Appendix N
Responses to Comment Letters Received
on the Draft EIR
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-1
Responses to Comment Letters Received on
the Draft EIR
The Draft EIR was circulated for public review from April 3 , 202 3, through May 18 , 202 3, in accordance with Section 15105(a) of the California Environmental Quality Act (CEQA) Guidelines. A total of thirteen (13) written comment letters were received on the Draft EIR from agencies and organizations, as shown in Table 1. Each of the written comment letters have been assigned an alphanumeric label, and the individual comments within each written comment letter are bracketed and numbered. For example, Comment Letter A1 contains one comment that is numbered A1-1.
The responses to each comment on the Draft EIR represent a good -faith, reasoned effort to address the environmental issues identified by the comments. Pursuant to Section 15088(a) of the CEQA Guidelines, the City of San Marcos (City), as lead agency, is not required to respond to all comm ents on the Draft EIR, but only those comments that raise environmental issues. In accordance with CEQA Guidelines Sections 15088 and 15204, the City has independently evaluated the comments and prepared the attached written responses to any significant environmental issues raised.
Table 1. Comment letters and Commenters
Comment Letter Commenter Date Received
Agency
A1 Vallecitos Water District April 4,2023
A2 California Department of Transportation (Caltrans) May 17, 2023 Organizations
O1 San Diego County Archaeological Society, Inc. April 13, 2023 Individuals
I1 Dale Armiyage May 3, 2023
I2 Kerianne Wilson May 8, 2023
I3 Mike Hazelton May 14, 2023
I4 Thomas J. Bryne May 15, 2023
I5 Kevin Wilson May 16, 2023
I6 Brent Mardian May 17, 2023
I7 Marie Marcinko May 18, 2023
I8 Dave Gazzano May 18, 2023
I9 Lorraine Terrell May 18, 2023
I10 C. Mardian May 18, 2023
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-2
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-3
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-4
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-5
Response to Comment Letter A1
Agency
Vallecitos Water District
April 4, 2023
A1-1 This comment notes that Vallecitos Water District received the Notice of Availability for the proposed project. The comment also notes that the developer completed a Water and Sewer Study with the District in March 2022, and that the developer will need to submit Improvement and Grading Plans to VWD for final reviewal. Final project plans will be submitted to VWD prior to construction. The comment does not raise any specific issues related to the adequacy of the EIR. No further response is required or necessary.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-6
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-7
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-8
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-9
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-10
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-11
Response to Comment Letter A2
Agency
Caltrans
May 17, 2023
A2-1 This introductory comment describes the project location and Caltrans’ mission to provide a safe and reliable transportation network that serves all people and respects the environment. The comment does not raise any specific issues related to the adequacy of the EIR. No further response is required or necessary.
A2-2 This comment states that the project’s VMT exceeds the regional threshold, and requests consideration of implementing other transportation improvements that would help mitigation the VMT impacts from the project as discussed in the EIR. This comment requests consideration of additional VMT reduction mitigation measures provided, to help meet the target VMT Threshold of 16.07% . Caltrans requested measures for consideration include providing pedestrian network improvements beyond the project site; extend the sidewalk along Mission Road west of the project site to north Pacific Street; bicycle clearance detection at signalized intersections near the project area; upgrading signalized intersections to smart intersections with leading pedestrian intervals; bicycle signal for the Inland Rail Trail at North Las Posas Road; signage within the project area to promote transit access; and e-scooter/e-bike stations.
In response, and as outlined in Section 3.15 of the EIR, the project site is located in an area surrounded by development wi th numerous bicycle, pedestrian, and transit facilities . Class II bike lanes are provided on North Las Posas Road and West Mission Road. Additionally, a Class I multi-use path exists along the south side of W est Mission Road. Pedestrian sidewalks are provi ded throughout the area, with pedestrian crossings located at intersections surrounding the project site. The project site is designated as a High Quality Transit Area due to its proximity to transit and other facilities and services that support alternatives to vehicle use. Palomar College Transit Center, an NCTD hub, is located less than 0.25 miles from the project site. Palomar College Transit Center consists of a bus depot on the north side of West Mission Road, near the main entrance to Palomar College, and a train station on the south side of West Mission Road that serves the SPRINTER hybrid rail train. Rail service and bus transit service offered at the Transit Center provide local and regional connections to schools, employment, shopping, and entertainment options within the City, as well as San Diego and Riverside Counties. An existing bus turnout and stop are also located on West Mission Road in front of CVS. The existing public pedestrian network, specifically the sidewalk along West Mission Road west of the project site to North Pacific Street, cannot be extended due to physical constraints as well as the fact that the applicant does not own or control the property to the west and cannot anticipate driveway openings or other potential improvements on that site. The other measures suggested by Caltrans are not quantifiable.
The project is located within a 0.25-mile of a major transit stop, and as part of the City’s Climate Action Plan (CAP) the project is implementing a transit demand management stra tegy. The project would provide pedestrian connections throughout all uses on-site and connection to adjacent sidewalks and existing roadways. Buildings on site would be arranged to create direct and frequent walkway connections throughout the site and to adjacent public sidewalks along N orth Las Posas Road and West Mission Road. Walkways would be designed to provide access in accordance with the Americans with Disability Act (ADA) and to promote walkability and connect people to surrounding transit and places. The project would provide shared use access for bicycles within the project’s private drives that
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-12
would connect to existing Class II bike lanes on N orth Las Posas Road and West Mission Road. These facilities also connect to the nearby Inland Rail Trail, located along the south side of West Mission Road.
All living units would provide bicycle storage and showers. Telecommuting is resident-based but will be encouraged. The TDM Plan is a proposed condition of approval prior to building occupancy.
Regarding Caltrans’ request for e-scooter/e-bike stations, this type of program requires administration.
Since this is a relatively small for-sale housing project, consisting of a limited number of individual homeowners, administration of this type of program is not feasible. Additionally, per the CAPCOA handbook (page 37), “…there is limited defensible research on the GHG reductions associated with small scale, site-specific bike-share programs.” Furthermore, the practicality of these services is that they have become burdensome to many jurisdictions because u sers leave the scooters/bikes around town instead of returning them to the stations.
As outlined in Section 3.15 of the EIR, the proposed project’s VMT per resident is not anticipated to fall under the significance threshold as the project site is located in a suburban area that includes single - family homes with higher automobile ownership as compared to the region. However, while the proposed project is located on an infill site and is consistent with Climate Action Plan and SANDAG’s Regional Plan, impacts related to VMT per resident would not be reduced to 85% of the regional average. This impact is primarily a result of the geographic location of the proposed project in a suburban neighborhood, as trip characteristics of the surrounding residential land uses are used as a surrogate to estimate proposed project trip characteristics, regardless of the inherent differences between the land uses. To reduce the average VMT per resident, the proposed project would implement a TDM Program. The TDM program would facilitate increased opportunities for walking and bicycling, as well as provide the resources, means, and incentives for ride sharing and carpooling.
The SANDAG Mobility Management Guidebook/VMT Reduction Tool was taken into consideration initially; however, this tool does not provide strategies that are applicable to project. Therefore, the methods and strategies contained in the California Air Pollution Control Officers Association Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity were considered . The City coordinated with the project applicant to review the feasibility of mitigation options that are identified in the City’s Traffic Impact Assessment Guidelines (TIA Guidelines) specifically the Applicable VMT Reduction Strategies. Mitigation measures MM-TRA-1 through MM-TRA-3 outlined in Section 3.15 of the EIR are proposed accordingly.
Although Caltrans suggests seven measures to reduce VMT, there is no substantial evidence presented demonstrating that implementation of these measures would reduce VMT impacts. The comment also does not provide substantial evidence that the EIR analysis is inadequate.
