San Marcos City Council
June 27, 2023

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,
Section 3.2.2.)
Flooring CALGreen Code The project must comply with efficiency standards regarding flooring materials. For example, 80% of
floor area receiving “resilient 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 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 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

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-29
Table 3.7-8. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable Laws/
Regulations GHG Reduction Measures Required for Project 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, Section 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 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 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 to
ensure pollutant control. (CALGreen 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 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 × (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

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-30
Table 3.7-8. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable Laws/
Regulations GHG Reduction Measures Required for Project 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 project must
meet various efficiency requirements. For example:

Refrigerator/Freezer: Use associated with the
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
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 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 project will be subject to energy efficiency requirements contained in
Title 20 Standards.

General Lighting: Indoor and outdoor lighting
associated with the project must comply with
applicable appliance efficiency regulations (Title 20
Standards, Sections 1605.1[j], [k], [n], 1605.3[j],
[k], [n].)

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-31
Table 3.7-8. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable Laws/
Regulations GHG Reduction Measures Required for Project 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 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 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, 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 incandescent
and luminaire lighting, and lighting control
functionality. (Id. at Section 6.)
AB 1109 Lighting associated with implementing the 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 project will be required to provide compliant bicycle parking, fuel-efficient
vehicle parking, and electric vehicle charging spaces
(CALGreen Sections 5.106.4, 5.106.5.1, 5.106.5.3)
California Energy Code The 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)

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-32
Table 3.7-8. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable Laws/
Regulations GHG Reduction Measures Required for Project 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. (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 Refrigerants
for Stationary Sources
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 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. (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 (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

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-33
Table 3.7-8. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable Laws/
Regulations GHG Reduction Measures Required for Project 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 project will be subject to CALGreen Code requirements for construction waste reduction,
disposal, 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
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

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-34
Table 3.7-8. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable Laws/
Regulations GHG Reduction Measures Required for Project 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 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 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 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. 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.

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-35
Table 3.7-8. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable Laws/
Regulations GHG Reduction Measures Required for Project Renewable Energy California RPS (SB X1-2,
SB 350, and SB 100)
Energy providers to the 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 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 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

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-36
Table 3.7-8. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable Laws/
Regulations GHG Reduction Measures Required for Project Gas & Electric, Southern California Edison, 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 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 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 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 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.

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-37
Table 3.7-8. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable Laws/
Regulations GHG Reduction Measures Required for Project Cap-and-Trade Program Gasoline used for 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 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.

Advanced Clean Car
and ZEV Programs
Cars that drive to and from the 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

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-38
Table 3.7-8. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable Laws/
Regulations GHG Reduction Measures Required for Project 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 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 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 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 water suppliers, homeowners’ associations,
California businesses, landlords and tenants, and
wholesale water agencies to take stronger
conservation measures.

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-39
Table 3.7-8. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable Laws/
Regulations GHG Reduction Measures Required for Project EO B-37-16 Water use associated with the 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
project will be subject.

SB X7-7 Water provided to the 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 project is subject to CALGreen Code’s water efficiency standards, including a required 20%
mandatory reduction in indoor water use.
(CALGreen, Division 4.3.)

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-40
Table 3.7-8. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable Laws/
Regulations GHG Reduction Measures Required for Project California Water Code,
Division 6, Part 2.10,
Sections 10910–
10915.

Development and approval of the project 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.

Source: Appendix B.

Notes: AB = Assembly Bill; CARB = California Air Resources Board; CEC = California Energy Commission; CFC = chlorofluorocarbon; CH4 = methane; CO2 = carbon dioxide; CO2e = 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 Sa fety Administration; PM = particulate matter; RPS = Renewable Portfolio Standard; RTP/SCS = Regional Transportation Plan/Sustainab le Communities Strategy; SB = Senate Bill; SANDAG = San Diego Association of Governments; VOC = volatile organic compound; ZEV = zero emission vehicle
As shown in the table above, the project would be consistent with and would not conflict with the applicable GHG - reducing strategies of the state that apply to the construction and operational components.

In addition, the project would help support achievement of the statewide 2030 goal (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 multimodal transportation optio ns and incorporating features such as electric vehicle charging stations, bicycle infrastructure, transportation demand management, electric water heaters, smart landscaping irrigation, and an urban tree canopy.

Consistency with San Diego Association of Governments ’ Regional Transportation Plan / Sustainable Communities Strategy
At the regional level, SANDAG’s RTP/SCS has been adopted for the purpose of reducing 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 that the San Diego region reduced per capita CO 2 emissions by 17.9% in 2020 compared to 2005 baseline, which exceeds the 2020 target set for SANDAG of 15% reduction.

Implementation of the 2021 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 auth ority 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.

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-41
For purposes of the RTP/SCS consistency evalu ation, the project would increase access to transit because it is located approximately 0.3 miles from the Palomar College SPRINTER station and two bus stops are located in front of the project site off W Mission Road.5 The project site’s proximity to State Route 78 further allows for easy regional connectivity to employment centers, shopping areas, and recreation opportunities. 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 t he project’s regional GHG emissions.

Based on the considerations outlined above, the 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.

3.7.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental effects. Pursuant to CEQA Guidelines Section 15130(b)(1)(A)(B), an adequate discussion of a project’s significant cumulative impact, in combination with other closely related projects, can be based on either a list of past, present, and probable future producing related impacts or a summary of projections contained in an adopted local, regional, or statewide plan or related planning document that describes conditions contributing to the cumulative effect.

Due to the global nature of the assessment of GHG emissions and the effects of global climate change, GHG emissions analysis, by its nature, is a cumulative impact analysis. Therefore, the information and analysis provided above in Section 3.7.4 to determine project -level impacts applies here and the project’s contribution to global climate change would not be cumulatively considerable.

This approach is consistent with the supporting documentation published by the California Natural Resources Agency when promulgating the SB 97-related CEQA amendments, which indicated that the impact of GHG emissions should be considered in the context of a cumulative impact, rather than a project -level impact (CNRA 2009b). The California Natural Resources Agency similarly advised that an environmental document must analyze the incremental contribution of a project t o GHG levels and determine whether those emissions are cumulatively considerable (CNRA 2009a). The adopted CEQA Guideline (14 CCR 15064.4) confirms that the analysis of climate change impacts is cumulative and, in the most recent update to the Guidelines, text was added to Section 15064.4 to clarify as much (CNRA 2018). Section 15064.4 now states , “In determining the significance of a project’s greenhouse gas emissions, the lead agency should focus its analysis on the reasonably foreseeable incremental contribution of the project’s emissions to the effects of climate change.” For the reasons stated above, the project’s cumulative impacts would be less than significant.

5 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 Escon dido and Oceanside with connections to Interstate 5 and the Coaster rail service operating out of the City of Oceanside. The NCTD operates the Paloma r 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 City 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.

3.7 – GREENHOUSE GAS EMISSIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.7-42

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

3.7.6 Conclusion
As presented in Section 3.7.4, the project would result in approximately 749 MT CO 2e per year and would not exceed the City’s significance threshold of 2.1 MT CO2e/SP/yr. Therefore, the project would be consistent with the City’s 2020 CAP. Furthermore, the project would be consistent with and would not conflict with the applicable GHG- reducing str ategies of the stat e, would be consistent with CARB’s Scoping Plan, and would be consistent with SANDAG’s RTP/SCS. In summary, impacts with regard to GHG emissions would be less than significant.

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-1

3.8 Hazards and Hazardous Materials
This section describes the existing hazards and hazardous materials within the vicinity of the proposed Gran Vista Specific Plan Project ( project), identifies associated regulatory requirements, and evaluates potential impacts related to implementation of the project. Information from the Phase I Environmental Site Assessment (Phase I ESA), prepared for the project by Hillmann Consulting on June 23, 2021, was used in preparation of this chapter and is included as Appendix F to this EIR.

Table 3.8-1 summarizes the hazards and hazardous materials and cumulative-level impact analysis, by threshold, for the project.

Table 3.8-1. Hazards and Hazardous Materials Summary of Impacts Threshold of Significance
Project -Level
Impact
Cumulative -
Level Impact
Significance
Determination
No. 1: Create a significant hazard to the public or the environment through the routine transport, use, or
disposal of hazardous materials.

Less than
Significant
Less than
Significant
Less than
Significant
No. 2: Create a significant hazard to the public or the environment through reasonably foreseeable upset and
accident conditions involving the release of hazardous
materials into the environment.

Less than
Significant
Less than
Significant
Less than
Significant
No. 3: Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.

Less than
Significant
Less than
Significant
Less than
Significant
No. 4: Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment.

Less than
Significant
Less than
Significant
Less than
Significant
No. 5: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area.

Less than
Significant
Less than
Significant
Less than
Significant
No. 6: Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan.

Less than
Significant
Less than
Significant
Less than
Significant
No. 7: Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or death involving wildland fires.

Less than
Significant
Less than
Significant
Less than
Significant

3.8.1 Existing Conditions
This section describes the existing conditions on the project site related to hazards and hazardous materials. The Phase I ESA assesses the likelihood of any recognized hazardous substances or petroleum products that might be present on site as a result of current or historical land uses or adjacent uses. The Phase I ESA included a review of the historical records of the project site, a s ite reconnaissance of the project site, reconnaissance of adjoining properties, a vapor encroachment screen for the project site, and a limited soil inves tigation. The Phase I ESA did not identify any evidence of recognized environmental conditions on the project site.

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-2
The 7.6-acre project site is an undeveloped lot located in the northwestern portion of the City of San Marcos (City) in an urbanized area . The project site is located in an area largely characterized by commercial and industrial facilities, and residences, with Palomar College approximately 0.2 miles to the east. The project site is bounded by N Las Posas Road along the eastern boundary, W Mission Road along the southwest boundary, an existing CVS Pharmacy to the south, and existing single -family residential development to the north and west, as well as to the east across N Las Posas Road.

Visual evidence of hazardous substances and wastes was not observed during the project site reconnaissance, and no visual indication of spills or leaks was observed. No other pungent or acrid odors were observed emanating from the project site. Additionally, there was no evidence of underground or aboveground fuel storage tanks or equipment that may contain polychlorinated biphenyls.

Site and Surrounding Area History
The Phase I ESA completed for the project reviewed reasonably ascertainable public documents, including aerial photographs, topographic maps, city directories, and fire insurance maps.

Aerial photographs were reviewed for the following years: 1928, 1939, 1946, 1953, 1964, 1967, 1970, 1979, 1985, 1989, 1990, 1994, 2005, 2009, 2012, and 2016 (Appendix F). In each photograph, the project site appears to be vacant and undeveloped land.

Included in Appendix F is an Environmental Data Resource s Inc. Historical Topo Map Report , which reviewed the Escondido Quadrangle (15-minute series), dated 1893; the Escondido Quadrangle (15-minute series), dated 1901; the Escondido Quadrangle (15 -minute series), dated 1947; the San Marcos (7.5 -minute series), dated 1948; the San Marcos (7.5 -minute series), dated 1949; the San Marcos Quadrangle (7.5 -minute series), dated 1968; the San Marcos Quadrangle (7.5-minute series), dated 1983; the San Marcos Quadrangle (7.5-minute series), dated 1996; and the San Marcos Quadrangle (7.5-minute series), dated 2012 (Appendix F). The project s ite appears to be vacant land on all the topographic map sheets reviewed for this assessment. The 2012 topographic map sheet shows little detail other than streets in the vicinity (Appendix F ).

Based on readily available historical information, the project site appears to have been vacant and undeveloped land from 1928 to 2005, used as a staging area for the construction of the CVS Pharmacy to the south, and has remained vacant since 2012. According to Google Earth images, the project site was used as an overflow parking lot for Palomar College in 2017 and 2018. Historically, the surrounding properties appear to have been vacant land from at least 1928 to at least 1953. Numerous structures and some vacant land can be observed from 1964 to 2005. Data gaps exist from 1901 to 1927, 1929 to 1939, 1940 to 1945, 1950 to 1952, 1954 to 1963, 1965 to 1966, 1971 to 1978, 1980 to 1982, 1984, 1986 to 1987, 1991 to 1995, and 1997 to 2004, due to the limited records that are reasonably ascertainable in the local area. However, according to Appendix F, additional historical information, if it were to become available, is likely insignificant and not likely to change the impact determination herein.

