 1605.1(m), 1605.3(m).)
California Energy
Code
Lighting associated with a use implementing the
proposed project will also be subject to energy efficiency requirements contained in Title 24, Part 6, which
contains energy standards for non-residential indoor
lighting and outdoor lighting. (See Title 24 Part 6
Compliance Manual, at Sections 5, 6.)
Mandatory lighting controls for indoor lighting include, for example, regulations for automatic shut-off, automatic
daytime controls, demand responsive controls, and
certificates of installation. (Id. at Section 5.) Regulations for outdoor lighting include, for example, creation of
lighting zones, lighting power requirements, a hardscape lighting power allowance, requirements for outdoor

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Table 17. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project incandescent and luminaire lighting, and lighting control functionality. (Id. at Section 6.)
AB 1109 Lighting associated with implementing the proposed project will be subject to energy efficiency requirements adopted pursuant to
AB 1109.

Enacted in 2007, AB 1109 required the CEC to adopt
minimum energy efficiency standards for general
purpose lighting, to reduce electricity consumption 50% for indoor residential lighting and 25% for indoor
commercial lighting.

Bicycle and Vehicle Parking CALGreen Code A use implementing the proposed project will be required to provide compliant bicycle parking, fuel-efficient vehicle parking, and electric vehicle charging spaces (CALGreen Code Sections 5.106.4, 5.106.5.1, 5.106.5.3)
California Energy
Code
The proposed project is also subject to parking
requirements contained in Title 24, Party 6. For example, parking capacity is to meet but not exceed minimum
local zoning requirements, and the project should employ approved strategies to reduce parking capacity (Title 24, Part 6, section 106.6)
Landscaping CALGreen Code The CALGreen Code requires and has further voluntary provisions for:
▪ -A water budget for landscape irrigation use;
▪ For new water service, separate meters or
submeters must be installed for indoor and outdoor
potable water use for landscaped areas of 1,000-
5,000 square feet;
▪ -Provide water-efficient landscape design that
reduces use of potable water beyond initial
requirements for plant installation and
establishment
Model Water
Efficient
Landscaping
Ordinance
The model ordinance promotes efficient landscaping in
new developments and establishes an outdoor water
budget for new and renovated landscaped areas that are
500 square feet or larger. (CCR, Title 23,
Division 2, Chapter 2.7.)
Cap-and-Trade
Program
Transportation fuels used in landscape maintenance
equipment (e.g., gasoline) would be subject to the Cap- and-Trade Program. Fuel refineries and suppliers are
subject to the Cap-and-Trade requirements. (See “Energy Use,” below.)
Refrigerants CARB
Management of
High GWP
Any refrigerants associated with the project will be subject to CARB standards. CARB’s Regulation for the Management of High GWP Refrigerants for Stationary Sources 1) reduces

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Table 17. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project Refrigerants for
Stationary
Sources
emissions of high-GWP refrigerants from leaky stationary, non-residential refrigeration equipment; 2) reduces
emissions resulting from the installation and servicing of stationary refrigeration and air conditioning appliances using high-GWP refrigerants; and 3) requires verification GHG emission reductions. (CCR, Title 17, Division 3,
Chapter 1, Subchapter 10, Article 4, Subarticle 5.1, Section 95380 et seq.)
Consumer Products CARB High GWP
GHGs in
Consumer
Products
All consumer products associated with the project will be subject to CARB standards. CARB’s consumer products
regulations set VOC limits for numerous categories of
consumer products, and limits the reactivity of the
ingredients used in numerous categories of aerosol
coating products (CCR, Title 17, Division 3, Chapter 1, Subchapter 8.5.)
Construction
Use of Off-Road Diesel Engines,
Vehicles, and Equipment
CARB In-Use Off-
Road Diesel
Vehicle Regulation
Any relevant vehicle or machine use associated with the project will be subject to CARB standards.

The CARB In-Use-Off-Road Diesel Vehicle Regulation
applies to certain off-road diesel engines, vehicles, or equipment greater than 25 horsepower. The regulation:
1) imposes limits on idling, requires a written idling
policy, and requires a disclosure when selling vehicles; 2) requires all vehicles to be reported to CARB (using the Diesel Off-Road Online Reporting System) and labeled; 3) restricts the adding of older vehicles into fleets starting on January 1, 2014; and 4) requires fleets to reduce
their emissions by retiring, replacing, or repowering older engines, or installing Verified Diesel Emission Control Strategies (i.e., exhaust retrofits).

The requirements and compliance dates of the Off-Road
regulation vary by fleet size, as defined by the regulation.

Cap-and-Trade
Program
Transportation fuels (e.g., gasoline) used in equipment operation would be subject to the Cap-and-Trade
Program. Fuel refineries and suppliers are subject to the Cap-and-Trade requirements. (See “Energy Use,” below.)
Greening New Construction CALGreen Code All new construction must comply with CALGreen Code, as discussed in more detail throughout this table.

Adoption of the mandatory CALGreen Code standards for
construction has been essential for improving the overall environmental performance of new buildings; it also sets voluntary targets for builders to exceed the mandatory
requirements.

Construction Waste CALGreen Code The proposed project will be subject to CALGreen Code requirements for construction waste reduction, disposal,

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Table 17. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project and recycling, such as a requirement to recycle and/or
salvage for reuse a minimum of 50% of the non-
hazardous construction waste in accordance with
Section 5.408.1.1, 5.408.1.2, or 5.408.1.3; or meet a
local construction and demolition waste management
ordinance, whichever is more stringent.

Solid Waste
Solid Waste Management Landfill Methane
Control Measure
Waste associated with a use implementing the proposed
project will be disposed per state requirements for
landfills, material recovery facilities, and transfer
stations. Per the statewide GHG emissions inventory, the largest emissions from waste management sectors come
from landfills, and are in the form of CH4.

In 2010, CARB adopted a regulation that reduces
emissions from methane in landfills, primarily by requiring owners and operators of certain uncontrolled municipal
solid waste landfills to install gas collection and control systems, and requires existing and newly installed gas and control systems to operate in an optimal manner. The
regulation allows local air districts to voluntarily enter into a memorandum of understanding with CARB to implement
and enforce the regulation and to assess fees to cover
costs of implementation.

Mandatory
Commercial
Recycling
(AB 341)
AB 341 will require a use implementing the proposed
project, if it generates four cubic yards or more of
commercial solid waste per week, to arrange for recycling services, using one of the following: self-haul; subscribe to a hauler(s); arranging for pickup of recyclable materials; subscribing to a recycling service that may include mixed waste processing that yields diversion results comparable to source separation.

The project will also be subject to local commercial solid waste recycling program required to be implemented by
each jurisdiction under AB 341.

CALGreen Code The proposed project will be subject to CALGreen Code requirement to provide areas that serve the entire
building and are identified for the depositing, storage and collection of nonhazardous materials for recycling
(CALGreen Code Section 5.410.1)
Energy Use
Electricity/Natural Gas
Generation
Cap-and-Trade
Program
Electricity and natural gas generated and/or imported
into the state which may be used for the proposed
project will be subject to the Cap-and-Trade Program.

The rules came into effect on January 1, 2013, applying to large electric power plants and large industrial plants.

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Table 17. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project In 2015, importers and distributors of fossil fuels were added to the Cap-and-Trade Program in the second
phase.

Specifically, on January 1, 2015, cap-and-trade
compliance obligations were phased in for suppliers of
natural gas, reformulated gasoline blendstock for
oxygenate blending (RBOB), distillate fuel oils, and
liquefied petroleum gas that meet or exceed specified
emissions thresholds. The threshold that triggers a cap- and-trade compliance obligation for a fuel supplier is
25,000 metric tons or more of CO2e annually from the
GHG emissions that would result from full combustion or oxidation of quantities of fuels (including natural gas, RBOB, distillate fuel oil, liquefied petroleum gas, and blended fuels that contain these fuels) imported and/or delivered to California.