A2-3 The comment refers to complete streets and mobility, and states that Caltrans supports transit, pedestrian, and transit improvements. The comment states that Caltrans looks forward to potential opportunities to coordinate with the City to meet multi -modal mobility needs and reduce GHG emissions. The comment states that maintaining bicycle, pedestrian, and transit access during project construction is in accordance with Caltrans’ goals and policies.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-13
In response, the comment does not raise any specific issues related to the adequacy of the EIR. The commenter is referred to Section 3.15.4, Project Impact Analysis, of the EIR, Threshold 1, which discusses the transit, bicycle, and pedestrian facility impacts. As described therein, Class II bike lanes are provided on N orth Las Posas Road and W est Mission Road. Additionally, a Class I multi -use path exists along the south side of West Mission Road. This Class I multi-use path is identified as the Inland Rail Trail, which consists of 21 miles of proposed facilities that will eventually connect the Cities of Oceanside and Escondido while passing through the Cities of San Marcos and Vista and unincorporated areas of the San Diego County. Pedestrian sidewalks are provided throughout the area, with pedestrian crossings located at intersections surrounding the project site. The project site is designated as a High Quality Transit Area due to its proximity to transit and other facilities and services that support alternatives to vehicle use. Palomar College Transit Center, an NCTD hub, is located less than 0.25 miles from the project site. Palomar College Transit Center consists of a bus depot on the north side of West Mission Road, near the main entrance to Palomar College, and a train station on the south side of West Mission Road that serves the SPRINTER hybrid rail train. Rail serv ice and bus transit service offered at the Transit Center provide local and regional connections to schools, employment, shopping, and entertainment options within the City, as well as San Diego and Riverside Counties. An existing bus turnout and stop are also located on W est Mission Road in front of CVS. As concluded in the LTA prepared for the project (Appendix K -1 to the EIR), the proposed project would not conflict with any existing or planned transit facilities and would not result in any impacts to tr ansit facilities. Similarly, the proposed project would not conflict with existing bicycle facilities and would not result in any impacts to bicyclist safety and accessibility. Sidewalks are proposed at the project frontage on West Mission Road to connect to existing sidewalk on North Las Posas Road and West Mission Road .
Sidewalks are also proposed throughout the internal roadways providing direct access to the proposed residential units and on -site amenities. Furthermore, with project implementation of th e LTA recommendations outlined below, the overall pedestrian environment would be enhanced for both walkability and safety and would not result in any impacts to pedestrian facilities. Project circulation would be designed to comply with the following recommendations of the TIA, as required by conditions of approval:
1. Driveways would be constructed in accordance with City standards.
2. Stop sign (R1-1) would be installed at project driveway no. 2.
3. High visibility pedestrian crossings where crossing is allowed would be installed at project driveway no. 1 and north leg of North Las Posas Road and West Mission Road Intersection.
4. Existing traffic detection camera would be modified (or new traffic loops would be installed) at traffic signal serving driveway no. 1 to accommodate queuing vehicles exiting through this driveway.
5. Appropriate signage would be posted to warn drivers of pedestrian foot traffic.
6. Installation of speed cushions/bumps along internal roadways would be considered to calm traffic.
Further, as described in Section 3.15.4; all proposed circulation improvements would be designed in accordance with the City’s roadway design standards to ensure proper safety requirements are met.
For any potential construction related activities in the public right-of-way during the construction period, applicable City regulations and policies require two -way traffic to be maintained, which would accommodate bikes and transit.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-14
A2-4 This comment describes Caltrans implementation of Complete Streets and Climate Change policies into State Highway Operations and Protection Program (SHOPP) projects to meet multi-model mobility needs, in order to reduce greenhouse gas emissions and achieve California’ s Climate Change target.
The comment states that Caltrans looks forward to working with the City to evaluate potential Complete Streets projects. The City acknowledges the comment, which does not raise any specific issues related to the adequacy of the EIR . Please refer to the proposed project improvements outlined in Response to Comment A2-3.
A2-5 The comment states that Caltrans recognizes that teleworking and remote learning reduces impacts of traffic, which reduces VMT and GHG emissions. The comment sta tes that reliable high -speed broadband is a key component in reaching the state’s transportation and climate action goals.
The City acknowledges the comment, which does not raise any specific issues related to the adequacy of the EIR. The commenter is referred to Section 3.17, Utilities and Service Systems, of the EIR, which identifies that telecommunications services to the project site may be provided by various distributors including AT&T and Cox Communications. The project connection to telecommunicat ions services is facilitated by existing lines that surround the site.
A2-6 The comment states that perpetuation of survey monuments by a licensed land surveyor is required, if they are being destroyed by any construction. No survey monuments are expected to be destroyed during project construction ; however, should any survey monuments be destroyed during project construction they would be replaced in kind per Business and Pro fession Code 8771. The comment also states that any work performed within Caltran s’ right-of-way will require discretionary review and approval by Caltrans and an encroachment permit will be required for any work within the Caltrans’ right-of-way prior to construction. The City acknowledges this comment. The comment does not raise any specific issues related to the adequacy of the Draft EIR.
A2-7 This comment concludes the letter, providing the commenter’s contact information. The comment does not raise any specific issues related to the adequacy of the EIR. No further response is req uired or necessary.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-15
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-16
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-17
Response to Comment Letter O1
Organization
San Diego County Archaeological Society, Inc.
April 13, 2023
O1-1 The comment states that the Environmental Review Committee of the San Diego County Archaeological Society has reviewed the cultural resource aspects of the Draft EIR and accepts the proposed mitigation measures and the impact analysis conclusions detailed in the Draft EIR. The comment does not raise any specific issues related to the adequacy of the EIR. No further response is required or necessary.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-18
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-19
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-20
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-21
Response to Comment Letter I1
Individual
Dale Armiyage
May 3, 2023
I1-1 This introductory comment introduces the project location and surrounding area and sets the discussion for comments to follow. The comment does not raise any specific issues related to the adequacy of the EIR. No further response is required or necessary.
I1-2 The comment s tates that the project corner of North Las Posas Road and Mission Road is already congested during rush hours for work and school and adding up to 264 cars that will need to access these roadways would worsen delays for the Santa Fe Hills and bordering neighborhoods. The comment provides no substantial evidence that the EIR analysis is inadequate. As outlined in Section 3.15 of the EIR, the project is consistent with SANDAG’s San Diego Forward: The Regional Plan policies and strategies to manage congestion, as it would develop in an area surrounded by existing development in a manner that would reduce VMT in comparison to development under the existing land use and zoning designation of Commercial (C). The project would incorporate safe acc ess to/from the project site and surrounding roadways and would not preclude the development of any specific improvement projects identified in the Regional Plan to reduce regional congestion. The project site is designated as a High Quality Transit Area due to its proximity to transit and other facilities and services that support alternatives to vehicle use.
As further outlined in Section 3.15 of the EIR, under CEQA, LOS or other measures of vehicle capacity or traffic congestion are no longer considered to be a significant impact on the environment. The effect of the project on traffic delay is not a significant impact under CEQA. However, a discussion of LOS is included to support the Local Transportation Analysis (LTA) and consider consistency with programs addressing the circulation system for informational purposes only. As outlined in the LTA (Appendix K- 1 to the EIR), no transportation study area roadway segments or intersections are anticipated to degrade in LOS to unacceptable levels with implementation of the project and no improvements would be required. The project is estimated to generate 960 average daily trips (ADT). VMT under the existing zoning was analyzed under the Existing Land Use Designation Alternative in DEIR Chapter 4. Under the existing zoning, traffic impacts are expected to be greater in comparison to the proposed project as a result of operational uses typical of such commercial uses, including daily transport and volume of large trucks. The estimated daily vehicle trips for this alternative are approximately 10,672 average daily trips, in comparison to the proposed project’s calculated 960 average daily trips. Because the project’s vehicle miles traveled (VMT) per resident is estimated to be more than 15% above the regionwide average, impacts were determined to be potentially significant absent mitigation. The proposed project’s VMT per resident is not anticipated to fall under the significance threshold as the project site is located in a suburban area that includes single -family homes with higher automobile ownership as compared to the region. However, while the proposed project is located on an infill site and is consistent with Climate Action Plan and SANDAG’s Regional Plan, impacts related to VMT per resident would not be reduced to 85% of the regional average. This impact is primarily a result of the geographic location of the propo sed project in a suburban neighborhood, as trip characteristics of the surrounding residential land uses are used as a surrogate to estimate proposed project trip characteristics, regardless of the inherent differences between the land uses. The project proposes implementation of mitigation measures MM-TRA-1 through MM-TRA-2, as outlined in Section 3.15 of the EIR, in an effort
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-22
to reduce VMT related impacts. However, even with implementation of proposed mitigation, impacts are determined to be significant a nd unavoidable for reasons outlined in Section 3.15 of the EIR and the Vehicle Miles Traveled (VMT) Analysis (Appendix K-2 to the EIR).