The surrounding properties appear to have a structure in 1893 and 1901 aerial photographs; railroad track, an unpaved road, and a structure in 1947 through 1949; multiple structures in 1968 and 1983; and in 1996 the remaining adjacent properties become developed. The 2012 maps show little detail other than streets in the vicinity (Appendix F).

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-3
Regulatory Database Review
As explained in Appendix F, Hillmann Consulting obtained and reviewed an environmental database report of the federal and state environmental records specified by international standard practice guidance (ASTM E 1527-13).

The database report was provided by Environmental Data Resources Inc. of Shelton, Connecticut , and tracks the presence of underground storage tanks (USTs), hazardous waste generation, and hazardous waste generators, or other environmental concerns, such as spills, leaks, or aboveground tanks. Table 3.8-2, Environmental Database, shows that the project site was not listed on any of these regulatory databases and four site listings were present on adjacent sites.

Table 3.8-2. Environmental Database
Environmental Database
Minimum Search
Distance (miles) Site Adjacent
Total
Listed
Federal National Priorities List (NPL) and
Proposed NPL

1.0 No 0 0
Delisted NPL 0.5 No 0 0
Federal Superfund Enterprise Management System
(SEMS), including archived sites (formerly CERCLIS)

0.5 No 0 0
Federal SEMS-ARCHIVE (formally known as

CERCLIS NFRAP)

0.5 No 0 3
Federal Resource Conservation and Recovery Act
(RCRA), Corrective Action Sites (CORRACTS)

1.0 No 0 1
Federal RCRA, Treatment, Storage, and
Disposal facilities (TSD) sites

0.5 No 0 1
Federal RCRA Generators (LQG, SGQ, and CESQG) Site and Adjacent No 1 1 Federal Institutional Control/Engineering Control
(IC/EC) registries
Site No 0 0
Federal Emergency Response Notification
System (ERNS)
Site No 0 0
State/Tribal Hazardous Waste Sites (SHWS) 1.0 No 0 1
State/Tribal Landfill and/or Solid Waste
Disposal (LF/SWF)

0.5 No 0 1
State/Tribal Leaking Storage Tanks 0.5 No 0 20
State/Tribal Registered Storage Tanks Site and Adjoining No 0 0 State/Tribal IC/EC Registries Site No 0 0
State/Tribal Voluntary Cleanup Sites 0.5 No 0 0
State/Tribal Brownfields 0.5 No 0 0
Additional Federal, State, Tribal and Local
Environmental Databases
Variable No 2 0
Source: Appendix F.

National Priorities List
The National Priorities List (NPL) is the U.S. Environmental Protection Agency's (EPA) list of confirmed or proposed Superfund sites. The Phase I ESA review ed the NPL list for confirmed or proposed Superfund sites, and for sites that have been delisted from the NPL, which occur within 1 mile of the project site. The project site does not appear on the NPL. There are no other facilities on the NPL within 1 mile of the project site.

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-4
Superfund Enterprise Management System
The Superfund Enterprise Management System (SEMS, formerly CERCLIS) is a compilation of sites that EPA has investigated or is currently investigating for a release or threatened release of hazardous substances. The Phase I ESA reviews current and archived SEMS sites within 0.5-mile distance of the project site.

The project site does not appear on the SEMS or SEMS-ARCHIVE list. There are three facilities on the SEMS-ARCHIVE list within 0.5 miles of the project site located at 217 N Las Posas Road (735 feet south of the project site) with no gradient due to a hydrologic barrier (Appendix F).

Due to the listings, distance, locations downgradient from the project site, and/or facility status as an archive facility (SEMS-ARCHIVE), these facilities are considered unlikely to represent an environmental concern to the project site.

Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act ( RCRA) compiles selective information on facilities that generate, transport, store, treat, and/or dispose of hazardous waste. RCRA facilities can be listed on one of the three databases:
▪ Corrective Action Facilities are facilities undergoing corrective action. A corrective action order is issued pursuant to RCRA Section 3008(h) when there has been a release of hazardous waste or constituents into the environment from a RCRA facility.
▪ Treatment, Storage, and Disposal Facilities (TSD) includes facilities that transport, store, or dispose of hazardous waste and are not listed on the RCRA Generators list. The TSD is searched for a 0.5-mile distance. ▪ Generators List identifies and tracks hazardous waste from the point of generation to the point of disposal.

The RCRA Generators database is a compilation by EPA of reporting facilities that generate hazardous waste. The RCRA generators list is searched for the project site and adjacent properties.

The project site does not appear on the Corrective Action Facilities list. There is one facility on the list within 1 mile of the project site. The facility is Signet Armorlite, located at 1001 Armorlite Drive. The site has been listed on the federal CORRACTS list but has not had any violations listed. Therefore, this facility is considered unlikely to represent an environmental concern to the project site.

The project site does not appear on the RCRA TSD list. There is one facility on the list within 0.5 miles of the project site: Signet Armorlite, located at 1001 Armorlite Drive. The site has been listed on the RCRA-NonGEN/NLR lists but has not had any violations listed. Therefore, this facility is considered unlikely to represent an environmental concern to the project site.

The project site does not appear on the RCRA Generators list. There is one facility listed as a RCRA Generator within

0.25 miles of the project site. The facility is CVS Pharmacy, located at 1302 W Mission Road, which is adjacent and south-southeast of the project site and lower in elevation relative to the project site. The CERZ HAZ WASTE database listed administrative violations, but the facility has since achieved compliance. No other environmental databases identified violations from this facility and this facility is considered unlikely to represent an environmental concern to the project site.

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-5
Federal Institutional Control/ Engin eering Control Registries EPA maintains institutional and engineering control databases or registries, which list sites with engineering or institutional controls in place. Institutional controls include administrative measures intended to prevent exposure to contaminants remaining on site. Engineering controls include various forms of caps, treatment methods, etc. The project site does not appear on the federal institutional control/engineering control registries.

Emergency Response Notification System
The Emergency Response Notification System is a national database used to collect information on reported releases of oil or hazardous substances. The project site does not appear on this list.

Solid Waste Fill/Landfill Database
The Solid Waste Fill/Landfi ll (SWF/LF) database include s information pertaining to closed and open solid waste facilities operating in the state of California. The SWF/LF database is searched for a 0.5-mile distance. The project site does not appear on the SWF/LF lists. There is one facility within 0.5 miles of the project site. The one facility is Benchmark Landscape Inc. located at 145 N Pacific Street is listed as being located 0.15 mile s southwest of the project site at an elevation below the project site. Despite the facility having multiple administrative violations, the facility returned to compliance in 2014 and does not represent an environmental concern to the site.

Leaking Underground Storage Tanks List
The California Leaking Underground Storage Tanks (LUST) list is a compilation of petroleum storage tank sites that have reported a release. The LUST list is searched for a 0.5-mile distance. The project site does not appear on the LUST list. There are 20 facilities on the LUST list within 0.5 miles of the project site. Appendix F provides a detailed table with the facility name, address, location in relation to the project site , and the facility status. Due to their status listings and location, these facilities do not represent an environmental concern to the project site.

Underground Storage Tanks List
The California UST list is a compilation of petroleum storage tank sites that are registered with the state of California.

The UST list is searched for the project site and adjacent properties. The project site did not appear on the UST list or historic UST list.

Dry Cleaners
Environmental Data Resources Inc. compiled and provided the dry cleaners list. The dry cleaner database is searched for a 0.25-mile distance. The project site does not appear on the dry cleaners list. There are no dry cleaner facilities listed within 0.25 miles of the project site.

Unmappable Facilities
Hillmann Consulting reviewed the list of “orphan” or unmappable facilities in the database report. There are no unmapped facilities in the report.

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-6
Vapor Encroachment Screening
The purpose of a vapor encroachment screen is to identify, to the extent feasible, if a vapor encroachment condition exists at the project site. According to Appendix F, a vapor encroachment condition is not likely to exist at the project site given that no recognized environmental conditions were identified.

Site Reconnaissance
A representative of Hillmann Consulting conducted a project site reconnaissance on June 8, 2021. The triangular- shaped project s ite currently comprise s two parcels of land ( Assessor’s Parcel Number s 219-121-15-00 and 219 121-16-00) and encompasses a total of approximately 7.6 acres. The project site can generally be accessed from either N Las Posas Road or W Mission Road. The project site is currently vacant and undeveloped land. No visual evidence of hazardous substances and wastes was observed during the project site reconnaissance. No visual indication of spills or leaks was observed. No other pungent or acrid odors were observed emanating from the project site.

Wildland Fire
The project site is no t designated as a high fire severity zone ( CAL FIRE 2022 ; City of San Marcos 2012). The San Marcos Fire Department (SMFD) prepared a Community Wildfire Protection Plan and Hazard Risk Assessment for the San Marcos community and unincorporated areas in the San Marcos Fire Protection District to reduce the risk of wildland fires (SMFD 2007). Fire protection services and wildfire risk for the project site are discussed in Section 3.13, Public Services, and Chapter 5, Environmental Effects Found Not to Be Significant.

3.8.2 Regulatory Setting
This section details the federal, state, and local regulations governing hazards and hazardous materials.

Federal
Chemical Accident Prevention Provision
Title 40 Part 68 of the Code of Federal Regulations set s forth a list of regulated substances and thresholds, the petition process for adding or deleting substances to the list of regulated substances, the requirements for owners or operators of stationary sources concerning the prevention of accident releases, and the state accidental release prevention programs approved under Section 112(r) of the Clean Air Act.

Federal Aviation Regulations —Notice of Proposed Construction or Alteration The Federal Aviation Administration (FAA), which has primary responsibility for the safety of civil aviation, imposes height restrictions in order to prevent obstru ctions to navigable airspace to protect flights and surrounding structures. In certain cases, the FAA should be notified of proposed development pursuant to Section 77.11 of the Federal Aviation Regulations. The notification of proposed development enables the FAA to:
▪ Evaluate the effect of the construction or alteration on operational procedures and proposed operational procedures
▪ Determine the possible hazardous effect of the proposed construction or alteration of air navigation

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-7
▪ Provide r ecommendations fo r identifying the construction or alteration in accordance with current FAA Advisory Circular AC 70/7460-1K, Obstruction Marking and Lighting, dated August 1, 2000 ▪ Determine other appropriate measures to be applied for continued safety of air navigation ▪ Provide charting and other notification to airmen of the construction or alteration Certain jurisdictions can request an FAA evaluation of proposed development when certain features appear to be potentially hazardous.

Federal Disaster Mitigation Act of 2000
The Disaster Mitigation Act of 2000 provided a new set of mitigation plan requirements for state and local jurisdictions to coordinate disaster mitigation planning and implementation. States are encouraged to complete a “standard” or an “ enhanced” natural mitigation plan. “Enhanced” plans demonstrate increased coordination of mitigation activities at the state level, and, if completed and approved, increase the amount of funding through the Hazard Mitigation Grant Program. California’s updated State Hazard Mitigation Plan was adopted in October 2010 and approved by the Federal Emergency Management Agency Region IX. The City is one of the communities covered by the County of San Diego (County) Multi-Jurisdictional Hazard Mitigation Plan, described below, whic h is a Countywide plan that identifies risks posed by natural and human-made disasters.

Hazardous Materials Transport
The U.S. Department of Transportation regulates transportation of hazardous materials between states. State agencies with primary responsibility for enforcing federal and state regulations and responding to hazardous materials transportation emergencies ar e the California Highway Patrol and the California Department of Transportation. Together, these agencies determine container types used and license hazardous waste haulers for transportation of hazardous waste on public roads, including explosives that may be used for blasting.

International Fire Code
The International Fire Code (IFC), created by the International Code Council, is the primary means for authorizing and enforcing procedures and mechanisms to ensure the safe handling and storage of any substance that may pose a threat to public health and safety. The IFC regulates the use, handling, and storage requirements for hazardous materials at fixed facilities. The IFC and the International Building Code use a hazard classification sys tem to determine what protective measures are required for fire and life safety. These measures may include construction standards, separations from property lines, and specialized equipment. To ensure that these safety measures are met, the IFC employs a permit system based on hazard classification. The IFC is updated every 3 years.