Renewable Energy California RPS (SB
X1-2, SB 350, and
SB 100)
Energy providers to the proposed project will be required to comply with RPS set by SB X1 2, SB 350, and SB 100.

SB X1 2 requires investor-owned utilities, publicly-owned utilities, and electric service providers to increase
purchases of renewable energy such that at least 33% of retail sales are procured from renewable energy
resources by December 31, 2020. In the interim, each
entity was required to procure an average of 20% of
renewable energy for the period of January 1, 2011
through December 31, 2013; and will be required to
procure an average of 25% by December 31, 2016, and
33% by 2020.

SB 350 requires retail sellers and publicly owned utilities to procure 50% of their electricity from eligible renewable energy resources by 2030.

SB 100 increased the standards set forth in SB 350
establishing that 44% of the total electricity sold to retail customers in California per year by December 31, 2024,
52% by December 31, 2027, and 60% by December 31,
2030, be secured from qualifying renewable energy
sources. SB 100 states that it is the policy of the state that eligible renewable energy resources and zero-carbon
resources supply 100% of the retail sales of electricity to California by 2045.

Million Solar Roofs
Program (SB 1)
The project will participate in California’s energy market by pre-wiring roofs for future installation of solar, which is affected by implementation of the Million Solar Roofs
Program.

As part of Governor Schwarzenegger's Million Solar Roofs

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Table 17. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project Program, California has set a goal to install 3,000
megawatts of new, solar capacity through 2016. The
Million Solar Roofs Program is a ratepayer-financed
incentive program aimed at transforming the market for
rooftop solar systems by driving down costs over time.

California Solar
Initiative- Thermal
Program
The proposed project will derive energy from California’s energy market, which is affected by implementation of
the California Solar Initiative -Thermal Program. The
program offers cash rebates of up to $4,366 on solar
water heating systems for single-family residential
customers. Multifamily and Commercial properties
qualify for rebates of up to $800,000 on solar water
heating systems and eligible solar pool heating systems qualify for rebates of up to $500,000. Funding for the
California Solar Initiative-Thermal program comes from
ratepayers of Pacific Gas & Electric, SCE, Southern
California Gas Company, and San Diego Gas & Electric.

The rebate program is overseen by the CPUC as part of
the California Solar Initiative.

Waste Heat and
Carbon Emissions
Reduction Act
(AB 1613,
AB 2791)
The proposed project will derive energy from California’s energy market, which is affected by implementation of
the Waste Heat and Carbon Emissions Reduction Act.

Originally enacted in 2007 and amended in 2008, this
act directed the CEC, CPUC, and CARB to implement a
program that would encourage the development of new
combined heat and power systems in California with a
generating capacity of not more than 20 megawatts, to
increase combined heat and power use by 30,000
gigawatt-hour. The CPUC publicly owned electric utilities, and CEC duly established policies and procedures for the purchase of electricity from eligible combined heat and power systems.

CEC guidelines require combined heat and power
systems to be designed to reduce waste energy; have a
minimum efficiency of 60%; have NOx emissions of no
more than 0.07 pounds per megawatt-hour; be sized to
meet eligible customer generation thermal load; operate continuously in a manner that meets expected thermal
load and optimizes efficient use of waste heat; and be
cost effective, technologically feasible, and
environmentally beneficial.

Vehicular/Mobile Sources
General SB 375 and

SANDAG RTP/SCS
The proposed project complies with, and is subject to,
the SANDAG adopted RTP/SCS, which CARB approved as
meeting its regional GHG targets in 2016. The most
recent plan was adopted in December 2021, but CARB

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Table 17. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project has not accepted it as of this writing. See discussion
below.

Fuel Low Carbon Fuel
Standard (LCFS)/
EO S-01-07
Auto trips associated with the proposed project will be subject to LCFS (EO S-01-07), which requires a 20% or
greater reduction in the average fuel carbon intensity by 2030 with a 2010 baseline for transportation fuels in
California regulated by CARB. The program establishes a strong framework to promote the low carbon fuel
adoption necessary to achieve statewide GHG reduction
goals.

Cap-and-Trade
Program
Gasoline used for proposed project implementation will
be subject to the Cap-and-Trade Program.

The rules came into effect on January 1, 2013, applying to large electric power plants and large industrial plants.

In 2015, importers and distributors of fossil fuels were added to the Cap-and-Trade Program in the second
phase.

Specifically, on January 1, 2015, cap-and-trade
compliance obligations were phased in for suppliers of
natural gas, RBOB, distillate fuel oils, and liquefied
petroleum gas that meet or exceed specified emissions
thresholds. The threshold that triggers a cap-and-trade compliance obligation for a fuel supplier is 25,000 MT or more of CO2e annually from the GHG emissions that
would result from full combustion or oxidation of
quantities of fuels (including natural gas, RBOB, distillate fuel oil, liquefied petroleum gas, and blended fuels that contain these fuels) imported and/or delivered to
California.

Light-Duty Vehicles AB 1493 (or the
Pavley Standard)
Cars that drive to and from the proposed project will be subject to AB 1493, which directed CARB to adopt a
regulation requiring the maximum feasible and cost-
effective reduction of GHG emissions from new
passenger vehicles.

Pursuant to AB 1493, CARB adopted regulations that
establish a declining fleet average standard for CO2, CH4, N2O, and HFCs (air conditioner refrigerants) in new
passenger vehicles and light-duty trucks beginning with the 2009 model year and phased-in through the 2016
model year. These standards are divided into those
applicable to lighter and those applicable to heavier
portions of the passenger vehicle fleet.

The regulations will reduce “upstream” smog-forming
emissions from refining, marketing, and distribution of fuel.

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Table 17. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project Advanced Clean
Car and ZEV
Programs
Cars that drive to and from the proposed project will be subject to the Advanced Clean Car and ZEV Programs.

In January 2012, CARB approved a new emissions-
control program for model years 2017 through 2025.

The program combines the control of smog, soot and
global warming gases and requirements for greater
numbers of zero-emission vehicles into a single package of standards called Advanced Clean Cars. By 2025, new
automobiles will emit 34% fewer global warming gases
and 75% fewer smog-forming emissions.

The ZEV program will act as the focused technology of
the Advanced Clean Cars program by requiring
manufacturers to produce increasing numbers of ZEVs
and plug-in hybrid electric vehicles in the 2018-2025
model years.

Tire Inflation
Regulation
Cars that drive to and from the proposed project will be subject to the CARB Tire Inflation Regulation, which took effect on September 1, 2010, and applies to vehicles
with a gross vehicle weight rating of 10,000 pounds or
less.

Under this regulation, automotive service providers must, inter alia, check and inflate each vehicle’s tires to the recommended tire pressure rating, with air or nitrogen, as appropriate, at the time of performing any automotive maintenance or repair service, and to keep a copy of the service invoice for a minimum of three years, and make
the vehicle service invoice available to the CARB, or its authorized representative upon request.

EPA and NHTSA
GHG and CAFE
Standards
Mobile sources that travel to and from the proposed
project would be subject to EPA and NHTSA GHG and
CAFE standards for passenger cars, light-duty trucks, and medium-duty passenger vehicles. (75 FR 25324–25728
and 77 FR 62624–63200.)
Water Use
Water Use Efficiency Emergency State
Water Board
Regulations
Water use associated with the proposed project will be
subject to emergency regulations.