The City has prepared a Statement of Overriding Considerations which addresses this significant and unavoidable impact in relation to the project benefits and has determined that the project benefits outweigh the impact.
I1-3 The comment voices opinions in favor of the analyzed Reduced Density Alternative, that could be more beneficial for the Santa Fe Hills and surrounding neighborhoods while still allowing the development company to make a profit. The comment does not raise any specific issues related to the adequacy of the EIR. No further response is required or necessary.
I1-4 This comment raises technical and legal concerns regarding the project's traffic analysis determination of less than significant impacts . The comment provides no substantial evidence that the EIR analysis is inadequate. The individual argues that the Draft Environmental Impact Report makes presumptions of law to avoid evaluating transportation impacts. The comment states that the EIR avoids studying the impact of what happens at the North Las Posas Road and West Mission corner when morning commuters are already backed -up and a Sprinter train adds signal -light interruption. In response, a Local Transportation Analysis (LTA), and Vehicle Miles Traveled (VMT) Analysis Technical Memorandum were prepared for the projec t and are included as Appendix K -1 and K-2 to the EIR, respectively , and findings of these technical reports are outlined in Section 3.15 of the EIR.
The VMT analysis was prepared to satisfy the requirements of the California Environmental Quality Act (CEQA). The level of service (LOS) analysis conducted as a part of the LTA was used to evaluate the effects of the proposed project on the circulation network. Per the City of San Marcos Transportation Impact Analysis Guidelines, the City strives to maintain intersection and roadway segment operations based on LOS standards outlined in the City of San Marcos General Plan (General Plan) Mobility Element. A discussion of LOS is included to support the LTA and consider consistency with programs addressing the circulation system for informational purposes only. Under CEQA, LOS or other measures of vehicle capacity or traffic congestion are no longer considered to be a significant impact on the environment. The effect of the project on traffic delay is not a signifi cant impact under CEQA. For informational purposes, trip generation rates and distribution information are provided in the LTA. As outlined in Response to Comment I1-2, no transportation study area roadway segments or intersections are anticipated to degra de in LOS to unacceptable levels with implementation of the project and no improvements would be required. However, the potential CEQA environmental impact of the project in terms of vehicle trips is analyzed in terms of VMT, as analyzed in Appendix K-2 to the EIR.
As outlined in Section 3.15 of the EIR, the project is consistent with SANDAG’s San Diego Forward: The Regional Plan policies and strategies to manage congestion, as it would develop in an area surrounded by existing development in a manner that would reduce VMT in comparison to development under the existing land use and zoning designation of Commercial (C). The project would incorporate safe access to/from the project site and surrounding roadways and would not preclude the development of any specific improvement projects identified in the Regional Plan to reduce regional congestion.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-23
The traffic technical reports prepared for the project were prepared in compliance with applicable local and state regulations, including the City’s Transportation Impact Analysis Guidelines (City of San Marcos 2020). Project impacts related to traffic are adequately analyzed in Section 3.15 of the EIR.
I1-5 This comment states that opinions of Santa Fe Hills residents should be considered regarding the proposed development and its potential impact on traffic delays , and mentions the City only notified people within 500 feet of the project. In response, notification of residents/businesses/tenants within 500 feet of the project site is required by the City Zoning Ordinance. Additionally, a Notice of Application sign (informing the public of the proposal) was posted on the project site. The City issued the Notice of Preparation of an Environmental Impact Report and Scoping Meeting/Public Workshop for the project on April 20, 2022. The Notice of Preparation (NOP) was circulated, and Notifications were sent out in compliance with State requirements. The City requested written feedback from the public, interested organizations, and responsible trustee agen cies about the scope and content of the environmental information that would be addressed in the EIR. The NOP scoping period was April 20, 2022, through May 20, 2022, and a public meeting/workshop was held at the City on May 12, 2022, at 6 p.m. to gather additional public input. Five (5) members of the public attended the public meeting, and 11 comment letters were received in response to the NOP, which are included in Appendix A to the EIR.
The comments received were considered in preparation of the EIR. The comment provides no substantial evidence that the EIR analysis is inadequate.
I1-6 This comment s tates that the project would violate the vehicle miles traveled per capita metric and CEQA Guideline section 15064.3. The commenter expresses the opinion that the VMT per-person and proposed mitigation are not as important to the existing site neighbors as adding total vehicle traffic from the project into one intersection already congested at daily commute times. In response, please refer to Response to Comments I1-2 and I1-4. The comment provides no substantial evidence that the EIR analysis is inadequate.
I1-7 This comment states that the methodology for impacts on schools from project generated students is unclear, and that the project would delay K -12 and Palomar College students in their commutes. In response, as outlined in Section 3.13 of the EIR, student-age population for the project was estimated using the San Marcos Unified School District (SMUSD) student generation rates as described in the City’s General Plan, Land Use and Community Design Element. The SMUSD generation rates for elementary, middle and high school were multiplied by the proposed unit count to generate the student estimates outlined in Secti on 3.13 of the EIR. As outlined in Response to Comment I1 -2, the project would incorporate frontage improvements including safe access to/from the project site and surrounding roadways and would not preclude the development of any specific improvement proj ects identified in the Regional Plan to reduce regional congestion. The project site is designated as a High Quality Transit Area due to its proximity to transit and other facilities and services that support alternatives to vehicle use. The project would be required to obtain will-serve letters from the SMUSD or servicing schools to confirm such schools have adequate capacity, prior to project occupancy.
Furthermore, the project would be required to contribute development fees to SMUSD pursuant to California Education Code Section 17620 et seq. and Government Code Sections 65995(h) and 65996(b), as well as SMMC Section 17.52.050. Senate Bill (SB) 50 states that the fees imposed by school districts shall constitute the exclusive method of considering and mitigating impacts on school facilities caused by a development project. Such payment shall provide “full and complete mitigation of the impacts of a ny legislative or adjudicative act...on the provision of adequate school facilities”
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-24
(Government Code Section 65995(h)). As such, with contribution of required development fees, impacts to schools as a result of the project are determined to be less than s ignificant. The comment provides no substantial evidence that the EIR analysis is inadequate.
I1-8 This comment states that the project as proposed would place too many cars and people on -site, and would impact all surrounding residents, in particular at c ommuting times. In response, please refer to Response to Comment I1-2 and I1-4, as well as the traffic analysis provided in Appendix K-1 of the EIR.
The comment provides no substantial evidence that the EIR analysis is inadequate.
I1-9 This comment expresses concerns about water service for the project, and additional demands on Vallecitos Water District in addition to the other development projects in the City. In response, a Water and Sewer Study Technical Memorandum was prepared for the pro ject by Vallecitos Water District on March 23, 2022, and is included as Appendix L to the EIR. As outlined in Section 3.17 of the EIR, the Metropolitan Water District of Southern California (MWD) Urban Water Management Plan (UWMP) shows water supplies will be available to meet current and future demands of the region. With a projected annual water demand of 4,925,000 acre -feet per year in 2025, the MWD UWMP demonstrates that, with implementation of required conservation measures, MWD has supply capabilities sufficient to meet expected demands through 2040 under normal, single dry, and multiple dry water years (MWD 2021). The 42.26 acre-feet per year generated by the project would present an insignificant increase in water demand relative to the annual water demand project ed by the MWD’s UWMP. Additionally, VWD requires a development -specific evaluation of water use to determine its ability to service any development and capacity fees to be paid. A Water Availability letter will be required to confirm water service, prior t o issuance of building permits . Furthermore, the project site would be developed in compliance with CALGreen, which implements water efficiency standards for appliances and fixtures. Compliance with CALGreen would further reduce project water usage in combination with VWD and MWD’s ongoing water conservation practices. The comment pro vides no substantial evidence that the EIR analysis is inadequate.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-25
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-26
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-27
Response to Comment Letter I2
Individual
Kerianne Wilson
May 8, 2023
I2-1 The commenter provides an introduction as a resident and homeowner in San Marcos, specifically in the Santa Fe Hills area. The comment expresses strong opposition to the proposed project, as a result of existing and future traffic in the area. Th is comment does voice support for the Reduced Den sity Alternative. The comment does not raise any specific environmental issues related to the adequacy of the Draft EIR, and no further response is required.