Resource Conservation and Recovery Act
RCRA gives EPA the authority to control hazardous waste during the generation, transportation, treatment, storage, and disposal of the waste. RCRA also sets forth a framework for the management of non -hazardous solid wastes.

The 1986 amendments to RCRA enabled EPA to address environmental problems that could result from underground tanks storing petroleum and other hazardous substances.

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-8
Haz ardous and Solid Waste Amendments of 1984
The Hazardous and Solid Waste Amendments of 1984 amends the Solid Waste Disposal Act (as amended by the RCRA of 1976) to authorize appropriations for fiscal years 1985 through 1988 for:

General administration by t he Administrator of EPA to carry out such act (including funds for resource recovery and conservation panels, hazardous waste management, and support for state, regional, local, and interstate agency solid waste plans
Grants to state hazardous waste programs
The hazardous waste site inventory
Development and implementation of plans by state, local, regional, and interstate authorities Implementation of state, local, and intermunicipal programs for solid waste management, resource recovery, resource conservation, and hazardous waste management Special communities assistance
Assistance to states for recycled oil programs
The Secretary of Commerce to carry out resource and recovery duties Additional EPA officers or employees to conduct criminal investigati ons under such act and for support costs for such additional criminal investigators
UST regulation
Grants to states for state UST release detection, prevention, and correction programs Small quantity generator waste education programs
State and other programs requiring compliance with open dumping/sanitary landfill criteria by solid waste management facilities within 36 months after enactment of this act The National Ground Water Commission
In general, both the scope and requirements of the amendments, as amended by RCRA, were significantly expanded and reinforced.

State
The state regulations that govern hazardous materials are equal to or more stringent than federal regulations.

California has been granted primary oversight responsibility by EPA to administer and enforce hazardous waste management programs. State regulations have detailed planning and management requirements to ensure that hazardous wastes are handled, stored, and disposed of properly to reduce risks to human health and the environment. Several key state laws pertaining to hazardous wastes are discussed below. In addition, the Department of Toxic Substance s Control, the State Water Resources Control Board, and the Integrated W aste Management Act also regulate the generation of hazardous materials, as described below.

California Emergency Services Act
The California Emergency Services Act provides the basic authority for conducting emergency operations following a proclamation of emergency by the governor and/or appropriate local authorities. Local government and district emergency plans are considered to be extensions of the California Emergency Plan, established in accordance with the Emergency Services Act.

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-9
Calif ornia Fire Code
The California Fire Code (CFC) is Chapter 9 of Title 24 of the California Code of Regulations. The California Code of Regulations is the primary means for authorizing and enforcing procedures and mechanisms to ensure the safe handling and storage of any substance that may pose a threat to public health and safety. The CFC regulates the use, handling, and storage requirements for hazardous materials at fixed facilities. The CFC and the C alifornia Building Code use a hazard classification system to determine what protective measures are required to ensure fire and life safety. These measures may include construction standards, separations from property lines, and specialized equipment. To ensure these safety measures are met, the CFC employs a permit system based on hazard classification. The CFC is updated every 3 years. SMFD has adopted the CFC by reference in its own fire code.

California Health and Safety Code —Hazardous Materials Release Response Plans and Inventory Pursuant to California H ealth and Safety Code, Chapter 6.95, the California Department of Environmental Health implements the Hazardous Materials Business Plan (HMBP) program and the California Accidental Release Prevention Program (CalARP) in the County. The HMBP and CalARP programs provide threshold quantities for regulated hazardous substances. When the indicated quantities are exceeded, an HMBP or risk management plan is required pursuant to the regulation. Congress requires EPA Region 9 to make risk management plan information available to the public through EPA’s Envirofacts Data Warehouse.

California Integrat ed Waste Management Act
This act requires the development and implementation of household hazardous waste disposal plans. The California Department of Resources Recycling and Recovery, formerly the California Integrated Waste Management Board, oversees compliance with this act and enforces operational plans for solid waste facilities.

Emergency Response to Hazardous Materials Incidents
California has developed an emergency response plan to coordinate emergency services provided by federal, state, and local governments and private agencies. Response to hazardous material incidents is one part of this plan. The plan is managed by the California Emergency Management Agency, which coordinates the responses of other agencies, including the California Environmenta l Protection Agency ( CalEPA), California Highway Patrol, California Department of Fish and Wildlife, and Regional Water Quality Control Board.

Emergency Services Act
Under the Emergency Services Act (California Government Code Section 8850 et seq.), the st ate developed an emergency response plan to coordinate emergency services provided by federal, state, and local agencies. Quick response to incidents involving hazardous materials or hazardous waste is a key element of this plan. The Governor’s Office of E mergency Services administers the plan, coordinating the responses of other agencies, including EPA, California Highway Patrol, Regional Water Quality Control Board s, air quality management districts, and county disaster response offices.

Government Code S ection 65962.5 (Cortese List)
The provisions of Government Code Section 65962.5 are commonly referred to as the Cortese List. The Cortese List is a planning document used by the state and local agencies to provide information about hazardous materials release sites. Government Code Section 65962.5 requires CalEPA to develop an updated Cortese List annually, at

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-10
minimum. The Department of Toxic Substances Control is responsible for a portion of the information contained in the Cortese List. Other California state and local government agencies are required to provide additional hazardous material release information for the Cortese List.

Hazardous Waste Control Act
The Hazardous Waste Control Act is implemented by regulations contained in California Code of Regulations Title 26 that describe requirements for the proper management of hazardous wastes. The act created the state hazardous waste management program, which is similar to but more stringent than the federal RCRA program. The Hazardous Waste Control Act and Title 26 regulations list more than 800 potentially hazardous materials and establish criteria for identifying, packaging, transporting, and disposing of such wastes. Under these regulations, the generator of hazardous waste material must complete a ma nifest that accompanies the material from the point of generation to transportation to the ultimate disposal location, with copies of the manifest filed with the Department of Toxic Substances Control.

Unified Program
CalEPA delegates to qualifying local a gencies oversight and permitting responsibility for certain state programs pertaining to hazardous waste and hazardous materials. This is achieved through the Unified Program, created by state legislation in 1993 to consolidate, coordinate, and make consistent the administrative requirements, permits, inspections, and enforcement activities for the following emergency and management programs:
▪ Hazardous materials release response plans and inventories (business plans) ▪ CalARP
▪ UST Program
▪ Aboveground Petroleum Storage Act Requirements for Spill Prevention, Control and Countermeasure plans ▪ Hazardous Waste Generator and On-site Hazardous Waste Treatment (tiered permitting) Programs ▪ CFC: Hazardous material management plans and hazardous material inventory statements The County is the designated certified Unified Program agency for all local jurisdictions within the San Diego region, including San Marcos.

State Responsibility Area Fire Safe Regulations ( California Code of Regulations, Title 14 Natural Resources, Department of Forestry Fire Protection) These regulations constitute the basic wildland fire protection standards of the California Board of Forestry. They have been prepared and adopted for the p urpose of establishing minimum wildfire protection standards in conjunction with building, construction, and development in State Responsibility Areas. Title 14 regulates that the future design and construction of structures, subdivisions, and developments in State Responsibility Areas shall provide for basic emergency access and perimeter wildfire protection measures.

Local
Airport Land Use Commission and Airport Land Use Compatibility Plans Airport Land Use Commissions assist local agencies in ensuring compatible land uses in the vicinity of existing or proposed airport s; coordinate planning at state, regional , and local levels; pr epare and adopt airport land use

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-11
policies; review plans or regulations submitted by local agencies; and review and make recommendations regarding the land use, building heights, and other issues related to air navigation safety. The San Diego County Region al Airport Authority is the Airport Land Use Commission for the San Diego region.

The closest airport to the project site is the McClellan -Palomar Airport, which operates under its own Airport Land Use Compatibility Plan. The project site is not located within any of the McClellan-Palomar Airport Influence Areas (San Diego County Regional Airport Authority 2011).

County of San Diego Multi -Jurisdictional Hazard Mitigation Plan To comply with the Disaster Mitigation Act of 2000, the County prepared the Multi -Jurisdictional Hazard Mitigation Plan. The plan serves as both a Countywide plan and a plan for local jurisdictions that identifies risks posed by natural and human-made disasters before a hazard event occurs. The plan includes overall goals and objective s shared by many jurisdictions, as well as specific goals, objectives, and mitigation action items for each of the participating jurisdictions to help minimize the effects of the specified hazards that could potentially affect their jurisdiction. Goals, objectives, and action items for the City are included in this plan (County of San Diego 2017).

San Marcos Fire Department Hazard Risk Analysis and Wildland Urban Interface Community Wildfire Protection Plan
The Community Wildfire Protection Plan, adopted in December 2007 (San Marcos Fire Department 2007 ), was developed by the SMFD with guidance from the County, California Department of Forestry and Fire Protection, and the U.S. Forest Service. The Community Wildfire Protection Plan supplements County Department of Planning and Land Use documents. The SMFD also published the Hazard Risk Analysis for internal City use, incorporating new and existing information relating to wildfire risk within the City to better quantify true risk and management needs.

The Hazard Risk Analysis quantifies, clarifies, and manages the wildland urban interface responsibility and meets the requirements of the federal Healthy Forests Restoration Act of 2003 for community fire planning.

City of San Marcos, Ordinance 2003 -1216
The City Ordinance 2003-1216 amends Chapter 17.64 of the San Marcos Municipal Code to adopt the most recent version of the CFC. This ordinance also requires all buildings or structures to provide and maintain an effective fuel modification zone of 150 feet.

City of San Marcos General Plan
Safety Element
The Safety Element of the San Marcos General Plan (City of San Marcos 2012 ) contains the following goals and policies pertaining to hazards and hazardous materials that apply to the project:

Goals S-3: Minimize injury, loss of life, and damage to property resulting from structure or wildland fire hazards.

Policy S -3.1: Require development to be located, designed and constructed to provide adequate defensibility and reduce the risk of structural loss and lif e resulting from wildland fires.

Development will consider hazards relative to terrain, topography, accessibility and proximity to vegetation. One such provision for development to minimize the risk of structural loss and life shall be the inclusion of overhead fire sprinklers.

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-12
Policy S-3.2: Provide sufficient level of fire protection service to reduce risk from urban and wildland fire.

Advocate and support regional coordination among fire protection and emergency service providers.

Policy S-3.3: Require development to provide additional access roads when necessary to provide for safe access of emergency equipment and civilian evacuation concurrently.

Policy S-3.4: Coordinate with fire protection and emergency service providers to assess fire hazards before and after wildfire events to adjust fire prevention and suppression needs, as necessary, commensurate with both short- and long-term fire prevention needs.

Goal S-4: Protect life, structures, and the environment from the harmful effects of hazardous materials and waste.

Policy S-4.1: Promote and support the proper disposal, handling, transport, delivery, treatment, recovery, recycling, and storage of hazardous materials in accordance with applicable federal, State, and local regulations.

Policy S -4.2: Require areas of known or suspected contamination to be assessed prior to reuse or redevelopment. Plan for reuse of contaminated areas in a manner that is compatible with the nature of the contamination and subsequent remediation efforts.

Policy S -4.3: Require areas of known or suspected contamination to be assessed prior to reuse or redevelopment. Plan for reuse of contaminated areas in a manner that is compatible with the nature of the contamination and subsequent remediation efforts.

Policy S-4.4: Avoid locating sensitive uses near established hazardous materials users or industrial areas where incompatibilities would result, except in cases where appropriate safeguards have been developed and implemented.

Goal S-5: Establish and maintain an effective emergency response program to respond to disasters and maintain continuity-of-life support functions during an emergency.

Policy S-5.3: Develop, implement, and maintain an effective evacuation program for areas of risk in the event of a disaster.

Goal S-7: Comply with the McClellan-Palomar Airport Land Use Compatibility Plan.

Policy S -7.1: Record an overflight notification document in association with the approval of any new residential land use within the AIA [Airport Influence Area] overflight notification area consistent with the ALUCP.