On May 18, 2016, partially in response to EO B-27-16, the State Water Board adopted emergency water use
regulations (CCR, title 23, Section 864.5 and amended and re-adopted Sections 863, 864, 865, and 866). The
regulation directs the State Water Board, Department of Water Resources, and CPUC to implement rates and pricing structures to incentivize water conservation, and calls upon

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Table 17. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project water suppliers, homeowners’ associations, California
businesses, landlords and tenants, and wholesale water
agencies to take stronger conservation measures.

EO B-37-16 Water use associated with the proposed project will be subject to Emergency EO B-37-16, issued May 9, 2016,
which directs the State Water Resources Control Board
to adjust emergency water conservation regulations
through the end of January, 2017 to reflect differing
water supply conditions across the state.

The Water Board must also develop a proposal to
achieve a mandatory reduction of potable urban water
usage that builds off the mandatory 25% reduction
called for in EO B-29-15. The Water Board and
Department of Water Resources will develop new,
permanent water use targets to which the project will be subject.

The Water Board will permanently prohibit water-wasting practices such as hosing off sidewalks, driveways, and
other hardscapes; washing automobiles with hoses not
equipped with a shut-off nozzle; using non-recirculated water in a fountain or other decorative water feature;
watering lawns in a manner that causes runoff, or within 48 hours after measurable precipitation; and irrigating ornamental turf on public street medians.

EO B-40-17 EO B-40-17 lifted the drought emergency in all California counties except Fresno, Kings, Tulare, and Tuolumne. It also rescinds EO B-29-15, but expressly states that EO B- 37-16 remains in effect and directs the State Water
Resources Control Board to continue development of
permanent prohibitions on wasteful water use to which
the proposed project will be subject.

SB X7-7 Water provided to the proposed project will be affected by SB X7-7’s requirements for water suppliers.

SB X7-7, or the Water Conservation Act of 2009, requires all water suppliers to increase water use efficiency. It also requires, among other things, that the Department
of Water Resources, in consultation with other state
agencies, develop a single standardized water use
reporting form, which would be used by both urban and
agricultural water agencies.

CALGreen Code The proposed project is subject to CALGreen Code’s water efficiency standards, including a required 20%
mandatory reduction in indoor water use. (CALGreen
Code, Division 4.3.)
California Water Development and approval of the proposed project

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Table 17. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project Code, Division 6,
Part 2.10, Sections
10910–10915.
would require the development of a project-specific
Water Supply Assessment assessing the projects water
demand and its inclusion within the City’s urban water
management plan.

Cap-and-Trade
Program
Electricity usage associated with water and wastewater
supply, treatment and distribution would be subject to
the Cap-and-Trade Program.

California RPS (SB
X1-2, SB 350,
SB 100)
Electricity usage associated with water and wastewater
supply, treatment and distribution associated with the
project will be required to comply with RPS set by SB X1- 2, SB 350, and SB 100.

Notes: AB = Assembly Bill; CARB = California Air Resources Board; CEC = California Energy Commission; CFC = chlorofluorocarbon; CH4 = methane; CO2 = carbon dioxide; CO 2e = carbon dioxide equivalent; CPUC = California Public Utilities Commission; EO = Executive Order; EPA = Environmental Protection Agency; GHG = greenhouse gas; GWP = global warming potential; HCFC = hydrochlorofluorocarbon; HFC = hydrofluorocarbon; gpm = gallons per minute; MT = metric tons; N 2O = nitrous oxide; NHTSA = National Highway Traffic Safety Administration; PM = particulate matter; RPS = Renewable Portfolio Standard; RTP/SCS = Region al Transportation Plan/Sustainable Communities Strategy; SB = Senate Bill; SANDAG = San Diego Association of Governments ; VOC = volatile organic compound; ZEV = zero emission vehicle
As shown, the project would be consistent with and would not conflict with the applicable GHG-reducing strategies of the state that implicate the project’s construction and operational components.

In addition, CARB notes in the First Update that “California is on track to meet the near-term 2020 GHG limit and is well positioned to maintain and continue reductions beyond 2020 as required by AB 32” (CARB 2014). The project would help support achievement of the near-term 2020 goal (as codified in AB 32), the interim 2030 g oal (as codified in SB 32) and the long -term, carbon neutrality 2045 goal (as set forth in EO B -55-18) by being infill development with access to multi-modal transportation options and incorporating design features such as electric vehicle charging station s, bicycle infrastructure, transportation demand management, electric water heaters, smart landscaping irrigation, and an urban tree canopy.

Consistency with SANDAG’s RTP/SCS
At the regional level, SANDAG’s RTP/SCS has been adopted for the purpose of redu cing GHG emissions attributable to passenger vehicles in the San Diego region. In December 2021, SANDAG adopted its RTP/SCS (The 2021 Regional Plan), which shows the San Diego region reduced per capita CO2 emissions by 17.9% in 2020 compared to 2005 baseline, which exceeds the 2020 target set for SANDAG of 15% reduction. Implementation of the RTP/SCS is estimated to result in a 20% CO 2 emissions reduction for cars and light -duty trucks by 2035, exceeding the 19% target from 2005 levels set by CARB . The RTP/SCS does not regulate land use or supersede the exercise of land use authority by SANDAG’s member jurisdictions, but it is a relevant regional reference document for purposes of evaluating the intersection of land use and transportation patterns and the corresponding GHG emissions.

For purposes of the RTP/SCS consistency evaluation, the proposed project would increase access to transit because it is located approximately 0. 3 mile from the Palomar College Sprinter station, and two bus stops are

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located in front of the project site off Mission Road.9 The project site’s proximity to State Route 78 further allows for easy regional connectivity to employment centers, shopping areas, and recreation opportunities. Furthermore, the project would be consistent with the City’s CAP . These measures would further reduce the project’s GHG emissions from vehicle trips, increase access to transit, and encourage alternative modes of transportation. The proposed density, land use type, and location are consistent with the SANDAG’s RTP/SCS, which increases access to transit and promotes regional connectivity to employment centers, shopping areas, and recreation opportunities. The features mentioned above would help facilitate alternative transit usage and reduce the overall vehicle trips, thereby reducing the project’s regional GHG emissions.

Based on the considerations outlined above, the proposed project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs, and potential impacts would be less than significant and no mitigation measure is required.

3.5 Mitigation Measures
The project would not result in significant impacts; therefore, no mitigation is required.

9 The City uses the North County Transit District ( NCTD) for Coaster rail service, Sprinter light rail service, and Breeze bus service for connections throughout the County of San Diego. Sprinter service operates between Escondido and Oceanside with connections to Interstate 5 and the Coaster rail service operating out of the City of Oceanside. The NCTD operates the Palomar College Sprinter, which is within a short walk from the project area. In addition, a bus stop is located in front of the project site. Connections to Orange County can be made via the Metrolink in the C ity of Oceanside. Similarly, connections to Riverside Transit Authority buses can be made via the transit station in Oceanside and Escondido. Both the Metrolink connection in Oceanside and the Riverside Transit Authority Bus connection in Oceanside and Escondido are accessible through Sprinter light rail service. These public transit options will offer residents of the project area quick access to a variety of alternative modes of transportation.

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4 References Cited
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CalRecycle (California Department of Resources, Recycling and Recovery). 2015. AB 341 Report to the Legislature. August 2015.

Caltrans (California Department of Transportation). 1998a. CALINE4 - A Dispersion Model for Predicting Air Pollutant Concentrations Near Roadways. Version 1.32. Written by Sonoma Technology Inc. Sponsored by the University of California, Davis Institute of Transportation Studies and Caltrans. http://www.dot.ca.gov/hq/InfoSvcs/EngApps/.