I2-2 The commenter notes that she has already observed an increase in traffic to and from her home during the short time she has lived there. This comment also expresses concern about the potential danger to pedestrians in the area due to increased traffic from proposed and recently constructed housing developments and worries that prioritizing traffic over pedestrian safety could put people, especially students of Palomar College and San Marcos Middle School, at risk. In response, a Local Transportation Analysis (LTA), and Vehicle Miles Traveled (VMT) Analysis Technical Memorandum were prepared for the proposed project, and potential traffic impacts are outlined in Section 3.15 of the EIR. As analyzed in Section 3.15 of the EIR, pedestrian sidewalks are provided throughout the area, with pedestrian crossings located at intersections surrounding the project site. Sidewalks are proposed at the project frontage on West Mission Road to connect to existing sidewalk on North Las Posas Road and West Mission Road. Sidewalks are also proposed throughout the internal roadways providing direct access to the proposed residential units and on -site amenities. As outlined in the LTA (Appendix K -1), it is recommended that curb ramps at the project driveways be constructed, if needed, with detectable surface warning tactiles, and meeting all Americans with Disabilities Act (ADA) requirements. With project implementation of LTA recom mendations, the overall pedestrian environment would be enhanced for both walkability and safety and would not result in any impacts to pedestrian facilities.
As concluded in the LTA, the proposed project would not conflict with any existing or planned tra nsit facilities and would not result in any impacts to transit facilities. Similarly, the proposed project would not conflict with existing bicycle facilities and would not result in any impacts to bicyclist safety and accessibility. Please refer to Response to Comment I1-2 and I1-4. The comment provides no substantial evidence that the EIR analysis is inadequate.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-28
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-29
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-30
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-31
Response to Comment Letter I3
Individual
Mike Hazelton
May 14, 2023
I3-1 The commenter provides an introduction and location in proximity to the project. This comment also expresses general opposition to the project, stating that a grocery store is needed instead of condominiums, and questions where new residents of the project and other developments in the area will shop. Please refer to EIR Section 3.15 and EIR Chapter 4, which analyze development of a grocery store under the Existing Land Use Designation Alternative and show that such an alternative would increase impacts in co mparison to the proposed project. Additionally, the proposed site has been on the market for commercial development for many years with no proposals. The comment does not raise any specific issues related to the adequacy of the EIR. No further response is required or necessary.
I3-2 This comment states that the project is not compliant with CEQA Guidelines, and the project needs to have its own traffic assessment completed and mentions traffic concerns at the intersection of Palm Road and North Las Posas Road. The comment provides no substantial evidence that the EIR analysis is inadequate. A Local Transportation Analysis (LTA), and Vehicle Miles Traveled (VMT) Analysis Technical Memorandum were prepared for the project and were included as Appendix K-1 and K-2 to the Draft EIR. Under CEQA, LOS or other measures of vehicle capacity or traffic congestion are no longer considered to be a significant impact on the environment. The effect of the project on traffic delay is not a significant i mpact under CEQA. However, a discussion of LOS is included to support the Local Transportation Analysis (LTA) and consider consistency with programs addressing the circulation system for informational purposes only. As outlined in the LTA (Appendix K -1 to the EIR), no transportation study area roadway segments or intersections (including the intersection of Palm Road and North Las Posas Road) are anticipated to degrade in LOS to unacceptable levels with implementation of the project and no improvements woul d be required (please refer to Response to Comment I1-2 and I1-4). The comment does not raise any specific issues related to the adequacy of the EIR. No further response is required or necessary.
I3-3 This comment expresses concern about the project causing pollution in the area. The comment provides no substantial evidence that the EIR analysis is inadequate. As concluded in Section 3.2 of the Draft EIR, impacts related to air quality, including the ne t increase of any criteria pollutant, were determined to the less than significant. Furthermore, project impacts related to water quality and noise were determined to be less than significant , as analyzed in Sections 3.9 and 3.11 of the EIR. The comment concludes with general opposition for the proposed project but does not raise any issue concerning the adequacy of the Draft EIR; therefore, no further response is required.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-32
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-33
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-34
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-35
Response to Comment Letter I4
Individual
Thomas J. Byrne
May 15, 2023
I4-1 The comment serves as an introduction to comments that follow and thanks the City for the opportunity to comment on the project. This comment also shares that the commenter agrees with the significant and unavoidable impact determination in the EIR transportation section even with the proposed mitigation. The comment does not raise any issue concerning the adequacy of the Draft EIR; therefore, no further response is required or provided.
I4-2 This commenter expresses opinions and concerns of the proposed traffic mitigation measures MM - TRA-1 through MM-TRA-3 and states they are ineffective in reducing impacts . The commenter states that under MM -TRA-1 residents do not use the Sprinter or Breeze alternative transportation options and a ridership study could have been done. The commenter states that MM -TRA-2 will be ignored by potential residents and is unproven mitigation. Additionally, the comment states that the City does not have enough centers of activity to promote public transportation and there are not enough local services for current residents. Finally, the commenter states that bike parking under MM-TRA-3 will not reduce impacts as San Marcos is not a bicycle city and people drive instead.
In response, the commenter does not provide substantial evidence that the EIR analysis is inadequate, and there is no substantial evidence concerning the assertion that the impos ed mitigation measures will be ineffective. As outlined in Section 3.15 of the EIR, the proposed project’s VMT per resident is not anticipated to fall under the significance threshold as the project site is located in a suburban area that includes single -family homes with higher automobile ownership as compared to the region. To reduce the average VMT per resident, the proposed project would implement a TDM Program. The TDM program would facilitate increased opportunities for walking and bicycling, as well as provide the resources, means, and incentives for ridesharing and carpooling. The SANDAG Mobility Management Guidebook/VMT Reduction Tool was taken into consideration initially; however, this tool does not provide strategies that are applicable to the project. Therefore, the methods and strategies contained in the California Air Pollution Control Officers Association Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity were considered in preparation of the proposed mitigation measures . The City coordinated with the project applicant to review the feasibility of mitigation options that are identified in the City’s Traffic Impact Assessment Guidelines (TIA Guidelines) specifically the A pplicable VMT Reduction Strategies.
Mitigation measures MM -TRA-1 through MM -TRA-3 outlined in Section 3.15 of the EIR are proposed accordingly. Please also refer to Response to Comment A2-2.
I4-3 This comment expresses concern about the Horizon year 2050 not being reflective of actual conditions in 2050 and specifically expresses concerns about cumulative projects not being addressed in the traffic study. The commenter does not provide substantial evidence that the EIR analysis is inadequate.
A Local Transportation Analysis (LTA), and Vehicle Miles Traveled (VMT) Analysis Technical Memorandum were prepared for the project and are included as Appendix K-1 and K-2 of the EIR. The LTA (Appendix K-1 to the EIR) analyzes cumulative project traffic and cumulative project trip generation under “Near-Term Year 2024” conditions . Cumulative projects analyzed in the LTA were identified by the City as projects that are anticipated to contribute traffic within the project study area by the
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-36
proposed project’s opening year. The LTA’s cumulative project analysis methodology is consistent with the City’s TIA Guidelines. All cumulative projects listed in Table 6.1 of the LTA were required to analyze traffic impacts consistent with City guidelines including project-specific impacts on-site and within the transportation study area , provide necessary mitigation measures, design features, or improvement recommendations to address any potentially significant impacts, as was done for this proposed project.