3.8.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts related to hazards and hazardous materials are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to hazards and hazardous material would occur if the project would:
▪ Threshold No. 1: Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-13
▪ Threshold No. 2: Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. ▪ Threshold No. 3: Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. ▪ Threshold No. 4: Be located on a site which is included on a list of hazardous materials sites com piled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment.
▪ Threshold No. 5: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area. ▪ Threshold No. 6: Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.
▪ Threshold No. 7: Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires.

3.8.4 Project Impact Analysis
Impacts related to hazards and hazardous materials as a result of development of the project are analyzed below.

Threshold No. 1. Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Construction of the project would entail transport, use, or disposal of potentially hazardous materials including, but not lim ited to , diesel fuel, gasoline, equipment fluids, concrete, cleaning solutions and solvents, lubricant oils, adhesives, human waste, and chemical toilets. Direct impacts to human health and biological resources from accidental spills of small amounts of hazardous materials from construction e quipment could occur with the transport, use, or disposal of these materials. However, existing federal and state standards related to the handling, storage, and transport of these materials would be implem ented during construction of the project. These regulations include the Federal Chemical Accident Prevention Provisions (Part 68 of th e Code of Federal Regulations); California Highway Patrol and California Department of Transportation container and licens ing requirements for transportation of hazardous waste on public roads; IFC; RCRA of 1976 as amended by the Hazardous and Solid Waste Amendments of 1984; California’s Hazardous Waste Control Law; CFC; California Health and Safety Code Hazardous Materials R elease Response Plans and Inventory; California Integrated Waste Management Act; regulations developed by California Occupations Safety and Health Administration; and the state Hazardous Waste Control Act.

During operation of the project, the only hazardous materials anticipated for transport, use, or disposal would be routinely used household products such as cleaners, paint, solvents, motor oil/automotive products, batteries, and garden maintenance products , which are typical of residential uses . The use , handling, and disposal of these products is addressed by household hazardous waste programs that are part of the Integrated Waste Management Plan of the County. The Household Hazardous Waste Element of the Integrated Waste Management Plan specifies the means by which hazardous wastes generated by households shall be collected, recycled, treated, and disposed of safely (County of San Diego 2005).

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-14
The project’s compliance with all standards required through federal, state, County, and municipal regulations, in addition to project -specific plan s reviewed by the City, would ensure potential impacts to the public or the environment through routine transport, use, or disposal of hazardous materials would not be substantial. Therefore, impacts related to transport of hazardous materials would be less than significant.

Threshold No. 2. Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? As discussed under Threshold No. 1, above, construction of the project would entail transport, use, or disposal of potentially hazardous materials including, but not limited to , diesel fuel, gasoline, equipment fluids, concrete, cleaning solutions and solvents, lubricant oils, adhesives, human waste, and chemical toilets. As described above, the project would be required to comply with all standards required through federal, state, County, and municipal regulations, in addition to project-specific plans review by the City, which would ensure potential impacts related to hazardous materials would not be significant.

The project would be limited to townhome residences, residential amenitie s, and some recreational uses , which are not typically characteristic of generating, releasing, or using large amounts of hazardous materials. During operations of the project, the only hazardous materials anticipated for transport, use, or disposal are routinely used household products such as cleaners, paint, solvents, motor oil/automotive products, batteries , and garden maintenance products. The use, handling, and disposal of these products are addressed by household hazardous waste programs that are part of the Integrated Waste Management Plan of the County, and therefore the project is not expected to create a significant hazard to the public or environment through hazardous upsets or accidents.

For these reasons, the project is not expected to result in potential upset and accident conditions involving release of hazardous materials in the environment; and impacts from a foreseeable upset would be less than significant.

Threshold No. 3: Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? The project site is located within 0.25 miles of an existing or proposed school. The closest school to the project site is Palomar College, located approximately 0.2 miles east of the project site. However, the project is not expected to emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste beyond routinely used household products such as cleaners, paint, solvents, motor oil/automotive products, batteries, and garden maintenance products. Uses of these materials are typical of such residential land uses. Considering the project is surrounded by existing development, including industrial and commercial uses between the project site and Palomar College, project impacts related to exposing an existing or proposed school to hazardous materials would be less than significant.

Threshold No. 4. Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
As part of the Phase I ESA prepared for the project site (Appendix F), a database search report was completed, which documents various federal, state, and local regulatory database searches regarding properties with known or suspected releases of hazardous materials, chemical handlers, and/or polluters. As outlined above in Section 3.8.1, Existing Conditions , the project site is not located on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5. Therefore, this impact would be less than significant.

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-15
Threshold No. 5: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? The closest airport to the project site is the M cClellan-Palomar Airport, which is located approximately 5.5 miles west of the project site. The project site is located within Review Area 2 of the McClellan-Palomar Airport, which limits the height of structures in areas of high terrain. Given that that project site is not located within an area with high terrain, no height limit restrictions apply to the project within the Airport Influence Area (San Diego County Regional Airport Authority 2011). Therefore, this impact would be less than significant.

Threshold No. 6: Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
According to the General Plan Safety Element, the San Marcos Emergency Operations Plan (EOP) governs the operations of the City during a disaster. This plan addresses response to moderate evacuation scenarios, including the identification of evacuation points and general routes (City of San Marcos 2012).

Additionally, the City is a participating jurisdi ction in the County Operational Area EOP, which provides a planned response to disasters within the operational area. The project would conform with the standards set forth in the Operational Area EOP and would be required to abide by the standards set forth in the San Marcos EOP.

Implementation of the project is not expected to impact any roadway or staging areas that are identified in any emergency planning documents and would not impair implementation of or physically interfere with an a dopted emergency response plan or emergency evacuation plan. As required under the CFC, t he project would be required to present development plans that afford fire and emergency responders suitable fire access roads ’ dimensions and surfaces (Chapter 5, Sections 503.1 through 503.4 of the CFC), and an adequate number of emergency-rated entrances to the community (Appendix D, Section D106 of the CFC). The proposed points of entry and private driveways will be reviewed by SMFD and would be required to meet the qualifications for emergency access to and from the project site. Furthermore, as described in Chapter 3.13 , Public Services, of this EIR, the Preliminary Fire Emergency Response Analysis prepared for the project (Appendix J to this EIR) determined that SMFD could provide emergency response to the project site within its internal 7 -minute response time from Fire Station 1. Therefore, it is determined th at impacts related to emergency response or emergency evacuation as a result of the project would be less than significant .

Threshold No. 7: Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
As described in Chapter 5 of this EIR, wildfire was an environmental topic area found not to be significant as it relates to the project site. The project site is not located in any fire hazard severity zones (CAL FIRE 2022). The project site is an undeveloped infill lot that is relatively flat and shows signs of previous disturbance . The project would not include associated infrastructure that may exacerbate fire risk. Additionally, the project would be required to comply with all applicable state and local fire codes, including compliance with the CFC and SMFD, which require a design that affords fire and emergency responders suitable fire access roads ’ dimensions and surfaces (Chapter 5, Sections 503.1 through 503.4 of the CFC), and an adequate number of emergency -rated entrances to the community (Appendix D, Section D106 of the CFC). Furthermore, as dete rmined in the Fire Response Summary Letter prepared for the project (Appendix J to this EIR), SMFD’s existing Station 1 would adequately serve the project site while maintaining SMFD’s response goals.

3.8 – HAZARDS AND HAZARDOUS MATERIALS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.8-16
For the reasons stated above and considering the project site is located in an urbanized area surrounded on all sides by existing development, implementation of the project would not expose people or structures to risk of loss, injury, or death involving wildfires, and impacts would be less than significant.

3.8.5 Cumulative Impact Analysis
Hazardous materials impacts are generally site specific and thus handled on a site -by-site basis. Identified cumulative projects are located more than 0.25 miles from the project site and thus would be unlikely to result in cumulative impacts to hazardous and hazardous materials together with the project. In addition, any cumulative project would be required to identify existing hazardous materials on site and comply with existing regulations related to use, transport, and disposal of hazardous materials. Similarly, all cumulative projects would be required to analyze and properly mitigate any impacts to the existing evacuation plan if impacts are identified.

With regard to wildfire hazards, any of the cumulative projects proposed within the wildland urban interface would be required to meet minimum fire fuel modification and/or clearing requirements in addition to meeting whatever standards of the various fire codes in effect at the time of building permit issuance. For projects within the City , these requirements are implemented through preparation of and compliance with a Fire Protection Plan, which is reviewed and approved by the Fire Marshal.

Therefore, the project’s and cumulative project s’ compliance with applicable regulations related to hazards and wildfire would ensure impacts related to hazards and hazardous materials would be less than significant.

3.8.6 Mitigation Measures
No impacts to hazards and hazardous materials were identified; thus, no mitigation measures are required.

3.8.7 Conclusion
As discussed above in Section 3.8.4, the project site is currently undeveloped and is not listed on any hazardous materials sites or databases. Construction and operation of the project is not expected to result in the transport, release, or disposal of any significant hazardous materials. Development of the project would not interfere with an adopted emergency response plan or emergency evacuation plan. Lastly, the project site is not designated as located within a high fire severity zone and proposed residential development on site would be constructed in accordance with all applicable fire codes and regulations . As such, project -level and cumulative -level impacts related to hazards and hazardous materials would be less than significant.

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-1

3.9 Hydrology and Water Quality
This section describes the existing hydrology and water quality of the proposed Gran Vista Specific Plan Project (project), identifies associated regulatory requirements, and evaluates potential impacts related to implementation of the project.

The analysis in this chapter relies on the following reports prepared for the project:
▪ Geotechnical Evaluation for the Proposed “Las Posas” Residential Development, prepared by L GC Geotechical Inc., July 15, 2021 (included as Appendix E to this environmental impact report [EIR]). ▪ Preliminary Drainage Study for Gran Vista , prepared by Hunsaker & Associates , May 20, 2022 (included as Appendix G to this EIR).
▪ Storm Water Quality Management Plan for Gran Vista, prepared by prepared by Hunsaker & Associates, May 20, 2022 (included as Appendix H to this EIR).

Table 3.9-1 summarizes the project- and cumulative-level hydrology and water quality impact analysis by threshold.

Table 3.9-1. Hydrology and Water Quality Summary of Impacts Threshold of Significance
Project -Level
Impact
Cumulative -
Level Impact
Significance
Determination
No. 1: Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality.

Less than
Significant
Less than
Significant
Less than
Significant
No. 2: Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such that the project may impede sustainable groundwater
management of the basin.

Less than
Significant
Less than
Significant
Less than
Significant
No. 3: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site.

Less than
Significant
Less than
Significant
Less than
Significant
No. 4: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite.

Less than
Significant
Less than
Significant
Less than
Significant
No. 5: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would create or contribute
runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

Less than
Significant
Less than
Significant
Less than
Significant
No. 6: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows
Less than
Significant
Less than
Significant
Less than
Significant

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-2
Table 3.9-1. Hydrology and Water Quality Summary of Impacts Threshold of Significance
Project -Level
Impact
Cumulative -
Level Impact
Significance
Determination
No. 7: In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.

Less than
Significant
Less than
Significant
Less than
Significant
No. 8: Conflict with or obstruct implementation of water quality control plan or sustainable groundwater
management plan?
Less than
Significant
Less than
Significant
Less than
Significant

3.9.1 Existing Conditions
This section details the existing hydrology, water quality and groundwater conditions on the project site.

Hydrologic Setting
The project site is located at the northeastern corner of W Mission Road and N Las Posas Road in the City of San Marcos (City), San Diego County, Ca lifornia. The site is bounded to the southwest by W Mission Road and to the east by N Las Posas Road. The project site is primarily flat with two mass graded pads. Site surface conditions generally consist of rolling unimproved earthen terrain, with low -growing vegetation. Surface drainage is directed toward the southwestern corner of the property toward W Mission Road . Elevation on the project site is approximately 575 feet above mean sea level.

Water arrives on site via natural rainfall only. Rainfall runoff from the site typically only occurs during a significant wet weather event. Water that does accumulate on site generally drains in a southwestern direction to an existing 12-inch corrugated metal pipe riser to a 12-inch corrugated metal pipe to meet up with the commercial site to the south of the project site . Water is then conveyed west through a storm channel and eventually downstream to Las Posas Creek south. The project site is mostly located outside of the Federal Emergency Management Agency (FEMA) 100-year floodplain zone , with the exception of a small portion of t he southwestern portion of the site , which is located in Zone X, and the northeastern edge of the project site, which is located in Zone AE, of the Flood Insurance Rate Map Panel 06073C0789H. Zone X is defined as areas determined to be outside the 0.2% chance of flooding each year and Zone AE is defined as having a 1% chance of flooding every year.