Caltrans. 1998b. User’s Guide for CL4: A User-Friendly Interface for the CALINE4 Model for Transportation Project Impact Assessments. User’s Guide STI-997480-1814-UG. June 1998. http://www.dot.ca.gov/hq/env/air/documents/CL4Guide.pdf.

CAPCOA (California Air Pollution Control Officers Association). 2010. Quantifying Greenhouse Gas Mitigation Measures.

August 2010. Accessed July 2018. https://www.arb.ca.gov/cc/capandtrade/auctionproceeds /capcoa_quantifying_ghg_measures.pdf.

CAPCOA. 2017. California Emissions Estimator Model (CalEEMod) User’s Guide, Version 2016.3.2. Prepared by BREEZE Software, A Division of Trinity Consultants, in collaboration with South Coast Air Quality Management District and the California Air Districts. September. Accessed May 2018. http://caleemod.com/.

CARB (California Air Resources Board). 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October 2000. http://www.arb.ca.gov/diesel/documents /rrpfinal.pdf.

CARB. 2004. 2004 Revision to the California State Implementation Plan for Carbon Monoxide. July 2004. http://www.arb.ca.gov/planning/sip/co/final_2004_co_plan_update.pdf.

CARB. 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April 2005. Accessed at:
http://www.arb.ca.gov/ch/landuse.htm.

CARB. 2008. Climate Change Scoping Plan: A Framework for Change. December 2008. http://www.arb.ca.gov/cc /scopingplan/document/scopingplandocument.htm.

CARB. 2011. Final Supplement to the AB 32 Scoping Plan Functional Equivalent Document. August 19, 2011. https://www.arb.ca.gov/cc/scopingplan/document/final_supplement_to_sp_fed.pdf.

CARB. 2014a. “Glossary of Air Pollution Terms.” Accessed April 24, 2014. http://www.arb.ca.gov /html/gloss.htm.

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CARB. 2014b. First Update to the AB 32 Scoping Plan . May 2014. http://www.arb.ca.gov/cc/scopingplan /document/updatedscopingplan2013.htm.

CARB. 2015a. “Glossary of Terms Used in GHG Inventories.” https://www.arb.ca.gov/cc/inventory /faq/ghg_inventory_glossary.htm.

CARB. 2015b. Executive Order G -15-075. San Diego Association of Governments (SANDAG), Sustainable Communities Strategy (SCS). CARB Acceptance of GHG Quantification Determination. December 2015.

CARB. 2016a. Ambient Air Quality Standards. May 4, 2016. http://www.arb.ca.gov/research /aaqs/aaqs2.pdf.

CARB. 2016b. Area Designation Maps/State and National. Last updated May 5, 2016. http://www.arb.ca.gov/desig/adm/adm.htm.

CARB. 2017a. California Greenhouse Gas Inventory for 2000-2015 by Category as Defined in the 2008 Scoping Plan. https://www.arb.ca.gov/cc/inventory/data/tables/ghg_inventory_scopingplan_sum_2000-15.pdf CARB. 2017b. California’s 2017 Climate Change Scoping Plan. November 2017. https://www.arb.ca.gov/cc /scopingplan/scoping_plan_2017.pdf.CARB. 2018. “AB 32 Scoping Plan.” Last updated January 8, 2018.

Accessed July 30, 2018. https://www.arb.ca.gov/cc/scopingplan/scopingplan.htm.

CARB. 2018. Opportunities for Additional Reductions from Petroleum Transportation Fuels. September 2018. https://www.arb.ca.gov/cc/scopingplan/meetings/082018/august-20-2018-ghg-workshop-summary.pdf.

CARB. 2019. Senate Bill 375 Regional Plan Climate Targets. Accessed August 13, 2019 https://ww2.arb.ca.gov/our- work/programs/sustainable-communities-program/regional-plan-targets.

CAT (Climate Action Team). 2006. Climate Action Team Report to Governor Schwarzenegger and the Legislature.

March 2006. http://www.climatechange.ca.gov/climate_action_team/reports/2006report /2006-04-03_FINAL_CAT_REPORT.PDF.

CAT. 2010. Climate Action Team Report to Governor Schwarzenegger and the California Legislature. December 2010. Accessed January 2015. http://www.energy.ca.gov/2010publications/CAT-1000-2010-005 /CAT-1000-2010-005.PDF.

CCCC (California Climate Change Center). 2006. Our Changing Climate: Assessing the Risks to California. CEC- 500-2006-077. July 2006. Accessed February 2014. http://www.energy.ca.gov/2006publications/CEC-500- 2006-077/CEC-500-2006-077.PDF.

CCCC. 2012. Our Changing Climate 2012: Vulnerability & Adaptation to the Increasing Risks from Climate Change in California. July 2012. Accessed August 2016. http://www.energy.ca.gov /2012publications/CEC-500-2012-007/CEC-500-2012-007.pdf.

CDPH (California Department of Public Health). 2017. Epidemiologic Summary of Coccidioidomycosis in California, 2017. https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library /CocciEpiSummary2017.pdf.

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13528 75 APRIL 2022

CEC (California Energy Commission). 2016. 2015 Integrated Energy Policy Report. June 29, 2016. CEC-100- 2015-001-CMF. http://www.energy.ca.gov/2015_energypolicy/.

CEC. 2017. “2016 Building Energy Efficiency Standards Frequently Asked Questions.” https://www.energy.ca.gov/title24/2016standards/rulemaking/documents/2016_Building_Energy_ Efficiency_Standards_FAQ.pdf.

CEC. 2018. “2019 Building Energy Efficiency Standards Frequently Asked Questions.” http://www.energy.ca.gov/title24/2019standards/documents/2018_Title_24_2019_Building_ Standards_FAQ.pdf.

CEC. 2018. “2019 Building Energy Efficiency Standards Frequently Asked Questions.” March 2018. https://www.energy.ca.gov/title24/2019standards/documents/2018_Title_24_2019_ Building_Standards_FAQ.pdf.

City of San Marcos. 2013a. City of San Marcos General Plan. Adopted February 14, 2012. http://www.san- marcos.net/work/economic-development/general-plan.

City of San Marcos. 2013b. City of San Marcos Climate Action Plan. Adopted September 10, 2013. http://www.san-marcos.net/home/showdocument?id=9922.

City of San Marcos. 2013c. “Appendix E: CAP Consistency Worksheet & GHG Thresholds.” In City of San Marcos Climate Action Plan. http://www.san-marcos.net/Home/ShowDocument?id=7602.

CNRA (California Natural Resources Agency). 2009. 2009 California Climate Adaptation Strategy: A Report to the Governor of the State of California in Response to Executive Order S-13-2008. http://resources.ca.gov /docs/climate/Statewide_Adaptation_Strategy.pdf.

CNRA. 2014. Safeguarding California: Reducing Climate Risk—An Update to the 2009 California Climate Adaptation Strategy. July 2014. http://resources.ca.gov/docs/climate/Final_Safeguarding_CA_ Plan_July_31_2014.pdf.

County of San Diego. 2007. Guidelines for Determining Significance and Report and Format and Content Requirements – Air Quality. Land Use and Environment Group. Department of Planning and Land Use.

Department of Public Works. March 19, 2007.

County of San Diego. 2011. San Diego County General Plan: A Plan for Growth, Conservation, and Sustainability.

Adopted August 3, 2011. Accessed November 13, 2014. http://www.sandiegocounty.gov /pds/generalplan.html.

CPUC (California Public Utilities Commission). 2013. “California’s Zero Net Energy Policies and Initiatives.” In NASEO Getting to Zero Conference. Presentation by C. Fogel, Demand Side Programs, Energy Division, CPUC.

September 18, 2013.