Furthermore, all cumulative projects would be required to comply with applicable City regulations related to transportation and circulation, as the project does.
I4-4 This comment states that the “Palomar Station” project, located south of the project site, has not been able to fill all of its vacancies and there are residences already available. The commenter does not provide substantial evidence that the EIR analysis is inadequate. In response, as outlined in Section
3.12 of the EIR, the City is forecasted to grow from 96,302 persons in 2020 to 109,095 persons in 2035, which is a population increase of 12,793 (SANDAG 2013a). Additionally, SANDAG allocated 3,116 housing units to the San Marcos area for the 2021 –2029 Housing Element Cycl e (SANDAG 2021). Approval of the project could help the City accommodate the substantial population growth projected to occur within the City and the need for housing. Housing in the City continues to remain in demand. The comment does not raise any issue concerning the adequacy of the Draft EIR; therefore, no further response is required of provided.
I4-5 This comment states that the City will eventually try to get Las Posas Road to connect with Buena Creek.
The comment states that a previous study predic ted over 14,700 daily trips down Las Posas Road if that were to happen, and that this should be considered by the project and in a new 2050 traffic study.
The comment provides no substantial evidence that the EIR analysis is inadequate. Please refer to response to comment I4-3.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-37
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-38
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-39
Response to Comment Letter I5
Individual
Kevin Wilson
May 16, 2023
I5-1 This is an introductory comment and sets the discussion for comments to follow. The comment does not raise any specific issues related to the adequacy of the EIR. No further response is required or necessary.
I5-2 This commen t states that the City does not have the roadway/freeway infrastructure to support additional housing development and expresses concern for traffic impacts from the project, and further roadway congestion for existing residents in the area. The commenter does not provide substantial evidence that the EIR analysis is inadequate. In response, as discussed in Section 3.15 of the EIR, the project is estimated to generate 960 average daily trips (ADT). The LTA (Appendix K -1 to the EIR) analyzes cumulative project traffic and cumulative project trip generation under “Near -Term Year 2024” conditions. Cumulative projects analyzed in the LTA were identified by the City as projects that are anticipated to contribute traffic within the project study area by the proposed project’s opening year. The LTA’s cumulative project analysis methodology is consistent with the City’s TIA Guidelines. All cumulative projects listed in Table 6.1 of the LTA were required to analyze traffic impacts consistent with City guidelines, including project-specific impacts on-site and within the transportation study area, provide necessary mitigation measures, design features, or improvement recommendations to address any potentially significant impacts, as was done for this proposed project. Furthermore, all cumulative projects would be required to comply with applicable City regulations related to tra nsportation and circulation, as the project does. The comment does not raise any specific issues related to the adequacy of the EIR.
I5-3 The comment expresses support for the Existing Land Use Designation Alternative and acknowledges that although it may not decrease the traffic in the area, it would allow for the potential of it being in the opposite direction of residents who are leaving to commute to work. This comment also includes concluding remarks expressing general opposition to the project. In response, as outlined in Chapter 4 of the EIR, the commercial use of the site under the Existing Land Use Designation Alternative would be expected to result in greater impacts to air quality, energy, GHG emissions, hazards and hazardous materials, tran sportation, and utilities, in comparison to the impacts resulting from the proposed project’s residential use, and additional mitigation may be required. Specific to traffic, this alternative is expected to result in a larger volume of large trucks during operation to service the gas station and grocery store. Furthermore, the estimated daily vehicle trips for this alternative is approximately 10,672 average daily trips, in comparison to the proposed project’s calculated 960 average daily trips. This comment does not raise any specific issues related to the adequacy of the EIR.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-40
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-41
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-42
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-43
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-44
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-45
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-46
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-47
Response to Comment Letter I6
Individual
Brent Mardian
May 17, 2023
I6-1 The comment serves as an introduction to comments that follow and expresses disappointment with City Planning for supporting the project and general opposition towards the proposed project for reasons including City Zoning inconsistency, the CEQA Traffic Analysis, San Marcos Food Desert, and housing alternatives. The comment does not raise any specific issues concerning the adequacy of the Draft EIR; therefore, no further response is required of provided. Please see Responses to Comments I6-2 through I6-9 herein.
I6-2 The comment expresses concern about the rezoning of the project site and other zoning changes that are occurring within the City in proximity to the project site . Additionally, the comment states that the zoning maps in the DEIR should only in clude the present zoning and the proposed action change .
Please refer to EIR Figure 2-6, Existing Zoning, and Figure 3-7, Proposed Zoning. The existing zoning for the site is presented before the proposed rezoning in the Chapter 2 EIR figures. As outlined in the project’s Specific Plan (Appendix M to the EIR), the proposed Specific Plan Area and the adjacent commercial parcel immediately to the south are currently designated as Commercial by the General Plan and the San Marcos Zoning Code. These three (3) parcels were previously designed and graded for a commercial center. In 2009, the southerly parcel was developed with the CVS pharmacy; however, due to changes in the market, the remaining two (2) parcels that make up the proposed Specific Plan Area are still undeveloped. Although not related to any environmental impact, for informational purposes, the following discusses market conditions affecting the Project. The proposed site has been on the market for commercial development for many years wi th no proposals. The proposed project provides for land use diversity and balanced development by taking an already graded site with no significantly environmental sensitives and proposes to utilize the property to its highest and best use.
Current market demands and the demand for new housing make the property most ideally suited for housing. Density of homes is increased to maximize the efficient use of the property while at the same time providing a transition between high density rental apartments in the south and lower density single family homes to the north. The proposed townhomes offer a “missing middle” housing type that is not widely available in this part of the City.
Regarding the commenter’s statement about the property rezone across the street , it was changed from Commercial (C) to Senior Residential (SR) under the City’s 2012 General Plan Update. The Senior Residential Zone is a subcategory of the Commercial Zone.
I6-3 This comment states that the DEIR fails to state that the project is inconsistent with other adjacent low- density parcels after the proposed rezoning and the reduced density alternative is consistent. In response, please refer to Response to Comment I6-2. The comment provides no substantial evidence regarding any significant environmental impacts. Although not related to any environmental impact, for informational purposes, the following discusses market conditions affecting the project. Current market demands and the demand for new housing make the property most ideally suited for housing. Density of homes is increased to maximize the efficient use of the property while at the same time providing a transition between high density rental apartments in the south and lower density single family homes to the north. Reg arding the Reduced Density Alternative analyzed as part of the project’s alternative
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-48
analysis (Chapter 4 of the EIR), it was acknowledged that development of single -family homes would be more consistent with the adjacent single -family homes to the west. Ho wever, the 33 single -family homes under this alternative would not be consistent with the urban setting of the area and other adjacent land uses and would not maximize development of the site near transit, schools, and commercial uses. Furthermore, due to the project site being located in an urban setting and the limited options available to mitigate Vehicle Miles Travelled (VMT) impacts for residential projects, the Reduced Density Alternative would still result in a significant and unavoidable transportation impact due to VMT.
The Reduced Density Alternative was identified as the environmentally superior alternative . However, it would potentially provide a reduced level of impact in some environmental analysis areas including air quality, Green House Gases (GHG), and noise. Such impacts under this alternative would still remain as less than significant, similar to the proposed project.