Water Quality
The project is located within the jurisdiction of the San Diego Regional Water Quality Control Board (RWQCB). The San Diego Region is divided into 11 hydrologic units. The project site is located in Richland Hydrologic Subarea (HSA) (HSA 904.52), within the San Marcos Hydrologic Area (HA) (HA 904.52) which is part of the Carlsbad Watershed Hydrologic Unit (HU) (HU 904.00) (RWQCB 2021a). The Carlsbad HU is a triangular area covering approximately 210 square miles (SWRCB 2002). This hydrologic unit is bordered by San Luis Rey HU to the north and San Dieguito HU to the east and south. The Carlsbad HU includes one small coastal lagoon (Loma Alta Slough) and four major coastal lagoons, including Buena Vista, Agua Hedionda, Batiquitos, and San Elijo (SWRCB 2002). The Carlsbad HU is separated into four primary subwatersheds based on topographical drainage areas to creek systems, including 904.1, San Luis Rey River; 904.3, Agua Hedionda Creek; 904.5, San Marcos Creek; and 904.6, Escondido Creek.

Each of these subwatershed areas is further refined by eight creek system branches divided into hydrographic subareas (City of San Marcos 2012a).

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-3
The protection of watersheds and water quality is a prominent concern for the City sin ce all of the major creeks and their tributaries (San Marcos, Agua Hedionda, and Escondido) are listed by the State Water Resources Control Board (SWRCB) as impaired for a variety of pollutants that ultimately affect the water quality of surface and groundwater supplies and biological resources. The City has partnered with other jurisdictions in the watersheds to implement water quality ma nagement plans for nutrients and bacteria in coordination with the San Diego RWQCB to protect the watersheds and address the water body impairments. The City is the lead agency for the nutrient management plan in the Upper San Marcos Creek Watershed (City of San Marcos 2012a).

The S an Diego RWQCB has adopted the Water Quality Control Plan for the San Diego Basin (Basin Plan ) (RWQCB 2021b) that outlines beneficial uses and water quality objectives that are protective of the beneficial uses for each of the HSAs in the City of San Marcos General Plan ( General Plan) area. In addition, the S an Diego RWQCB has adopted Order R9 -2007-0001, Waste Discharge Requirements for Discharges of Urban Runoff From the Municipal Separate Storm Sewer Systems (MS4s) (RWQCB 2007 ). The City regionally and locally implements the requirements of Order R9 -2007-0001. This includes best management practice (BMP) inspection programs for businesses, municipal facilities, and treatment control facilities; preventative programs such as str eet sweeping and storm drain facility cleaning; monitoring water quality within the City; and integrating site design, source control, low impact development (LID), treatment controls, and hydromodification design for City projects and private development and redevelopment to reduce the amount of polluted stormwater entering the City’s storm drain system (City of San Marcos 2012a).

Due to the undeveloped condition of the project site and relatively flat terrain, the project site in current conditions does not contribute to water quality issues in the City.

Groundwater
As described in the Preliminary Geotechnical Evaluation prepared for the project (Appendix E), shallow groundwater was not encountered during drilling operations, which included excavations up to a depth of 15.5 feet below existing ground surfaces. Localized perched groundwater may be present but is also not anticipated to be a factor in site development, with the exception that seasonal water levels are likely to impact stormwater management.

The Basin Plan identifies beneficial uses for groundwater in the four primary subwatersheds as municipal, agricultural, and industrial uses. The City is located in th e California Department of Water Resources (DWR) South Coast Hydrologic Region. DWR Bulletin 118 identifies the San Marcos Area as Basin 9 -32 (DWR 2020). The DWR San Marcos Area is 2,129 acres. This groundwater basin is located entirely within San Marcos C reek HAS 904.52, which is designated as impaired and has a hydrologic connection to Lake San Marcos . Other minor groundwater basins and wells are located throughout the General Plan area outside of Basin 9 -32; however, Basin 9-32 is the only groundwater basin formally designated in the General Plan area.

The implementation of watershed protection programs in the City to protection the beneficial uses identified in the Basin Plan is critical to protecting the City’s ability to use these resources. Due to the undeveloped condition of the project site, the project site in current conditions does not contribute to groundwater contamination, nor is groundwater used in current conditions. The project would connect to existing City infrastructure for water use and would not use groundwater for construction or operation.

3.9.2 Regulatory Setting
This section details the applicable federal, state, and local regulations pertaining to hydrology and water quality.

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-4
Federal
Federal Emergency Management Agency
FEMA administers the National Flood Insurance Program to provide subsidized flood insurance to communities that comply with FEMA regulations limiting development in floodplains. FEMA also issues Flood Insurance Rate Maps that identify which land areas are subject to flooding. These maps provide flood information and identify flood hazard zones in the community. The standard for flood protection is established by FEMA, with the minimum level of flood protection for new development determined to be the 1% annual exceedance probability (i.e., the 100 -year flood event). A small portion of the project site is located within a 100-year flood zone.

Federal Clean Water Act
The Clean Water Act (CWA) establishes the basic structure for regulating discharges of pollutants int o the waters of the United States and regulating quality standards for surface waters. The basis of the CWA , the Federal Water Pollution Control Act , was enacted in 1948 ; the act was significantly reorganized and expanded in 1972. The Clean Water Act became the act’s common name with amendments in 1977.

Under the CWA, the U.S. Environmental Protection Agency (EPA) has implemented pollution control programs such as setting wastewater discharge standards for industry. The EPA has also set water quality standards for contaminants in surface waters. The CWA made it unlawful to discharge any pollutant from a point source into navigable waters unless a permit was obtained.

Under Section 303(d) of the CWA, states are required to develop lists of water bodies that would not attain water quality objectives after implementation of required levels of treatment by point -source dischargers (municipalities and industries). Section 303(d) requires that the state develop a TMDL for each of the listed pollutants. The TMDL is the amount of loading that the water body can receive and still be in compliance with water quality objectives. The TMDL can also act as a plan to reduce loading of a specific pollutant from various sources to achieve compliance with water quality objectives. The TMDL prepared by the state must include an allocation of allowable loadings to point and nonpoint sources, with consideration of background loadings and a margin of safety. The TMDL must also include an analysis that shows the linkage between loading reductions and the attainment of water quality objectives. EPA must either approve a TMDL prepared by the state or, if it disapproves the state’s TMDL, issue its own. National Pollutant Discharge Elimination System (NPDES) permit limits for listed pollutants must be consistent with the waste load allocation prescribed in the TMDL s. After implementation of a TMDL, it is anticipated that the problems that led to placement of a given pollutant on the Section 303(d) list would be remediated.

National P ollutant Discharge Elimination System
The NPDES permit system was established in the federal CWA to regulate municipal and industrial discharges to surface waters of the United States. Sections 401 and 402 of the CWA contain general requirements regarding NPDES permits. Section 307 of the CWA describes the factors that EPA must consider in setting effluent limits for priority pollutants.

Nonpoint sources are diffuse and originate from a wide area rather than from a definable point. Nonpoint pollution often enters receiving waters in the form of surface runoff, but is not conveyed by way of pipelines or discrete conveyances. As defined in the federal regulations, such nonpoint sources are generally exempt from federal NPDES permit program requirements. Howeve r, three types of nonpoint source discharges are controlled

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-5
by the NPDES program: nonpoint source discharge caused by general construction activities, the general quality of stormwater in municipal stormwater systems, and discharges associated with industr ial operations. The 1987 amendments to the CWA directed EPA to implement the stormwater program in two phases. Phase I addressed discharges from large (population 250,000 or above) and medium (population 100,000 to 250,000) municipalities and certain industrial activities. Phase II addresses all other discharges defined by EPA that are not included in Phase I.

In accordance with NPDES regulations, in order to minimize the potential effects of construction runoff on receiving water quality, the state requires that any construction activity that disturbs 1 acre or more must obtain a General Construction Activity Stormwater Permit. Permit applicants are required to prepare a stormwater pollution prevention plan (SWPPP) and implement BMPs, such as erosion and sediment control and non -stormwater management measures, to reduce construction effects on receiving water quality.

Examples of typical BMPs implemented in SW PPPs include using temporary mulching, seeding, or other suitable stabilization measures to protect uncovered soils; storing materials and equipment to ensure that spills or leaks cannot enter the storm drain system or surface water; developing and impleme nting a spill prevention and cleanup plan; installing traps, filters, or other devices at drop inlets to prevent contaminants from entering storm drains; and using barriers, such as straw bales or plastic, to minimize the amount of uncontrolled runoff that could enter drains or surface water.

The project would be subject to permit requirements and would develop and implement a project -specific SWPPP to minimize construction activity impacts.

State
California Water Code Division 7 (Porter -Cologne Act)
The California Water Code contains provisions regulating water and its use. Division 7 establishes a program to protect water quality and beneficial uses of state water resources including groundwater and surface water. The SWRCB and RWQCB administer the program and are responsible for control and water quality. They establish waste discharge requirements, oversee water quality control planning and monitoring, enforce discharge permits, and establish groundwater and surface water quality objectives.

State Water R esources Control Board
In California, the SWRCB has broad authority over water -quality control issues for the state. The SWRCB is responsible for developing statewide water quality policy and exercises the powers delegated to the state by the federal government under the CWA. Other state agencies with jurisdiction over water quality regulation in California include California Department of Public Health (for drinking water regulations), the California Department of Pesticide Regulation, the California Depar tment of Fish and Wildlife, and the Office of Environmental Health and Hazard Assessment.

Construction General Permit
Owners and operators of construction activities who disturb 1 or more acres of soil, or who disturb less than 1 acre but are part of a larger common plan of development that in total disturbs 1 or more acres, are required to obtain coverage under the SWRCB’s Order 2009-0009-DWQ (as amended by 2010-0014-DWQ and 2012-0006-DWQ), the Construction General Permit. Construction and demolition activities subject to this permit include clearing, grading,

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-6
grubbing, and excavation or any other activity that results in a land disturbance equal to or greater than 1 acre.

Applicants are required to submit a notice of intent to the SWRCB and prepare a SWPPP. The SWPPP must identify BMPs that are to be implemented to reduce construction impacts on receiving water quality based on potential pollutants. The SWPPP also must include descriptions of the BMPs to be implemented to reduce pollutants in stormwater discharges after construction phases are completed at a site (post-construction BMPs).

Regional Water Quality Control Board
The project site is situated within the jurisdiction of the San Diego RWQCB (Region 9). The San Diego RWQCB has the authority to implement water quality protection standards through the issuance of permits for discharges to waters at locations within its jurisdiction.

The project site is located in the Richland HSA within the San Marcos HA, which is part of the C arlsbad HU. The Basin Plan was prepared by the RWQCB in compliance with the federal CWA and the Porter -Cologne Act and establishes water quality objectives and implementation programs to meet stated objectives and to protect the beneficial uses of water bo dies in the area . Because the City is located within the RWQCB’s jurisdiction, all discharges to surface water or groundwater are subject to the Basin Plan requirements.

In May 2013, the San Diego RWQCB adopted Order R9 -2013-0001, the new municipal NPDES p ermit for 39 municipal, county government, and special district entities located in southern Orange County, southwestern Riverside County, and San Diego County that own and operate large municipal separate storm sewer systems (MS4s) that discharge stormwater runoff and non -stormwater runoff to surface waters throughout the San Diego region. This permit requires development projects to minimize or eliminate the impacts of such development on water quality. The project is subject to the requirements of the MS4 Permit as it is implemented via the Carlsbad Watershed Urban Runoff Management Program. The specific requirements include the selection of appropriate BMPs to avoid, prevent, or reduce the pollutant loads entering the storm drain system and receiving wat ers. The permit was amended in February 2015 by Order R9-2015-0001 and in November 2015 by Order R9-2015-0100.