DOF (California Department of Finance). 2021. E-5 Population and Housing Estimates for Cities, Counties and the State – May 2021. Accessed April 27, 2022. https://dof.ca.gov/Forecasting/Demographics/Estimates/estimates-e5- 2010-2021/

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EPA (Environmental Protection Agency). 1980. AP-42, Section 13.3 – Explosives Detonation. Accessed October 2018. https://www3.epa.gov/ttnchie1/ap42/ch13/final/c13s03.pdf.

EPA. 1998. AP-42, Section 11.9 – Western Surface Coal Mining. Accessed October 2018. https://www3.epa.gov /ttnchie1/ap42/ch11/final/c11s09.pdf.

EPA. 2004. AP-42, Section 11.9.2 – Crushed Stone Processing and Pulverized Mineral Processing. Accessed October 2018. https://www3.epa.gov/ttnchie1/ap42/ch11/final/c11s09.pdf.

EPA. 2006. AP-42, Section 13.2.4 – Aggregate Handling and Storage Piles. Accessed October 2018. https://www3.epa.gov/ttnchie1/ap42/ch13/final/c13s0204.pdf.

EPA. 2016a. “Criteria Air Pollutants.” https://www.epa.gov/criteria-air-pollutants.

EPA. 2016b. Region 9: Air Quality Analysis, Air Quality Maps. March 2017 http://www.epa.gov/region9 /air/maps/.

EPA. 2016c. “Sulfur Dioxide Designations: EPA Completes Second Round of Sulfur Dioxide Designations.” Accessed June 30, 2016. https://www.epa.gov/sulfur-dioxide-designations/epa-completes-second-round- sulfur-dioxide-designations.

EPA. 2016d. “Glossary of Climate Change Terms.” July 10, 2017. https://www3.epa.gov/climatechange /glossary.html
EPA. 2017a. “Climate Change.” Last updated January 19, 2017. https://www.epa.gov/ climatechange.

EPA. 2017b. Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990–2015. EPA 430-P-17-001. https://www.epa.gov/sites/production/files/2017-02/documents/2017_complete_report.pdf.

EPA. 2017c. Midterm Evaluation of Light-Duty Vehicle Greenhouse Gas (GHG) Emissions Standards for Model Years 2022-2025. https://www.epa.gov/regulations-emissions-vehicles-and-engines/midterm-evaluation- light-duty-vehicle-greenhouse-gas-ghg.

EPA and NHTSA (U.S. Environmental Protection Agency and National Highway Traffic Safety Administration). 2016.

Regulations and Standards: Heavy-Duty. EPA and DOT Finalize Greenhouse Gas and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles. Last updated August 2016. https://www.epa.gov/newsreleases/epa-and-dot-finalize-greenhouse-gas-and-fuel-efficiency-standards- heavy-duty-trucks-0.

EPA and NHTSA. 2018. U.S. EPA and DOT Propose Fuel Economy Standards for MY 2021-2026 Vehicles. August 2, 2018. https://www.epa.gov/newsreleases/us-epa-and-dot-propose-fuel-economy-standards-my-2021- 2026-vehicles.

IPCC (Intergovernmental Panel on Climate Change). 1995. IPCC Second Assessment: Climate Change 1995. A Report of the Intergovernmental Panel on Climate Change. Geneva, Switzerland: IPCC. https://www.ipcc.ch/pdf /climate-changes-1995/ipcc-2nd-assessment/2nd-assessment-en.pdf.

GRAN VISTA PROJECT / AIR QUALITY AND GREENHOUSE GAS EMISSIONS TECHNICAL REPORT

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IPCC. 2007. Climate Change 2007: Synthesis Report. A Report of the Intergovernmental Panel on Climate Change. Geneva, Switzerland: IPCC. https://www.ipcc.ch/publications_and_data/publications_ipcc_ fourth_assessment_report_synthesis_report.htm.

IPCC. 2013. Climate Change 2014: Synthesis Report. Contribution of Working Groups I, II and III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change, edited by R.K. Pachauri and L.A.

Meyer. Geneva, Switzerland: IPCC. https://www.ipcc.ch/report/ar5/syr/.

IPCC. 2014. “Summary for Policymakers.” In Climate Change 2014 Synthesis Report. A Report of the Intergovernmental Panel on Climate Change. Contribution of Working Groups I, II, and III to the Fifth Assessment Report of the IPCC. Geneva, Switzerland: IPCC. http://www.ipcc.ch/report/ar5/syr/.

Nelson, J. 2018. Coccidioidomycosis Data Requests. Email from J. Nelson (County of San Diego Health & Human Services Agency, Epidemiologist II) to R. Kelly (Dudek). June 19, 2018.

NHTSA (National Highway Traffic and Safety Administration). 2016. “EPA and DOT Finalize Greenhouse Gas and Fuel Efficiency Standards for Heavy-Duty Trucks.” https://www.nhtsa.gov/press-releases/epa-and-dot- finalize-greenhouse-gas-and-fuel-efficiency-standards-heavy-duty-trucks.

SANDAG (San Diego Association of Governments). 2002. (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region. http://sandiegohealth.org/sandag/sandag_pubs_2009-725 /publicationid_1140_5044.pdf.

SANDAG. 2013. Series 13 Regional Growth Forecast City of San Marcos. http://datasurfer.sandag.org /download/sandag_forecast_13_jurisdiction_san-marcos.pdf.

SANDAG. 2015. San Diego Forward: The Regional Plan. October 2015. http://www.sdforward.com/pdfs/ RP_final/The%20Plan%20-%20combined.pdf.

SANDAG. 2022. Land Use Data by Master Geographic Reference Area. November 15.

SCAQMD (South Coast Air Quality Management District). 1993. CEQA Air Quality Handbook. http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook.

SCAQMD. 2008. Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold.

October 2008. http://planning.rctlma.org/Portals/0/Major%20Planning%20Efforts /pp25422/Orginal%20FEIR/SCAQMD%202008%20Final%20Interim%20Proposal.pdf.

SDAPCD (San Diego Air Pollution Control District). 1976. Regulation IV: Prohibitions; Rule 51: Public Nuisance.

Accessed February 2017. http://www.sdapcd.org/content/dam/sdc/ apcd/PDF/Rules_and_Regulations/Prohibitions/APCD_R50-1-51.pdf.

SDAPCD. 1997. Regulation IV: Prohibitions; Rule 50: Visible Emissions. Effective August 13, 1997. Accessed July 27, 2018. https://www.sdapcd.org/content/dam/sdc/apcd/PDF/Rules_and_Regulations /Prohibitions/APCD_R50.pdf.

GRAN VISTA PROJECT / AIR QUALITY AND GREENHOUSE GAS EMISSIONS TECHNICAL REPORT

13528 78 APRIL 2022

SDAPCD. 1998. Regulation II: Permits; Rule 20.2: New Source Review Non-Major Stationary Sources. Effective December 17, 1998. Accessed July 27, 2018. https://www.sdapcd.org/content/dam/sdc /apcd/PDF/Rules_and_Regulations/Permits/APCD_R20-2.pdf.

SDAPCD. 2007. Guidelines for Determining Significance and Report Format and Content Requirements Air Quality. http://www.sandiegocounty.gov/content/dam/sdc/pds/ ProjectPlanning/docs /AQ-Guidelines.pdf
SDAPCD. 2009. Regulation IV: Prohibitions; Rule 55: Fugitive Dust. Adopted June 24, 2009; effective December 24, 2009. Accessed December 12, 2016. http://www.sdapcd.org/content/dam/sdc/apcd /PDF/Rules_and_Regulations/Prohibitions/APCD_R55.pdf.