I6-4 The comment states that the DEIR underestimates the amount of traffic impacts despite the project being determined to have significant and unavoidable impacts because it fails to account for the volume of traffic that cuts through the CVS parking lot. Additionally, the comment states that because the project was determined to have significant and unavoidable traffic im pacts, the reduced development alternative needs additional analysis. CEQA Guidelines section 15064.3 provides that automobile congestion no longer is considered a significant environmental impact, so the following discussion is provided for informational purposes only. As described in Appendix K-1 to the EIR, the LTA was prepared in accordance with the standards and requirements of the City of San Marcos Transportation Impact Analysis Guidelines (TIAG). Per the City’s TIAG, the study area was defined using the following criteria: Signalized and unsignalized intersections along and adjacent to the project site; Site access driveways; and any classified (non -residential) roadway segments that are linked to the intersections that are being studied. The CVS parking lot adjacent to the project site is not an officially classified roadway as it is private property. The designated CVS parking lot would be for the exclusive use of CVS customers. As described in Chapter 2 of the EIR, the adjacent CVS parcel includes 99 existing parking spaces that would remain for the exclusive and ongoing use of CVS, which only requires 53 spaces to meet the City’s Parking Ordinance for commercial uses. The project site currently contains an additional 38 parking spaces that would be shared between the project site and CVS.
Transportation related impacts of the Reduced Density Alternative were analyzed under DEIR Section
4.4.5.1. It was determined that due to the project site being located in an urban setting and the limited options available to mitigate VMT impacts for residential projects, the Reduced Density Alternative would still result in a significant and unavoidable transportation impact due to VMT.
I6-5 This comment states that the project fails to accurately analyze emergency response to the project site because it fails to address the worst-case scenario, particularly when there are peak traffic conditions.
A Fire Response Technical Memorandum was prepared for the proposed project and was included as Appendix J to the EIR. Please refer to Section 3 of Appendix J, which outlines the methodology used to determine the fire response time to the project site. Additionally, as determined in EIR Section 3.13, Public Services, impacts to public services resulting from project implementation was determined to be less than significant with payment of the City’s Development Services Fees outlined in Section
17.44.030 of the SMMC. Payment of the Development Services Fees goes toward City services.
I6-6 The comment states that the DEIR fails to address the cumulative impacts from three constr uction projects in the area and states that these projects are not required to analyze traffic effects during operation or over the long term. The comment further states that t he City should engage in a larger
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-49
traffic analysis outside of the in dividual per mitting analysis because cumulative analysis is not addressed for individual projects. The comment provides no substantial evidence regarding any significant environmental impacts. CEQA Guidelines section 15064.3 provides that automobile congestion no longer is considered a significant environmental impact, so the following discussion is provided for informational purposes only. In response, the LTA (Appendix K -1 to the EIR) analyzes cumulative project traffic and cumulative project trip generation under “N ear-Term Year 2024” conditions. Cumulative projects analyzed in the LTA were identified by the City as projects that are anticipated to contribute traffic within the project study area by the proposed project’s opening year.
As outlined in the LTA (Appendix K-1 to the EIR), cumulative projects are anticipated to generate 6,756 daily trips, including 536 trips during the AM peak hour and 623 trips during the PM peak hour that would be dispersed throughout the San Marcos community and beyond the proposed proj ect’s study area. Based on the analysis conducted, the LTA determined that there is no need for off -site improvements to accommodate project traffic under the Near-Term Year 2024 with Project Conditions scenario. As concluded in EIR Section 3.15.5, all cumulative projects listed in the project’s LTA were required to analyze traffic impacts consistent with City guidelines, including project-specific impacts on site, and within the transportation study area, provide necessary mitigation measures, design features, or improvements recommendations to address any potentially significant impacts. Furthermore, all cumulative projects would be required to comply with applicable City regulations related to transportation and circulation, as the project does. Due to the significant VMT impact resulting from this project within the transportation study area , the EIR determined that cumulative impacts to transportation as a result of project implementation would similarly be significant and unavoidable.
I6-7 This comment expresses dissatisfaction with the approval of numerous housing developments within the City and expresses concerns about the project area being located within a food desert. The comment provides figures showing development within the area as well as t he location of the food desert over the project site. The comment provides no substantial evidence regarding any significant environmental impacts. Therefore, the following is provided merely for informational purposes. In response, the project site is located within an urban part of the City. Sprouts Farmers Market is located approximately 0.7 mile south of the project site, Grocery Outlet is located approximately 0.6 mile southwest of the project site, Smart & Final is located approximately 1 mile southea st of the project site, and WinCo Foods located approximately 1.3 miles southeast of the project site. The USDA Food Access Research Atlas (FARA) map does not identify the project site as a low access area (USDA 2019, https://gisportal.ers.usda.gov/portal/apps/experiencebuilder/experience/?id=a53ebd7396cd4ac3a 3ed09137676fd40). It should be noted that the topic of food deserts is not analyzed under CEQA.
As outlined in the project’s Specific Plan (Appendix M to the EIR), the proposed Specific Plan Area and the adjacent commercial parcel immediately to the south are currently designated as Commercial by the General Plan and the San Marcos Zoning Code. These three (3) parcels were previously designed and graded for a commercial center. In 2009, the southerly parcel was developed with the CVS pharmacy; however, due to changes in the market, the remaining two (2) parcels that make up the proposed Specific Plan Area are still undeveloped. The proposed site has been on the market for commercial development for many years with no proposals. The proposed project provides for land use diversity and balanced development by taking an already graded site with no significantly environmental sensitives and proposes to utilize the property to its highest and best use. Current market demands and the demand for new housing make the property most ideally suited for housing.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-50
This comment does not raise any specific issues related to the adequacy of the EIR. No further response is required.
I6-8 This comment expresses the opinion that there are other properties that would be better suited to meet the needs of the Housing Element and that the City should incentivize the development of grocery store at the project site. The comment further expresses opposition to the project and notes that it does not maintain the quality of life for residents and expresses dissatisfaction with City Planning. The comment provides no substantial evidence regarding any significant environmental impacts. In response, Chapter 4 of the EIR analyzed project alternatives as required by Section 15126.6 of the CEQA Guidelines. As described in EIR Section 4.3.1, an Alternative Location was considered but rejected as a feasible alternative because the project applicant does not control another site with similar characteristics. One of the factors for feasibility o f an alternative is “whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.” Because the City is highly urbanized and is largely built out, obtaining another site of a similar size in a similar location is n ot considered feasible. The Existing Land Use Designation Alternative was analyzed in EIR Section 4.4.4, which would include 69,000 square feet ( S.F.) of grocery store and gas station uses and 23,000 S.F. of office space. As concluded in the EIR, this alte rnative would be consistent with the existing designated land use and zoning for the site and adjacent land uses to the south, but would not reduce or avoid significant environmental impacts and would increase traffic-related impacts in comparison to this project. As outlined in Response to Comment I6 -7, the proposed site has been on the market for commercial development for many years with no proposals. The proposed project provides for land use diversity and balanced development by taking an already grade d site with no significantly environmental sensitives and proposes to utilize the property to its highest and best use. Current market demands and the demand for new housing make the property most ideally suited for housing.
This comment does not raise any specific issues related to the adequacy of the EIR. No further response is required.
I6-9 The comment provides closing remarks and expresses general opposition to wards the project. This comment does not raise any specific issues related to the adequacy of the EIR. No further response is required.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-51
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-52
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-53
Response to Comment Letter I7
Individual
Marie Marcinko
May 17, 2023
I7-1 The commenter provides an introduction and location in proximity to the project. This comment also expresses general opposition to the project, stating that the project should include retail or mixed uses, and prefaces comments to follow. The comment does not raise any specific issues related to the adequacy of the EIR. No further response is required or necessary.
I7-2 The comment states that the City has consistently rezoned areas for the past two years from retail to residential. The number of residential projects being constructed in the City are further impacting existing traffic and congestion . The commenter expresses concern regarding the lack of smaller community-oriented shopping centers to accommodate the number of new residential projects, and to service the existing Santa Fe Hills neighborhood. In response, the comment does not raise any specific issues related to the adequacy of the EIR. N o further response is required or necessary; however, it should be noted the proposed site has been on the market for commercial development for many years with no proposals.