Provision D.1.a of Order R9 -2013-0001 requires the San Diego Stormwater Co -Permittees to continue water monitoring programs established within p revious orders and pursuant to the approved Hydromodification Management Plan (2011). The City is one of the co-permittees.

To comply with Order R9-2013-0001, as amended, the September 2020 Model BMP Design Manual – San Diego Region (BMP Design Manual) was developed to provide county-specific project design and post -construction stormwater requirements for development projects and to replace the prior San Diego Regional Model Standard Urban Stormwater Mitigation Plan (County of San Diego 2020). The BMP Design Manual was used to recommend BMPs and LID features for th is project. LID is an approach to land development that uses multiple small -scale natural detention and filtration features to manage stormwater as close to its source as possible. LID employs principles such as preserving and re -creating natural landscape features, minimizing effective imperviousness to create functional and appealing site drainage that treats stormwater as a resource rather than a waste product.

Local
Carlsbad Watershed Management Area Water Quality Improvement Plan On May 8, 2013, the San Diego RW QCB adopted Order R9 -2013-0001, a n NPDES MS4 Permit, regulating discharges from Phase I MS4s in the San Diego region (SWRCB 2015). Provision B of the permit requires Responsible Agencies in each of the region’s Watershed Management Areas to develop water q uality

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-7
improvement plans (WQIPs) that identify water quality conditions and strategies to improve water quality within the watershed. Through the WQIP approach, Highest Priority Water Quality Conditions within the Watershed Management Areas are identified and strategies are implemented through the Responsible Agencies’ jurisdictional runoff management plan to progressively improve water quality. The plans contain an adaptive planning and management process and a public participation component. The Carlsbad Watershed Management Area WQIP was prepared in May 2018 for the Carlsbad Watershed Management Area Responsible Agencies , which include the Cities of Carlsbad, Encinitas, Escondido, Oceanside, San Marcos, Solana Beach, and Vista and the County of San Diego (Carlsbad WMA Responsible Agencies 2016).

San Marcos Storm Water Standards
The City has adopted the use of the BMP Design Manual for the San Diego region as the City’s Storm water Standards Manual, and the project must comply with the standards and regulations contained therein (County of San Diego 2020).

City of San Marcos General Plan
Conservation and O pen Space Element
The following are applicable goals and policies from the Conservation and Open Space Element of the General Plan related to hydrology and water quality (City of San Marcos 2012a):

Goal COS-6: Protect and restore appropriate surface water and groundwater be neficial uses through prioritizing the improvement of locally impaired water bodies within the City of San Marcos sub watersheds.

Policy COS-6.2: Promote watershed stewardship as the community norm.

Goal COS -7: Achieve sustainable watershed protection for surface and ground water quality that balances social, economical, and environmental needs.

Policy COS-8.4: Require new development and redevelopment to protect the quality of water bodies and natural drainage systems through site design, source controls, storm water treatment, runoff reduction measures, BMPs, LID, hydromodification strategies consistent with the Current San Diego RWQCB Municipal Stormwater NPDES Permit, and all future municipal stormwater permits.

Safety Element
The following goal and policy in the Safety Element of the General Plan are applicable to flooding and flood control (City of San Marcos 2012b):

Goal S-2: Minimize the risk to people, property, and the environment due to flooding hazards.

Policy S-2.2: Require existing private development to take responsibility for maintenance and repair of structures to resist flood damage.

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-8
Land Use and Community Design Element
The following goal and policies in the Land Use and Community Design Element of the General Plan are applicable to stormwater drainage facilities (City of San Marcos 2012c):

Goal LU-15: Flood control and storm water drainage facilities: ensure adequate flood control and storm water drainage is provided by the community.

Policy LU -15.1: Implement acti vities, practices, procedures, or facilities that avoid, prevent, or reduce pollution of the San Marcos Storm Water Conveyance System and receiving waters.

Policy LU -15.2: Improve inadequate or undersized drainage/flood control facilities to solve both sma ll neighborhood and large regional drainage and flood control problems.

Policy LU-15.3: Avoid, to the extent possible, development in floodplain and flood prone areas.

Policy LU -15.4: Retain drainage courses in their natural condition, to the extent possib le. Consider smaller-scale drainage improvements to protect the environment and avoid disturbing natural drainage courses; consider detention areas and raised building pads.

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10, Land Use and Planning. As detailed in Section 3.10, the project is consistent with the applicable goals and policies pertaining to hydrology and water quality.

City of San Marcos Ordinances
The Storm Water Management and Discharge Control Ordinance (San Marcos Municipal Code Chapter 14.15) requires that all new development and redevelopment activities comply with the stormwater pollution prevention requirements. Th ese stormwater pollution prevention requirements, which are described in detail in Section 14.15.050 of the Municipal Code, Reduction of Pollutants in Storm Water, include construction, development and redevelopment, and residential BMPs.

3.9.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to hydrology and water quality are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to hydrology and water quality would occur if the project would:
▪ Threshold No. 1: Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality.
▪ Threshold No. 2: Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin. ▪ Threshold No. 3: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on or off site.

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-9
▪ Threshold No. 4: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite.
▪ Threshold No. 5: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or r iver or through the addition of impervious surfaces, in a manner which would c reate or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. ▪ Threshold No. 6: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows.
▪ Threshold No. 7: In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation. ▪ Threshold No. 8: Conflict with or obstruct implementation of a water quality control or sustainable groundwater management plan.

3.9.4 Project Impact Analysis
This section considers the impacts to hydrology and water quality that would result from implementation of the project.

Threshold No. 1: Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Construction activities associated with the project could result in potential impacts to water quality. In addition to sediment erosion from ground-disturbing activities on the project site, f uels, oils, lubricants, and other hazardous substances used during construction could be released and potentially impact water quality.

The project would be required to comply with the SWRCB NPDES Construction General Permit Order No. 2009-0009-DWQ for stormwater discharges and general construction activities, and would incorporate standard BMPs, such as regular cleaning or sweeping of construction areas and impervious areas, as well as various stormwater BMPs, such as filtration media screens. In compliance with the Construction General Permit, a SWPPP will be prepared for the project that would specify BMPs that would be implemented during construction to minimize impacts to water quality. Lastly, project implementation of biofiltration, source control, and site design BMPs would effectively treat post- construction stormwater runoff prior to discharge from the site in compliance with the requirements of the BMP Design Manual and BMPs outlined in the Storm Water Quality Management Plan (SWQMP) (Appendix H).

The proposed biofiltration features on site would be subject to regular inspection and maintenance. The property owner is required, pursuant to San Marcos Municipal Code Section 14.15 and the BMP Design Manual, to enter into a stormwater management and discharge control maintenance agreement fo r the installation and maintenance of permanent BMPs prior to issuance of permits.

As described in Section 3.8, Hazards and Hazardous Materials , of this EIR, proposed residential uses do not typically generate, releas e, or us e large amounts of hazardous ma terials. The only hazardous materials anticipated would be for transport, use, or disposal of routinely used household products such as cleaners, paint, solvents, motor oil/automotive products, batteries , and garden maintenance products, typical of residen tial land uses. Operation of the project is not expected to include uses that would violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface water or groundwater quality.

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-10
Furthermore, uses associated with construction and operation of the project would likely be less of a detriment to water quality than those uses associated with commercial uses, which is the current designated land use for the project site.

The implementation of biofiltration, source control, and site design BMPs and a SWPPP would effectively treat runoff prior to discharge from the site in compliance with the requirements of the BMP Design Manual and BMPs outlined in the SWQMP. Therefore, with implementation of all required BMPs as conditions of project approval, the project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface water or groundwater quality. Impacts to water quality would be less than significant.

Threshold No. 2: Would the project substantial ly decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? As discussed above, l ocalized perched groundwater may be present on the project site; h owever, no static groundwater was encountered that would be indicative of an aquifer occurring below the site . As described in the response to Threshold No. 1, the project would treat stormwater runoff through the use of biofiltration basins. All stormwater w ould be adequately treated by the biofiltration basins prior to being discharged to natural/ undisturbed areas that could allow the runoff to infiltrate into the ground and eventually reach groundwater. As the project would use biofiltration and BMPs that would effectively treat stormwater runoff, it is not expected that project implementation would have a potentially significant adverse impact on groundwater quality or cause or contribute to an exceedance of applicable groundwater water quality objectives or degradation of beneficial uses.

Further, as discussed in Section 3.17, Utilities and Service Systems, the project would receive water from the Vallecitos Water District, which receives its water from the Metropoli tan Water District of Southern California. The Metropolitan Water District obtains water from local sources and the Colorado River, via the Colorado River Aqueduct, and the Sacramento -San Joaquin Delta, via the State Water Project (MWD 2016). No groundwate r would be used for project construction. During operation, irrigation for the site would tie into the proposed looping water system on site . Irrigation of landscaping throughout the project site would be required to comply with the City’s Water Efficient Landscape Ordinance and the City’s Landscape Manual. No groundwater would be used for operation of the project , and implementation of the pr oject would not interfere with infiltration and groundwater recharge. Additionally, implementation of the project would not decrease groundwater basins through increasing water demand on site or impede sustainable groundwater management of any groundwater basin. Therefore, impacts to groundwater supplies would be less than significant.

Threshold No. 3. Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site? There are no existing streams or rivers on site that would be substantially altered as a result of project implementation. As discussed above, the project site drainage is collected in a corrugated metal pipe riser that drains to a 12-inch corrugated metal pipe to meet up with the commercial site to the south of the project site . The remainder of the project site surface drains to the surrounding streets. The project site is currently a vacant lot and has no existing impervious areas. Project implementation would introduce new impervious areas and include on-site drainage systems that would alter the existing drainage pattern on the project site.

As described in response to Threshold No. 1, the project would be required to implement BMPs during construction and incorporate storm drain and biofiltration basins into development design . With implementation

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-11
of the proposed biofiltration basins, the project would not generate runoff volumes that would significantly alter the overall drainage on site. Additionally, project-related runoff would be adequately treated prior to discharge into planned drainage systems via biofiltration and BMPs such that the project would not provide substantial additional sources of polluted runoff.

The project would be required to demonstrate adequate drainage on site and connections off site to existing facilities in project-specific plans to be reviewed and approved by the City. Further, implementation of BMPs and a SWPPP would ensure construction of the project would not result in substantial erosion or siltation on or off site. A SWQMP was prepared for the project and is included as Appendix H of this EIR. The SWQMP recommends storm drains, such as biofiltration basins, for the project site. Recommendations outlined in the SWQMP would be conditions of approval for the project. These components would properly handle runoff to meet regulatory requirements and to ensure p ost-development runoff quantities and rates that are similar to, or less than , pre- development conditions. Therefore, impacts to existing drainage on site would be less than significant.

Threshold No. 4. Would the project substantially alter the existing drainage patter n of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces , in a manner which would substantially increase the rate or amount of surface runoff in a mann er which would result in flooding on- or off-site?
Please refer to response to Threshold No. 3. Implementation of the project would increase the area of impervious surface on the project site, which could increase runoff flow rates and volumes. However, the project would include implementation of BMPs during construction and proposed storm drain and biofiltration basins during operation as recommended by the SWQMP (Appendix H). Drainage facilities such as curb inlets, storm drains, flow control, and detention vaults would assist in reducing runoff from the project site. This would ensure that the runoff quantities generated by the project do not significantly alter the existing drainage pattern of the site resulting in flooding. As concluded in the Drainage Study (Appendix G), development of the project would result in a 0.8% increase of peak discharge, which is considered negligible , and would not impact downstream propertie s or facilities. Impacts would be less than significant.

Threshold No. 5. Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? Please refer to response to Threshold No. 3 and Threshold No. 4. As described above, i mplementation of t he project would increase impervious areas on-site. However, the project would include implementation of BMPs during construction and proposed storm drain and biofiltration basins during operation as recommended by the SWQMP (Appendix H). Drainage faciliti es such as curb inlets, storm drains, flow control , and detention vaults would assist in reducing runoff from the project site. These components would properly handle runoff to meet regulatory requirements and to ensure that post -development runoff would occur at rates that are similar to , or less than, pre-development conditions. Further, preparation and implementation of a SWPPP and implementation of project specific BMPs would ensure construction of the project would not result in substantial additional sources of polluted runoff. For these reasons, i mplementation of the project would not alter the course of a stream or river, and development of the project is not expected to exceed the capacity of existing or planned stormwater drainage systems or result in substantial sources of polluted runoff. Therefore, i mpacts related to stormwater drainage would be less than significant.