SDAPCD. 2012. Redesignation Request and Maintenance Plan for the 1997 National Ozone Standard for San Diego County. Adopted December 5, 2012. San Diego, California: SDAPCD. http://www.sandiegocounty.gov/content/dam/sdc/apcd/PDF/Air%20Quality%20Planning/8_Hour_O3_M aint-Plan.pdf.

SDAPCD. 2015. Regulation IV: Prohibitions; Rule 67.0.1: Architectural Coatings. Adopted June 24, 2015. Effective January 1, 2016. Accessed December 12, 2016. http://www.sdapcd.org/content/dam/sdc/apcd /PDF/Rules_and_Regulations/Prohibitions/APCD_R67-0-1.pdf.

SDAPCD. 2016. 2008 Eight-Hour Ozone Attainment Plan for San Diego County. Final. December 2016. San Diego, California: SDAPCD. http://www.sandiegocounty.gov/content/dam/sdc/apcd/PDF /Air%20Quality%20Planning/8-Hr-O3%20Attain%20Plan-08%20Std.pdf.

Under 2 Coalition. 2015. “Global Climate Leadership Memorandum of Understanding (MOU).” http://under2mou.org/the-mou/.

USGS (United States Geological Survey). 2000. Operational Guidelines (version 1.0) for Geological Fieldwork in Areas 1 Endemic for Coccidioidomycosis (Valley Fever).

WRCC (Western Regional Climate Center). 2017. “Monthly Climate Summary San Diego Lindbergh Field, California (047740).” Accessed June 2018. https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca7740.

13528 79 MARCH 2023

5 List of Preparers
Adam Poll, Senior Air Quality Specialist

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Appendix A
CalEEMod Output Files

Table of Contents
Summer
2 Winter
34 Annual 2030 CAP
66 Annual Existing Land Use
106
GHG Reductions
138
PVWatts Calculator-Existing Commercial
141
Gran Vista Specific Plan
San Diego County APCD Air District, Summer
Project Characteristics -
Land Use - Based on site plan for project.

Construction Phase - Based on applicant provided information.

Off-road Equipment - Based on applicant provided information.

Trips and VMT - Based on applicant provided information.

1.1 Land Usage
Land Uses
Size
Metric
Lot Acreage
Floor Surface Area
Population
Other Asphalt Surfaces

2.14 Acre

2.14 93,218.40
0 Parking Lot

20.00 Space

0.18 8,000.00
0 City Park

3.40 Acre

3.40 148,104.00
0 Condo/Townhouse High Rise
120.00
Dwelling Unit

1.88 120,000.00
343

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
13 Wind Speed (m/s)
Precipitation Freq (Days)

2.6 40

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company
San Diego Gas & Electric
2025
Operational Year
CO2 Intensity
(lb/MWhr)
539.98

0.033
CH4 Intensity
(lb/MWhr)

0.004
N2O Intensity
(lb/MWhr)
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On-road Fugitive Dust - CalEEmod defaults.

Grading - CalEEmod defaults.

Architectural Coating - Low-VOC content coatings to be used onsite.

Vehicle Trips - Based on traffic assessment for project.

Road Dust - CalEEmod defaults.

Woodstoves - No wood or natural gas.

Consumer Products - CalEEmod defaults.

Area Coating - Low-VOC coatings to be used.

Landscape Equipment - CalEEmod defaults.

Energy Use - CalEEMod defaults.

Water And Wastewater - CalEEmod defaults.

Solid Waste - CalEEmod defaults.

Construction Off-road Equipment Mitigation - In accordance with SDAPCD Rule 55. Applicant has committed to Tier 4 Interim equipment over 50 horsepower, electric under 50 horsepower.

Mobile Land Use Mitigation -
Area Mitigation - Low-VOC architectural coatings and no hearths.

Energy Mitigation - Energy star appliances
Water Mitigation - low-flow fixtures and water-efficient irrigation Table Name
Column Name
Default Value
New Value
tblArchitecturalCoating
EF_Nonresidential_Exterior
250.00
150.00
tblArchitecturalCoating
EF_Nonresidential_Interior
250.00
100.00
tblArchitecturalCoating
EF_Parking
250.00
100.00
tblArchitecturalCoating
EF_Residential_Exterior
250.00
100.00
tblArchitecturalCoating
EF_Residential_Interior
250.00

50.00 tblAreaCoating
Area_EF_Parking
250
100
tblAreaCoating
Area_EF_Residential_Exterior
250
100
tblAreaCoating
Area_EF_Residential_Interior
250
50 tblAreaMitigation
UseLowVOCPaintParkingCheck
False
True
tblAreaMitigation
UseLowVOCPaintParkingValue
250
100
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tblAreaMitigation
UseLowVOCPaintResidentialExteriorValu
e
250
100
tblAreaMitigation
UseLowVOCPaintResidentialInteriorValu
e
250
50 tblConstDustMitigation
WaterUnpavedRoadVehicleSpeed
0 15
tblConstEquipMitigation
FuelType
Diesel
Electrical
tblConstEquipMitigation
NumberOfEquipmentMitigated

0.00 3.00
tblConstEquipMitigation
NumberOfEquipmentMitigated

0.00 1.00
tblConstEquipMitigation
NumberOfEquipmentMitigated

0.00 2.00
tblConstEquipMitigation
NumberOfEquipmentMitigated

0.00 1.00
tblConstEquipMitigation
NumberOfEquipmentMitigated

0.00 2.00
tblConstEquipMitigation
NumberOfEquipmentMitigated

0.00 3.00
tblConstEquipMitigation
NumberOfEquipmentMitigated

0.00 1.00
tblConstEquipMitigation
NumberOfEquipmentMitigated

0.00 4.00
tblConstEquipMitigation
NumberOfEquipmentMitigated

0.00 1.00
tblConstEquipMitigation
NumberOfEquipmentMitigated

0.00 5.00
tblConstEquipMitigation
NumberOfEquipmentMitigated

0.00 1.00
tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
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tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
tblConstEquipMitigation
Tier
No Change
Tier 4 Interim
tblConstructionPhase
NumDays
230.00
262.00
tblConstructionPhase
NumDays

20.00 24.00
tblConstructionPhase
NumDays

10.00 6.00
tblConstructionPhase
PhaseEndDate
1/23/2025
3/10/2025
tblConstructionPhase
PhaseEndDate
11/28/2024
2/10/2025
tblConstructionPhase
PhaseEndDate
12/26/2024
2/8/2024
tblConstructionPhase
PhaseEndDate
12/14/2023
12/8/2023
tblConstructionPhase
PhaseStartDate
12/27/2024
2/11/2025
tblConstructionPhase
PhaseStartDate
1/12/2024
2/9/2024
tblConstructionPhase
PhaseStartDate
12/15/2023
12/9/2023
tblConstructionPhase
PhaseStartDate
11/29/2024
1/12/2024
tblFireplaces
FireplaceDayYear

82.00 0.00
tblFireplaces
FireplaceHourDay

3.00 0.00
tblFireplaces
FireplaceWoodMass
3,078.40

0.00 tblFireplaces
NumberGas

66.00 0.00
tblFireplaces
NumberNoFireplace

12.00 0.00
tblFireplaces
NumberWood

42.00 0.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

1.00 0.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

3.00 2.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

2.00 3.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

3.00 0.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

3.00 1.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

4.00 3.00
tblOffRoadEquipment
UsageHours

7.00 4.00
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tblOffRoadEquipment
UsageHours