I7-3 The comment expresses dissatisfaction with the lack of walkable, community-oriented shopping centers. The comment further expresses concern about reduction in the City’s carbon footprint without the ability to walk to shopping centers. In response, t he commenter does not provide substantial evidence that the EIR analysis is inadequate. As outlined in the project’s Specific Plan (Appendix M to the EIR), the proposed Specific Plan Area and the adjacent commercial parcel immediately to the south are currently designated as Commercial by the General Plan and the San Marcos Zoning Code. These three (3) parcels were previously designed and graded for a commercial center. In 2009, the southerly parcel was developed with the CVS pharmacy; however, due to changes in the market, the remaining two (2) parcels that make up the proposed Specific Plan Area are still undeveloped. The proposed site has been on the market for commercial development for many years with no proposals. Concurrent with the proposed Specific Plan, a Ge neral Plan Amendment and Zone Change application are being processed to redesignate the two (2) project parcels that comprise the project site to Specific Plan Area (SPA), thereby allowing for the development of the urban townhome community proposed herein .
Although the project site is currently designated as Commercial (C) by the General Plan, the residential development proposed under the Specific Plan implements Assembly Bill (AB) 32, Strategy 3 of the San Marcos Climate Action Plan (CAP), Senate Bill (SB) 743, numerous General Plan goals, and various other state regulations related to reducing GHG emissions. In accordance with AB 32, the Global Warming Solution Act, the State adopted SB 97, which revised the California Environmental Quality Act (CEQA) Guidelines to require an analysis of GHG emissions as part of the CEQA process and established standards for the content and approval process of plans to reduce GHG. An Air Quality and Greenhouse Gas Emissions Technical Report was prepared for the project and is included as Appendix B to the EIR.
As determined in the Air Quality and Greenhouse Gas Emissions Technical Report, project impacts related to Air Quality and GHG emissions would be less than significant. Furthermore, as described in DEIR Section 3.15, the overall pedestrian environment would be enhanced for both walkability and safety in proximity to the project site with project implementation of the LTA recommendations . This comment does not raise any specific issues related to the adequacy of the EIR.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-54
I7-4 The commenter states that when they attended the NOP scoping meeting the developers stated the parcel was the perfect spot for the development due to the proximity of the train station; how ever virtually no one is riding on it. The commenter states that the project should not be approved until the developers can support their theory with data that includes the number of individuals currently using the train and anticipated users from the proposed project. The comment concludes with a request to keep the original plan for retail or at least incorporate both retail and residential. In response, t he commenter does not provide substantial evidence that the EIR analysis is inadequate. The proposed project provides for land use diversity and balanced development by taking an already graded site with no significantly environmental sensitives and proposes to utilize the property to its highest and best use. Current market demands and the demand for new housing make the property most ideally suited for housing. Density of homes is increased to maximize the efficient use of the property while at the same time providing a transition between high density rental apartments in the south and lower density single family homes to the north. The proposed townhomes offer a “missing middle” housing type that is not widely available in this part of the City. Furthermore, the Specific Plan prepared for the project site encourages an efficient and responsible relati onship between land use and transit, by providing urban housing in proximity to transit, trails, and non -residential uses; includes design guidelines that require pedestrian friendly architecture and landscaping that engage the public sidewalk along public roadways and internal pathways; and minim izes parking in accordance with the City’s Climate Action Plan (CAP) to prioritize transit use and active transportation over private vehicle use. This comment does not raise any specific issues related to the adequacy of the EIR.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-55
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-56
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-57
Response to Comment Letter I8
Individual
Dave Gazzano
May 18, 2023
I8-1 The comment states that the EIR incorrectly determines that traffic impacts would not be substantial under horizon year 2050 conditions. The comment further discusses development surrounding the site that contributes to traffic in the area. The comment provides no substantial evidence regarding any significant environmental impacts. CEQA Guidelines section 15064.3 provides that automobile congestion no longer is considered a significant environmental impact, so the following discussion is provided for informational purposes only. In response, the commenter does not provide substantial evidence that the EIR analysis is inadequate. Methodology used for the Near-Term Year 2024 Conditions and Horizon Year 2050 Conditions analyzed in the Local Transportation Analysis (LTA) (Appendix K-1 to the EIR) is discussed in Section s 6 and 7 of the LTA. Please refer to Response to Comments A2-2, A2-3, I1-2, and I1-4.
I8-2 The comment suggest s that the project reduces the number of units or have the project remain a commercial site. Please refer to Chapter 4 of the EIR for discussion regarding the Reduced Density Alternative and Existing Land Use Designation Alternative. The comment does not raise any specific issues related to the adequacy of the EIR and no further response is required.
I8-3 The comment expresses concern about the operational noise that would be generated an d privacy issues resulting from project implementation adjacent to the commenter’s home . In response, as discussed in Section 3.11 of the EIR, all noise -related impacts were determined to be less than significant. The closest proposed units at the north/northwestern project boundary are approximately 90 feet from existing residents to the west.
Design of the project would follow the design guidelines outlined in the Gran Vista Specific Plan (Appendix M). The design guidelines propose transitional architectural styles for the project to allow it to blend in with the surrounding neighborhood. As discussed in Appendix M of the EIR, the project would incorporate the following to provide transition massing between the pr oject and surrounding area:
utilizing building-form elements, vertically and horizontally articulate building design for front and rear elevations and break up unbroken surfaces on front and rear elevations.
Under the Specific Plan Development Standards f or the project site, the maximum building height allowed on-site is 3-stories or 45 feet. In comparison, under the existing commercial zoning for the site, the maximum height for buildings is 5 stories or 60 feet as outlined in Section 20.220.050 of the San Marcos Municipal Code. The comment does not raise any specific issues related to the adequacy of the EIR; therefore, no further response is required of provided.
I8-4 The comment states that the project would provide too much tax revenue and money to not get approved and asks for the rights of the existing residents to be considered. The comment also includes the request for an eight-foot wall along the west side of the project to protect the residents from view, noise, dust, and light pollution. In response, the EIR determined that impacts related to noise, air quality (dust), and aesthetics (light pollution) would be less than significant. The comment does not raise any specific issues related to the adequacy of the EIR and no further response is required.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-58
I8-5 The comment expresses concern regarding dust from project construction and grading and would like the City to ensure project constru ction does not impact surrounding residents . In response, as discussed in Section 3.2 of the EIR, construction of the proposed project would result in the temporary addition of pollutants to the local airshed caused by soil disturbance, fugitive dust emiss ions, and combustion pollutants from on -site construction equipment, as well as from off -site trucks hauling construction materials. However, the proposed project would be subject to SDAPCD Rule 55, Fugitive Dust Control. This rule requires that a project take steps to restrict visible emissions of fugitive dust beyond the property line. Compliance with Rule 55 would limit fugitive dust 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 particulate matter. Compliance with Rule 55 would be required as a standard condition of project approval or for issuance of a grading permit. Furthermore, the project would be required to comply with the San Marcos Municipal Code Chapter 10.24.020.b.9 which addresses construction activity. The comment does not raise any specific issues related to the adequacy of the EIR and no further response is required.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-59
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-60
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-61
Response to Comment Letter I9
Individual
Lorraine Terrell
May 18, 2023
I9-1 The comment provides introductory remarks for comments to follow. The comment does not raise any specific issues related to the adequacy of the EIR and no further response is required.
I9-2 The comment expresses concern about where residents will park and the increased traffic from the project site at the intersection of Las Posas and Mission Road in addition to the freeway entrances on Las Posas and Rancho Santa Fe. As described in Chapter 2 of the EIR, the adjacent CVS parcel includes 99 existing parking spaces that would remain for the exclusive and ongoing use of CVS, which only requires 53 spaces to meet the City’s Parking Ordinance for commercial uses. The project site currently contains an additional 38 parking spaces that would be shared between the project site and CVS. The project would introduce an additional 20 guest spaces to meet the City’s requirement for multifamily dwelling guest parking of 1 space per 3 units (120 units/3 = 40 spaces total). As required, 2 of the 20 additional guest parking spaces would include electric vehicle charging stations. The project also includes 240 garage spaces which would provide 2 garage spaces per unit and therefore would comply with the City’s Parking Ordinance. Guest parking would be evenly distributed throughout the project site, designed to occur along private drives, or divided into small, landscaped parking courts to avoid the creation of l arge parking lots. The 2019 California Green Building Standards Code, Section
4.106.4.2.1, requires the installation of at least one electric vehicle space in common use parking. The project includes two electric vehicle charging stations in the common use parking. Additionally, bicycle racks would be provided throughout the project site. The project would comply with the Gran Vista Specific Plan required vehicle and bicycle parking ratios for development within the project site.