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-12
Threshold No. 6: Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows?
Please refer to the responses to Threshold Nos. 3, 4 and 5. The project would increase the impervious surface area on site in comparison to existing conditions, which could increase runoff flow rates or volumes. However, the project site and the immediate area are relatively flat and do not currently result in flooding during storms. As concluded in the Drainage Study (Appendix G), development of the project would result in a 0.8% increase of peak discharge, which is considered negligible , and would no t impact downstream propertied or facilities. On-site drainage facilities and off -site drainage connections would be designed to collect and convey runoff from 100-year storm events. Implementation of the project is not expected to impede or redirect flood flows and impacts to stormwater drainage would be less than significant.

Threshold No. 7: In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
The project site is approximately 8.5 miles inland from the Pacific Ocean and would not be subject to inundation by tsunami. A small southwest portion of the site is located within a 100 -year flood hazard area (Zone AE) .

Despite a small portion of the project site being located within a 100-year flood hazard area , the base flood elevation at the portion of the site that is within the 100 -year flood hazard area would not reach to top of the slope. The project is not located in a tsunami or seiche zones. Given that the project site is not l ocated near a large standing body of water, inundation by seiche (or standing wave) is considered negligible. The project site is generally flat with no steep slopes and does not contain slopes subject to mudflows ; therefore, potential impacts related to inundation would be less than significant.

Threshold No. 8: Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
The Carlsbad Watershed Management Area WQIP was updated in May 2018 for the Car lsbad Watershed Management Area Responsible Agencies, which include the Cities of Carlsbad, Encinitas, Escondido, Oceanside, San Marcos, Solana Beach, and Vista and the County of San Diego. The purpose of the Carlsbad WQIP is to guide the Responsible Agencies’ jurisdictional runoff management plans towards achieving improved water quality in MS4 discharges (or stormwater discharges) and receiving water bodies. The Responsible Agencies’ jurisdictional runoff management plans contain the strategies, standards , and protocols by which each agency will implement their individual program in response to the priorities and goals established in the WQIP (Carlsbad WMA Responsible Agencies 2018).

The project is located within the San Marcos HA, which is the second larges t within the Carlsbad Watershed Management Area. The Carlsbad Watershed Management Area Water WQIP outlines areas of priority water quality conditions and highest -priority water quality condit ions. As discussed in Section 3.3, Biological Resources, no potential wetland or non-wetland water features are present within the project site. As such, the project would not conflict with or obstruct implementation of the Carlsbad Watershed Management Area Water WQIP or any other water quality plan. Further, the site is not located within a sustainable groundwater management plan area.

Therefore, impacts relating to a conflict with a water quality control plan or sustainable groundwater management plan would be less than significant.

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-13

3.9.5 Cumulative Impact Analysis
The project and cumulative projects would result in an increase of impervious surfaces in the area. More specifically, other large development projects nearby would result in conversion of large pervious areas to impervious areas. This would potentially result in increased surface runoff, alteration of the regional drainage pattern, and flooding. However, like the project applicant, each individual project applicant would be re quired to hydrologically engineer the respective cumulative project sites to ensure that post -development surface runoff flows can be accommodated by the regional drainage system.

The project, in conjunction with cumulative projects that drain to the San Marcos HA, ha ve the potential to increase the concentration of pollutants in surface runoff and downstream water quality. However, all cumulative projects would be subject to the same federal water quality standards and state waste discharge requirements as the project. This includes preparation of project -specific SWPPPs per the NPDES permit program and implementation of associated BMPs to prevent construction-related runoff from polluting receiving waters.

As discussed above, the project would incorporate biofiltration and BMPs into the project site design to limit the potential for water quality impacts to the greatest extent feasible. By incorporating these features into the project design, the project would not substantially contribute to a significant cumulative impact to water quality. Impacts would be less than significant.

3.9.6 Mitigation Measures
Based upon the analysis presented in Section 3.9.4 and 3.9.5, no impacts were identified , and no mitigation is required.

3.9.7 Conclusion
As described above, storm drainage components recommended by the Preliminary Drainage Study (Appendix G) would properly handle runoff to meet regulatory requirements and to ensure that post -development runoff would occur at rates that are similar to , or less than, pre-development conditions. Appropriate design of on - and off-site drainage facilities; implementation of a SWPPP, SWQMP, and BMPs; and implementation of all recommendations from the Preliminary Drainage Study and development-specific drainage plans would ensure the project would not substantially alter the drainage patterns on or off site or result in substantial polluted runoff . Therefore, impacts to hydrology and water quality as a result of the project would be less than significant.

3.9 – HYDROLOGY AND WATER QUALITY
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.9-14

INTENTIONALLY LEFT BLANK

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-1

3.10 Land Use and Planning
This section analyzes the potential for the proposed Gran Vista Specific Plan Project ( project) to have impacts related to land use and planning. This section considers consistency with applicable land use plans and habitat conservation plans.

Table 3.10-1 summarizes the project- and cumulative-level land use impact analysis for the project.

Table 3.10-1. Land Use Summary of Impacts
Threshold of Significance
Project -Level
Impact
Cumulative -
Level Impact
Significance
Determination
No. 1: Physically divide an established community. Less than Significant
Less than
Significant
Less than
Significant
No. 2: Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect.

Less than
Significant
Less than
Significant
Less than
Significant

3.10.1 Existing Conditions
This section describes the existing planning context for the project site, including the General Plan and Zoning designations that currently apply to the site.

Project Site
As shown in Figures 2-2 and 2-3, the project is located in north San Diego County within the northwestern portion of the City of San Marcos (City). The undeveloped project site is an approximately 7.6-acre site located at the northwest corner of N Las Posas Road and W Mission Road. The project site is located in an urban area of the City and surrounded by existing development , located in the College Area Neighborhood (City of San Marcos 2012a).

The project site is undeveloped and reflects a history of disturbance.

Existing General P lan Designation
The City of San Marcos General Plan (General Plan) designates the 7.6-acre project site as Commercial (C) (City of San Marcos 2012a). Development allowed under this land use designation must be consistent with those uses outlined in the San Marcos Municipal Code and zoning ordinance, as well as the Commercial land use designation of the General Plan. The Commercial (C) designation generally allows for a wide range of retail activities, services, and offices. Please refer to Figure 2-4, Existing General Plan Land Use.

Existing Zoning Designation
Existing zoning of the project site is Commercial (C). The purpose of the Commercial land use d esignation is to “provide a business district for the full range of retail goods, services, and commercial centers that stabilize, maintain, and enhance the vitality of San Marcos in a supportive commercial setting adjacent to thoroughfares.

Appropriate C Zone commercial uses will contribute to the range of service and destination retail, shopping centers, entertainment, and restaurant uses that generate a strong tax base” (City of San Marcos 2022) . The Commercial zone is intended to implement and be consistent with the Commercial land use designation of the General Plan (City of San Marcos 2022). Please refer to Figure 2-6, Existing Zoning.

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-2
Surrounding Land Uses
The project site is immediately bordered by N Las Posas Road to the east and W Mission Road to the southwest .

Beyond these adjacent roads, t he project site is surrounded by residential uses to the north, west, and east; industrial uses to the south; and commercial uses to the south and east. A CVS Pharmacy is loc ated directly south of the project site. Undeveloped lots are also located adjacent to the site to the west on W Mission Road and to the east across N Las Posas Road. Surrounding land uses outside of the immediately adjacent residential and commercial uses include designated industrial, commercial , single -family and multifamily residential, and schools/educational facilities. The closest freeway is State Route 78 located approximately 0. 4 mile south of the project site.

3.10.2 Regulatory Setting
This section provides an overview of the regulatory setting related to planning and land use that applies to the project, including federal, state, regional, and local regulation and planning documents.

Federal
There are no federal codes , policies, or regu lations regarding land use and planning that would apply to the proposed project.

State
California Planning and Zoning Law
The legal framework in which California cities and counties exercise local planning and land use functions is provided in the California Planning and Zoning Law, Government Code Sections 65000 et seq. Under state planning law, each city and county is required to adopt a general plan “for the physical development of the county or city, and any land outside its boundaries which bears rel ation to its planning” (Section 65300). The general plan expresses the community’s development goals and embodies public policy relative to the distribution of future land uses, both public and private. A general plan consists of several elements, including land use, circulation, housing, conservation, open space, noise, and safety; other elements may be included at the discretion of the jurisdiction that relate to the physical development of the county or city.

Local
San Diego Association of Governments ’ San Diego Forward: The Regional Plan The San Diego Association of Governments (SANDAG) is the federally designated metropolitan planning organization for the San Diego region. SANDAG serves as a forum for public decision making on regional issues such as growth, transportation, and land use in San Diego County and consists of representatives from each of the county’s local jurisdictions. SANDAG builds consensus, develops strategic plans, obtains and allocates resources, and provides information on a broad range of topics pertinent to the region’s quality of life.

The Regional Comprehensive Plan, adopted in 2004 by SANDAG, laid out key principles for managing the region’s growth while preserving natural resources and limiting urban sprawl. The plan covered eight policy areas, including urban form, transportation, housing, healthy environment, economic prosperity, public facilities, our borders, and social equity (SANDAG 2004).

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-3
In 2011, SANDAG approved the 2050 Regional Transportation Plan (RTP) and Sustainable Communities Strategy (SCS). This approval marked the first time SANDAG’s RTP included a n SCS, consistent with the Sustainable Communities and Climate Protection Act of 2008, also known as Senate Bill 375. This RTP/SCS provided a blueprint to im prove mobility, preserve open space, and create communities, all with transportation choices to reduce greenhouse gas emissions and meet specific targets set by the California Air Resources Board as required by Senate Bill 375 (SANDAG 2011) . In 2010, the California Air Resources Board established targets for each region in California governed by a metropolitan planning organization.

On December 10, 2021, the SANDAG Board of Directors adopted San Diego Forward: The Regional Plan (Regional Plan) (SANDAG 2021 ). The Regional Plan combines the two previously described existing regional planning documents: the Regional Comprehensive Plan and the RTP/SCS. The Regional Plan updates growth forecasts and is based on the most recent planning assumptions from currently adopted land use plans, including the City’s General Plan and other factors from the cities in the region and the county. SANDAG’s Regional Plan will change in response to the ongoing land use planning of the City and other jurisdictions. For example, the City’s General Plan, and other local cities’ general plans , may change based on General Plan Amendments (GPAs) initiated by jurisdictions or landowner applicants. The GPAs may result in increases in development densities due to amendments of the regional category designations or zoning classifications. Accordingly, SANDAG’s RTP/SCS forecasts of future development in the San Diego region, including location, must be coordinated closely with each jurisdiction’s ongoing land use planning because that planning is not static, as recognized by the need for updates to SANDAG’s RTP/SCS every 4 years.

San Diego Association of Governments ’ North County Multiple Habitat Conservation Program The North County Multiple Habitat Conservation Program (MHCP) is a comprehen sive conservation planning process that addresses the needs of multiple plant and animal species in northwestern San Diego County (SANDAG 2003). The MHCP encompasses the Cities of Carlsbad, Encinitas, Escondido, Oceanside, San Marcos, Solana Beach, and Vista. Its goal is to conserve approximately 19,000 acres of habitat, of which roughly 8,800 acres (46%) are already in public ownership and contribute toward the habitat preserve system for the protection of more than 80 rare, threatened, or endangered species.

The City began preparing the City of San Marcos Subarea Habitat Conservation Plan/Natural Community Conservation Plan (Draft San Marcos Subarea Plan) in May 2001. Although the Draft San Marcos Subarea Plan has not yet been approved by the U.S. Fish and Wildlife Service and California Department of Fish and Wildlife, the plan is a component of the adopted MHCP and is currently being used as a guide for open space design and preservation within the City (SANDAG 2001). The intent of the Draft San Marcos Subarea Plan is to identify a citywide preserve system that meets local and regional biological goals while minimizing fiscal and economic impacts to the City and adverse impacts on private property owners. To help achieve this goal, Focused Planning Areas have been designated with parcel-level preserve goals that would contribute to achieving local and regional conservation goals while minimizing adverse effects on property rights and property values. The project site is located within the northern Focused Planning Area within the MHCP planning area.