7.00 4.00
tblTripsAndVMT
VendorTripNumber

0.00 4.00
tblTripsAndVMT
VendorTripNumber

0.00 4.00
tblTripsAndVMT
WorkerTripNumber

10.00 12.00
tblTripsAndVMT
WorkerTripNumber

18.00 16.00
tblTripsAndVMT
WorkerTripNumber

18.00 16.00
tblTripsAndVMT
WorkerTripNumber
191.00
192.00
tblVehicleTrips
DV_TP

11.00 0.00
tblVehicleTrips
HO_TL

7.50 0.00
tblVehicleTrips
HO_TTP

39.60 0.00
tblVehicleTrips
HS_TL

7.30 0.00
tblVehicleTrips
HS_TTP

18.80 0.00
tblVehicleTrips
HW_TL

10.80 6.58
tblVehicleTrips
HW_TTP

41.60 100.00
tblVehicleTrips
PB_TP

3.00 0.00
tblVehicleTrips
PR_TP

86.00 100.00
tblVehicleTrips
ST_TR

1.96 0.00
tblVehicleTrips
ST_TR

4.91 8.00
tblVehicleTrips
SU_TR

2.19 0.00
tblVehicleTrips
SU_TR

4.09 8.00
tblVehicleTrips
WD_TR

0.78 0.00
tblVehicleTrips
WD_TR

5.44 8.00
tblWoodstoves
NumberCatalytic

6.00 0.00
tblWoodstoves
NumberNoncatalytic

6.00 0.00
tblWoodstoves
WoodstoveDayYear

82.00 0.00
tblWoodstoves
WoodstoveWoodMass
3,019.20

0.00 CalEEMod Version: CalEEMod.2020.4.0
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2.0 Emissions Summary
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2.1 Overall Construction (Maximum Daily Emission)
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Year
lb/day
lb/day
2023

4.4151

46.6481

32.0241

0.0810

11.4831

1.8484

13.3315

3.9254

1.7006

5.6260

0.0000
7,855.752
6 7,855.752
6 2.4800

0.0157
7,922.439
9 2024

4.2795

43.7091

31.3097

0.0809

11.4831

1.7408

13.2239

3.9254

1.6016

5.5270

0.0000
7,846.053
8 7,846.053
8 2.4784

0.2026
7,912.576
9 2025

48.6039

13.6184

19.9009

0.0493

1.9430

0.4895

2.4324

0.5237

0.4727

0.9964

0.0000
4,874.135
4 4,874.135
4 0.4207

0.1973
4,943.444
3 Maximum

48.6039

46.6481

32.0241

0.0810

11.4831

1.8484

13.3315

3.9254

1.7006

5.6260

0.0000
7,855.752
6 7,855.752
6 2.4800

0.2026
7,922.439
9 Unmitigated Construction
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Year
lb/day
lb/day
2023

1.3599

21.5772

43.1463

0.0810

5.2546

0.1310

5.3856

1.7899

0.1309

1.9208

0.0000
7,855.752
6 7,855.752
6 2.4800

0.0157
7,922.439
9 2024

1.3571

21.5733

43.1191

0.0809

5.2546

0.1310

5.3856

1.7899

0.1309

1.9208

0.0000
7,846.053
8 7,846.053
8 2.4784

0.2026
7,912.576
9 2025

48.4876

11.0781

19.5829

0.0467

1.9430

0.0772

2.0202

0.5237

0.0760

0.5996

0.0000
4,666.657
6 4,666.657
6 0.4010

0.1973
4,735.473
7 Maximum

48.4876

21.5772

43.1463

0.0810

5.2546

0.1310

5.3856

1.7899

0.1309

1.9208

0.0000
7,855.752
6 7,855.752
6 2.4800

0.2026
7,922.439
9 Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0
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ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio-CO2
Total CO2
CH4
N20
CO2e
Percent
Reduction

10.64 47.84
-27.17

1.21 50.01

91.69 55.87

51.00 91.05

63.45 0.00

1.01 1.01

0.37 0.00

1.00 CalEEMod Version: CalEEMod.2020.4.0
Date: 9/20/2022 8:45 AM

Page 8 of 32 ends

Gran Vista Specific Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

2.2 Overall Operational
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Area

3.1736

0.1140

9.8934

5.2000e-
004

0.0549

0.0000

17.8319

0.0171

0.0000

18.2590
Energy

0.0258

0.2205

0.0938

1.4100e-
003

0.0178

0.0178
281.4266
281.4266

5.3900e-
003

5.1600e-
003
283.0990
Mobile

2.4482

2.3053

20.6088

0.0447

4.8402

0.0338

4.8740

1.2893

0.0315

1.3208
4,552.962
4 4,552.962
4 0.3159

0.1979
4,619.826
3 Total

5.6476

2.6397

30.5960

0.0466

4.8402

0.1065

4.9467

1.2893

0.1042

1.3935

0.0000
4,852.220
8 4,852.220
8 0.3384

0.2030
4,921.184
2 Unmitigated Operational
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Area

3.1736

0.1140

9.8934

5.2000e-
004

0.0549

0.0000

17.8319

0.0171

0.0000

18.2590
Energy

0.0258

0.2205

0.0938

1.4100e-
003

0.0178

0.0178
281.4266
281.4266

5.3900e-
003

5.1600e-
003
283.0990
Mobile

2.0278

1.6251

14.3162

0.0281

2.9954

0.0223

3.0176

0.7979

0.0208

0.8187
2,866.473
4 2,866.473
4 0.2320

0.1415
2,914.426
1 Total

5.2272

1.9595

24.3034

0.0301

2.9954

0.0950

3.0903

0.7979

0.0935

0.8914

0.0000
3,165.731
9 3,165.731
9 0.2545

0.1466
3,215.784
0 Mitigated Operational
CalEEMod Version: CalEEMod.2020.4.0
Date: 9/20/2022 8:45 AM

Page 9 of 32 ends

Gran Vista Specific Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name
Phase Type
Start Date
End Date
Num Days
Week
Num Days
Phase Description
1 Site Preparation
Site Preparation
12/1/2023
12/8/2023
5 6
2 Grading
Grading
12/9/2023
1/11/2024
5 24
3 Building Construction
Building Construction
2/9/2024
2/10/2025
5 262
4 Paving
Paving
1/12/2024
2/8/2024
5 20
5 Architectural Coating
Architectural Coating
2/11/2025
3/10/2025
5 20
OffRoad Equipment
Phase Name
Offroad Equipment Type
Amount
Usage Hours
Horse Power
Load Factor
Site Preparation
Rubber Tired Dozers
0 8.00
247

0.40 Site Preparation
Rubber Tired Loaders
1 8.00
203

0.36 Site Preparation
Tractors/Loaders/Backhoes
3 8.00
97 0.37
Grading
Excavators
0 8.00
158

0.38 Grading
Graders
1 8.00
187

0.41 Grading
Rubber Tired Dozers
1 8.00
247

0.40 ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio-CO2
Total CO2
CH4
N20
CO2e
Percent
Reduction

7.44 25.77

20.57 35.51

38.11 10.81

37.53 38.11

10.31 36.04

0.00 34.76

34.76 24.79

27.79 34.65
Residential Indoor: 243,000; Residential Outdoor: 81,000; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 6,073 (Architectural Coating
–
sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 120
Acres of Paving: 2.32
CalEEMod Version: CalEEMod.2020.4.0
Date: 9/20/2022 8:45 AM

Page 10 of 32 ends

Gran Vista Specific Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.1 Mitigation Measures Construction
Use Alternative Fuel for Construction Equipment
Use Cleaner Engines for Construction Equipment
Water Exposed Area
Reduce Vehicle Speed on Unpaved Roads
Grading
Scrapers
4 8.00
367

0.48 Grading
Tractors/Loaders/Backhoes
1 8.00
97 0.37
Building Construction
Air Compressors
2 8.00
78 0.48
Building Construction
Cranes
1 4.00
231