Regarding traffic congestion, please refer to Response to Comment I1-4. The comment does not raise any specific issues related to the adequacy of the EIR.
I9-3 The comment expresses concern about the project impacting San Marcos schools. In response, Section
3.13 of the EIR analyzed the projects' impacts on schools. As discussed in the EIR, the project would be required to contribute development fees to SMUSD pursuant to California Education Code Section 17620 et seq. and Government Code Sections 65995(h) and 65996(b), as well as SMMC Section
17.52.050. With payment of development fees, based upon provisions of state law, impacts to schools were determined to be less than significant. It should also be noted that San Marcos schools are not determined to be impacted, and students generated by project population are expected to be adequately served by existing schools. Please refer to Response to Comment I1-7. The comment does not raise any specific issues related to the adequacy of the EIR and no further response is required.
I9-4 The comment expresses general opposition to the project and states that the planning departmen t should consider current residents and voters when considering such project proposals. Please refer to Response to Comment I7-4. The comment does not raise any specific issues related to the adequacy of the EIR.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-62
INTENTIONALLY LEFT BLANK
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-63
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-64
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-65
Response to Comment Letter I10
Individual
C. Mardian
May 18, 2023
I10-1 This is an introductory comment to comments that follow, expressing general opposition to the project because of increased traffic, aesthetics, and lack of food and good services in the area. The comment does not raise any specific issues related to the adequacy of the EIR; therefore, no further response is required of provided.
I10-2 The comment expresses concern that the alternatives presented were insufficient and only residential alternatives were provided. The comment further expresses the opinion that the parcel should remain a commercial lot. In response, as outlined in Chapter 4 Alternatives of the EIR, other than the No Project Alternative, the EIR needs to examine only those alternatives that could feasibly obtain most of the basic objectives of the proposed project even if the alternative would impede to some degree the attainment of project objectives. Three alternatives including No Project Alternative (Section 4.4.3), Existing Land Use Designation Alternative (Section 4.4.4), and the Reduced Density Alternative (Section
4.4.5), were discussed in Chapter 4 of the EIR. Only one of these three alternatives proposed residential uses. The Existing Land Use Alternative proposed would include development of the site as previously processed with the existing CVS Conditional Use Permit. The Existing Land Use Designation Alternative would include 69,000 square feet (S.F.) of grocery store and gas station uses and 23,000 S.F. of office space. This alternative would include 276 parking spaces. As described in Chapter 4 of the EIR, because development of the Existing Land Use Designation Alternative would include grading and development of the same site, construction -related impacts would be similar t o the proposed project and would require similar mitigation for impacts to biological resources, cultural resources, geology and soils, tribal cultural resources, and transportation. However, the commercial use of the site would be expected to result in gr eater impacts to air quality, energy, GHG emissions, hazards and hazardous materials, transportation, and utilities, in comparison to the impacts resulting from the proposed project’s residential use, and additional mitigation may be required.
As outlined in the project’s Specific Plan (Appendix M to the EIR), the proposed Specific Plan Area and the adjacent commercial parcel immediately to the south are currently designated as Commercial by the General Plan and the San Marcos Zoning Code. These three (3) p arcels were previously designed and graded for a commercial center. In 2009, the southerly parcel was developed with the CVS pharmacy; however, due to changes in the market, the remaining two (2) parcels that make up the proposed Specific Plan Area are sti ll undeveloped. The proposed site has been on the market for commercial development for many years with no proposals. The proposed project provides for land use diversity and balanced development by taking an already graded site with no significantly environmental sensitives and proposes to utilize the property to its highest and best use. Current market demands and the demand for new housing make the property most ideally suited for housing.
Density of homes is increased to maximize the efficient use of th e property while at the same time providing a transition between high density rental apartments in the south and lower density single family homes to the north. The proposed townhomes offer a “missing middle” housing type that is not widely available in this part of the City.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-66
I10-3 The comment expresses concern that the residential project would replace a potential location for a grocery store within an area designated as a food desert. In response, the project site is located within an urban part of the City. Sprouts Farmers Market is located approximately 0.7 mile south of the project site, Grocery Outlet is loca ted approximately 0.6 mile southwest of the project site , Smart & Final is located approximately 1 mile southeast of the project site, and WinCo Foods located approximately 1.3 miles southeast of the project site. The USDA Food Access Research Atlas (FARA) map does not identify the project site as a low access area (USDA 2019, https://gisportal.ers.usda.gov/portal/ apps/experiencebuilder/experience/?id=a53ebd7396cd4ac3a3ed09137676fd40). It shoul d be noted that the topic of food deserts is not analyzed under CEQA. The comment does not raise any specific issues related to the adequacy of the EIR; therefore, no further response is required of provided. Additionally, p lease refer to Response to Comme nt I 10-2, which discusses history of the project site.
I10-4 The comment expresses concern about existing traffic conditions being exacerbated by the project site.
The comment also expresses the opinion that traffic volumes were underestimated because the Traffic Analysis did not account for cars cutting through the CVS parking lot. The comment also states that the grocery store alternative would result in less traffic at peak times. In response, as outlined in Chapter 4 of the EIR, the commercial use of the site under the Existing Land Use Designation Alternative would be expected to result in greater impacts to air quality, energy, GHG emissions, hazards an d hazardous materials, transportation, and utilities, in comparison to the impacts resulting from the proposed project’s residential use, and additional mitigation may be required. Specific to traffic, this alternative is expected to result in a larger volume of large trucks during operation to service the gas station and grocery store.
Furthermore, the estimated daily vehicle trips for this alternative is approximately 10,672 average daily trips, in comparison to the proposed project’s calculated 960 average daily trips. Regarding traffic report methodology, please refer to Response to Comments I1-2, I1-4, I5-2, I6-4, and I7-2.
I10-5 The comment expresses concern about the height of the proposed project and the compatibility of the height compared to the single-story homes and industrial uses across Mission Boulevard. The comment further suggests that the parcel should be utilized for commercial uses that would not have as big of a height difference between the site and surrounding uses.
In response, design of the project would follow the design guidelines outlined in the Gran Vista Specific Plan (Appendix M). The design guidelines propose transitional architectural styles for the project to allow it to blend in with the surrounding neighborhood. As discussed in Appendix M of the EIR, the project would incorporate the following to provide transition massing between the project and surrounding area: utilizing building-form elements, vertically and horizontally articulate building design for front and rear elevations, break up unbroken surfaces on front and rear elevations, and plant trees and shrubs on the eastern edge of the development to soften/screen the project from the adjacent single-family homes. As outlined in Response to Comment I1 0-2, current market demands and the demand for new housing make the property most ideally suited for housing. Density of homes is increased to maximize the efficient use of the property while at the same time providing a transition between high density rental apartments in the south and lower density single family homes to the north.
The proposed townhomes offer a “missing middle” housing type that is not widely available in this part of the City.
An Existing Land Use Designation was analyzed in Chapter 4 o f the EIR. Impacts to aesthe tics would remain less than significant under this alternative, similar to the proposed project. Additionally, under
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-67
the existing commercial zoning, the maximum height for buildings is 5 stories or 60 feet as outlined in Section 20.220.050 of the San Marcos Municipal Code. The comment does not raise any specific issues related to the adequacy of the EIR; therefore, no further response is required of provided.
I10-6 The comment provides a summary of previous comments in the comment letter and expresses general opposition to the project. Please refer to Responses to Comments I10-2 through I10-5.
RESPONSES TO COMMENTS
RESPONSE TO COMMENTS FOR THE GRAN VISTA SPECIFIC PLAN PROJECT 13528 MAY 2023 RTC-68
INTENTIONALLY LEFT BLANK