0.29 Building Construction
Forklifts
2 8.00
89 0.20
Building Construction
Generator Sets
1 8.00
84 0.74
Building Construction
Skid Steer Loaders
1 4.00
65 0.37
Building Construction
Tractors/Loaders/Backhoes
1 4.00
97 0.37
Building Construction
Welders
1 8.00
46 0.45
Paving
Pavers
2 8.00
130

0.42 Paving
Paving Equipment
2 8.00
132

0.36 Paving
Rollers
3 8.00
80 0.38
Architectural Coating
Air Compressors
1 6.00
78 0.48
Trips and VMT
Phase Name
Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Site Preparation
4 12.00

4.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
Grading
7 16.00

4.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
Building Construction
9 192.00

54.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
Paving
7 16.00

4.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
Architectural Coating
1 38.00

4.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
CalEEMod Version: CalEEMod.2020.4.0
Date: 9/20/2022 8:45 AM

Page 11 of 32 ends

Gran Vista Specific Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.2 Site Preparation - 2023
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

0.0000

0.0000
Off-Road

0.7246

7.2617

8.2037

0.0156

0.3163

0.2910

0.2910
1,510.290
6 1,510.290
6 0.4885
1,522.502
1 Total

0.7246

7.2617

8.2037

0.0156

0.0000

0.3163

0.0000

0.2910

0.2910
1,510.290
6 1,510.290
6 0.4885
1,522.502
1 Unmitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.0000

0.0000
Vendor

4.7800e-
003

0.1715

0.0618

8.2000e-
004

0.0271

1.0400e-
003

0.0281

7.8000e-
003

1.0000e-
003

8.8000e-
003

88.4188

2.6800e-
003

0.0128

92.3009
Worker

0.0328

0.0204

0.2880

8.7000e-
004

0.0986

5.3000e-
004

0.0991

0.0262

4.9000e-
004

0.0266

88.0397

2.3900e-
003

2.1900e-
003

88.7534
Total

0.0376

0.1918

0.3498

1.6900e-
003

0.1257

1.5700e-
003

0.1273

0.0340

1.4900e-
003

0.0354
176.4585
176.4585

5.0700e-
003

0.0150
181.0542
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 9/20/2022 8:45 AM

Page 12 of 32 ends

Gran Vista Specific Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

0.0000

0.0000
Off-Road

0.3120

5.7265

10.3774

0.0156

0.0255

0.0000
1,510.290
6 1,510.290
6 0.4885
1,522.502
1 Total

0.3120

5.7265

10.3774

0.0156

0.0000

0.0255

0.0000

0.0255

0.0000
1,510.290
6 1,510.290
6 0.4885
1,522.502
1 Mitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.0000

0.0000
Vendor

4.7800e-
003

0.1715

0.0618

8.2000e-
004

0.0271

1.0400e-
003

0.0281

7.8000e-
003

1.0000e-
003

8.8000e-
003

88.4188

2.6800e-
003

0.0128

92.3009
Worker

0.0328

0.0204

0.2880

8.7000e-
004

0.0986

5.3000e-
004

0.0991

0.0262

4.9000e-
004

0.0266

88.0397

2.3900e-
003

2.1900e-
003

88.7534
Total

0.0376

0.1918

0.3498

1.6900e-
003

0.1257

1.5700e-
003

0.1273

0.0340

1.4900e-
003

0.0354
176.4585
176.4585

5.0700e-
003

0.0150
181.0542
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 9/20/2022 8:45 AM

Page 13 of 32 ends

Gran Vista Specific Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.3 Grading - 2023
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

11.3246

0.0000

11.3246

3.8828

0.0000

3.8828

0.0000

0.0000
Off-Road

4.3666

46.4495

31.5784

0.0790

1.8467

1.6989

1.6989
7,649.947
6 7,649.947
6 2.4742
7,711.801
3 Total

4.3666

46.4495

31.5784

0.0790

11.3246

1.8467

13.1712

3.8828

1.6989

5.5817
7,649.947
6 7,649.947
6 2.4742
7,711.801
3 Unmitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.0000

0.0000
Vendor

4.7800e-
003

0.1715

0.0618

8.2000e-
004

0.0271

1.0400e-
003

0.0281

7.8000e-
003

1.0000e-
003

8.8000e-
003

88.4188

2.6800e-
003

0.0128

92.3009
Worker

0.0437

0.0272

0.3840

1.1600e-
003

0.1314

7.0000e-
004

0.1321

0.0349

6.5000e-
004

0.0355
117.3863
117.3863

3.1800e-
003

2.9300e-
003
118.3378
Total

0.0485

0.1986

0.4458

1.9800e-
003

0.1585

1.7400e-
003

0.1603

0.0427

1.6500e-
003

0.0443
205.8050
205.8050

5.8600e-
003

0.0157
210.6387
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 9/20/2022 8:45 AM

Page 14 of 32 ends

Gran Vista Specific Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.3 Grading - 2023
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

5.0961

0.0000

5.0961

1.7473

0.0000

1.7473

0.0000

0.0000
Off-Road

1.3114

21.3786

42.7005

0.0790

0.1292

0.0000
7,649.947
5 7,649.947
5 2.4742
7,711.801
2 Total

1.3114

21.3786

42.7005

0.0790

5.0961

0.1292

5.2253

1.7473

0.1292

1.8765

0.0000
7,649.947
5 7,649.947
5 2.4742
7,711.801
2 Mitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.0000

0.0000
Vendor

4.7800e-
003

0.1715

0.0618

8.2000e-
004

0.0271

1.0400e-
003

0.0281

7.8000e-
003

1.0000e-
003

8.8000e-
003

88.4188

2.6800e-
003

0.0128

92.3009
Worker

0.0437

0.0272

0.3840

1.1600e-
003

0.1314

7.0000e-
004

0.1321

0.0349

6.5000e-
004

0.0355
117.3863
117.3863

3.1800e-
003

2.9300e-
003
118.3378
Total

0.0485

0.1986

0.4458

1.9800e-
003

0.1585

1.7400e-
003

0.1603

0.0427

1.6500e-
003

0.0443
205.8050
205.8050

5.8600e-
003

0.0157
210.6387
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 9/20/2022 8:45 AM

Page 15 of 32 ends

Gran Vista Specific Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.3 Grading - 2024
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

11.3246

0.0000

11.3246

3.8828

0.0000

3.8828

0.0000

0.0000
Off-Road

4.2339

43.5144

30.8911

0.0790

1.7391

1.6000

1.6000
7,645.647
2 7,645.647
2 2.4728
7,707.466
1 Total

4.2339

43.5144

30.8911

0.0790

11.3246

1.7391

13.0637

3.8828

1.6000

5.4827
7,645.647
2 7,645.647
2 2.4728
7,707.466
1 Unmitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.0000

0.0000
Vendor

4.6000e-
003

0.1703

0.0604

8.0000e-
004

0.0271

1.0500e-
003

0.0281

7.8000e-
003

1.0000e-
003

8.8000e-
003

86.8772

2.7400e-
003

0.0126

90.6941
Worker

0.0411

0.0244

0.3582

1.1200e-
003

0.1314

6.7000e-
004

0.1321

0.0349

6.2000e-
004

0.0355
113.5294
113.5294

2.9000e-
003

2.7300e-
003
114.4167
Total

0.0457

0.1947

0.4186

1.9200e-
003

0.1585

1.7200e-
003

0.1603

0.0427

1.6200e-
003

0.0443
200.4066
200.4066

5.6400e-
003

0.0153
205.1108
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 9/20/2022 8:45 AM

Page 16 of 32 ends

San Marcos City CouncilJune 27, 2023

San Marcos City Council
June 27, 2023