San Diego County Regional Airport Authority Land Use Compatibility Plan The nearest public airport is the McClellan-Palomar Airport, which is approximately 55 miles southwest of the project site. The McClellan-Palomar Airport Land Use Compatibility Plan contains policies to promote land use compatibility between the McClellan-Palomar Airport and adjacent and proximate land uses, to the extent these areas are not already developed with existing uses, and to protect the public health, safety, and welfare. Using airport -related

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-4
forecasts and background data approved by the California Department of Transportation, Division of Aeronautics, the plan reflects anticipated growth of the airport over a 20 -year horizon. The plan includes land use compatibility criteria and identifies policies applicable to the airport and surrounding land uses. The project site is not located within any of the McClellan-Palomar Airport Influence Areas (San Diego County Regional Airport Authority 2011).

City of San Marcos General Plan
The General Plan consists of the following elements:
▪ Land Use and Community Design Element – Describes the desired future physical composition of the planning area in terms of location, type, and intensity of new development and open space to ensure balanced development that maximizes the long-term livability of the San Marcos community. ▪ Mobility Element – Describes the mobility strategy for the City, which identifies a network of options including streets, sidewalks, trails, and transit that connect people with the City. ▪ Conservation and Open Space Element – Recognizes the habitat and scenic value of nat ural and cultural open spaces within the City and lists goals and policies that ensure long -term stewardship of these resources. This element also addresses climate change, water conservation, energy conservation, air quality, watersheds, and water quality.
▪ Parks, Recreation and Community Health Element – Identifies the recreational amenities and community service programs offered within the City and outlines goals for increased access to parks, trails, recreational facilities, and community service programs for all community members. ▪ Safety Element – Establishes policies and programs to protect public health, safety, and welfare of all residents and property. This element identifies and describes plans for response to natural and human - caused safety issues, including geologic, seismic, flood, and fire hazards. ▪ Noise Element – Identifies problematic noise sources within the City and outlines strategies to reduce overall ambient noise levels. This element also includes measures to strategically distribute land uses throughout the City.
▪ Housing Element – Describes the strategy for developing a variety of housing opportunities to accommodate all residents and preserve the quality of existing housing in order to promote safe, decent, and affordable housing within the 2021–2029 planning period. ▪ Environmental Justice Element – Highlights existing policies contained in other General Plan elements as they relate to environmental justice. This element is designed to promote a more equitable, safe, and healthy lifestyle for all residents and support the long-term needs of the community’s most vulnerable populations.

The following goals and policies from the City ’s Land Use and Community Design Element pertain to planning and are applicable to the project (City of San Marcos 2012a):

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 char acter elements, and access to various mobility choices.

Policy LU-1.3: Diversify land uses by providing mixed use land uses in strategic locations within the City that place housing adjacent to employment.

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-5
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-2.2: Encourage new development to be sited to respond to climatic conditions, such as solar orientation, wind, and shading patterns.

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 pla nts) that minimizes demands on water supply.

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

Goal LU-3: Develop land use patterns that are compatible with and support a variety of mobility opportunities and choices.

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

Policy LU-3.7: Require new development to prepare traffic demand management programs.

Policy LU -3.8: Require new development and discretionary actions to annex into a Congestion Management Community Facilities District.

Goal LU-5: Promote community design that produces a distinctive, high-quality built environment with forms and character that create memorable places and enrich community life.

Policy LU-5.3: Use public landscaping, banners, and signage along streets, sidewalks, property frontages, and in public spaces to strengthen the City’s identity and create a unique sense of place.

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

Policy LU-5.5: Encourage development of public spaces and plazas within commercial, mixed -use, and residential projects that include fire and water features that can accommodate civic events and function as community gathering areas.

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

Policy LU -5.7: Architecture shall be enhanced with high -end building materials, varied roof lines, and decorative details.

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-6
Goal LU-7: Direct and sustain growth and expansion in areas of San Marcos that can support a concentration of a variety of uses and are particularl y suitable for multimodal transportation and infrastructure expansion and improvements.

Policy LU -7.2: Coordinate pedestrian, transit and infrastructure upgrades with infill and redevelopment opportunities.

Goal LU-8: Ensure that existing and future development is adequately serviced by infrastructure and public services.

Policy LU -8.1: New development sha ll pay its fair share of required improvements to public facilities and services.

Policy LU-8.2: Promote development timing that is guided by the adequacy of existing and/or expandable infrastructure, services, and facilities.

Goal LU- 11.: Schools: Ensure all residents have access to high-quality education.

Policy LU 11.2: Work with San Marcos Unified School District and developers to ensure adequate school facilities are funded as required by State law and through developer mitigation agreements between the school district and the developer. The City shall require a “will serve” letter substantiating that the developer has paid fees to the satisfaction of the school district prior to issuance of building permits.

Goal LU-14: Wastewater: Ensure an adequate wastewater system for existing and future development.

Policy LU -14.2: Ensure development approval is directly tied to commitments for the construction or improvement of primary water, wastewater, and circulation systems.

Goal LU-17: Utilities and Communications: Encourage provision of power and communication systems that provide reliable, effective and efficient service for San Marcos.

Policy LU-17.2: Require all new development and redevelopment to provide the technology to support multiple telecommunica tions facilities and providers such as multi -media products, wireless technologies, and satellite communications.

Policy LU -17.4: Require utility location to be shown on all site development plans at the time of development/project application
The General Plan includes goals and policies applicable to other areas, such as mobility, safety, noise, and conservation. The project’s consistency with applicable General Plan goals and policies is presented in Section 3.10.4.

San Marcos Municipal Code a nd Zoning Ordinance , Title 20 The provisions of Title 20 of the San Marcos Municipal Code are referred to as the Zoning Ordinance. The Zoning Ordinance is based on the official Zoning Map of the City of San Marcos. The purpose of this Zoning Ordinance is to protect and promote the public health, safety, comfort, convenience, and general welfare of the San Marcos community; to implement the policies of the General Plan; and to provide the physical, environmental, economic, and social advantages that result from the orderly planned use of land resources.

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-7

3.10.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to land use and planning are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to land use and planning would occur if the project would:
▪ Threshold No. 1: Physically divide an established community. ▪ Threshold No. 2: Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

3.10.4 Project Impact Analysis
This section considers the impacts to land use and planning that would result from the project.

Threshold No. 1: Would the project physically divide an established community? The project site is currently undeveloped and surrounded by residential uses to the north, west, and east; industrial uses to the south; and commercial uses to the south and eas t. As described in Chapter 2 , Project Description, of this EIR, the project proposes development of 120 townhomes on approximately 7.6 acres. The project would also include 92,645 square feet of common recreation area, landscaping, bio-retention areas, and circulation improvements. The project would have a density of approximately 15.8 dwelling units per acre.

The adjacent CVS parcel includes 99 existing 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 existing parking spaces on the project site that would be shared between the project site and CVS. The City’s Parking Ordinance requires the project to introduce an additional 20 guest spaces to meet the City’s requirement for multifamily dwelling guest parking requirement of 1 space per 3 units. 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.

Additionally, the project proposes a GPA and Rezone to change the General Plan designation and Zoning from Commercial (C) to Specific Plan Area (SPA), to allow for the proposed townhome dwelling unit development and associated amenities.

Although development of the proposed residential land uses would be inconsistent with the neighboring commercial uses, the project site is located in an urban part of the City within close proximity to existing residential development.

Because the project site is surrounded on all sides by existing infrastructure, the project would not divide an established community, and therefore this impact would be less than significant.

Threshold No. 2: Would the project cause a significant environmental impact due to a conflict with any applicable land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? The project would conflict with the current General Plan and zoning designations for the site. However, a s described above and in Chapter 2 of this EIR, the project proposes a GPA and Rezone to change the General Plan designation and Zoning from Commercial (C) to Specific Plan Area (SPA) to allow for the proposed townhome

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-8
dwelling unit development and associated amenities. These requested project entitlements/discretionary actions by the City are further outlined below :
▪ Specific Plan - A Specific Plan would be required to provide a comprehensive plan to ensure the efficient development of a new residential community. The Specific Plan serves as both a policy document and a regulatory document for the systematic implementation of the policies and goals of the General Plan. ▪ General Plan Amendment – A GPA would be required to re -designate the project site from Commercial to Specific Plan Area.
▪ Rezone - A Rezone would be required to re -designate parcels 219-121-15-00 and 219 -121-16-00 from Commercial (C) to Specific Plan Area (SPA).
▪ Tentative Map – A Tentative Map will present specific lot configurations for the site. ▪ Multifamily Site Development Plan – A Site Development Plan will configure the site for townhome dwelling units, street configuration, infrastructure, and recreational open space.

Upon approval of the GPA/Rezone from Commercial (C) to Specific Plan Area (SPA), the project would be required to comply with the allowable residential uses outlined in the Specific Plan prepared for the project site (Appendix M).

Although the project would amend the land use designation, the concurrent process of amending the General Plan designation does not necessarily equate to consistency with the document. As such, a consistency analysis with the City’s General Plan goals are included in Table 3.10-2 below.

Table 3.10-2. General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy Conservation and Open Space Element
Goal COS-1: Identify, protect, and enhance
significant ecological and biological resources
within San Marcos and its adaptive Sphere
of Influence.

Consistent. Implementation of the project would result in potentially significant impacts to biological resources.

However, compliance with existing regulations and
implementation of MM-BIO-1 and MM-BIO-2 outlined in
Section 3.3, Biological Resources, would ensure that the project would not conflict with the MHCP or draft San
Marcos Subarea Plan, or other applicable regulations
related to biological resources.

Goal COS-2: The City is committed to conserving,
protecting, and maintaining open space,
agricultural, and limited resources for future
generations. By working with property owners,
local organizations, and state and federal
agencies, the City can limit the conversion of
resource lands to urban uses.

Consistent. The project site is currently vacant and zoned for Commercial uses. The project site is surrounded by
existing development and infrastructure and would not be considered open space. Implementation of the project
would not convert any designated open space or
agricultural uses.

Goal COS-3: Protect natural topography to
preserve and enhance the natural beauty of
San Marcos.

Consistent. The project site is currently vacant and zoned for Commercial uses. The project site is surrounded by
existing development and infrastructure. Development of the project site would not destroy the existing
characteristics of the surrounding area as described in Section 3.1, Aesthetics, of this EIR.

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-9
Table 3.10-2. General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy Goal COS-4: Improve regional air quality and
reduce greenhouse gas emissions that contribute
to climate change.

Consistent. The project would result in fewer greenhouse gas emissions than the existing zoning, and the project would be required to implement all applicable checklist items within the City’s 2020 Climate Action Plan.

Goal COS-6: Protect and restore appropriate
surface water and groundwater beneficial uses
through prioritizing the improvement of locally
impaired water bodies within the City of
San Marcos subwatersheds.

Consistent. The project would be required to comply with the NPDES State Water Resources Control Board
Construction General Permit Order No. 2009-0009-DWQ
for stormwater discharges and general construction
activities, and would incorporate standard BMPs, such as regular cleaning or sweeping of construction areas and
impervious areas, and various stormwater BMPs, such as
filtration media screens. In compliance with the
Construction General Permit, a SWPPP will be prepared
for the project that would specify BMPs that would be
implemented during construction to minimize impacts to
water quality. Lastly, project implementation of
biofiltration, source control, and site design BMPs would effectively treat post-construction stormwater runoff prior to discharge from the site in compliance with the
requirements of the BMP Design Manual and BMPs
outlined in the SWQMP.

Goal COS-7: Achieve sustainable watershed
protection for surface and ground water quality
that balances social, economical, and
environmental needs.

Consistent. Please refer to the consistency response to Goal COS-6. Implementation of the project would not
conflict with the goal to achieve sustainable watershed protection for surface and ground water quality.

Goal COS-8: Focus watershed protection, surface
and groundwater quality management on sources
and practices that the City has the ability to affect.

Consistent. Storm drainage components recommended by
the Preliminary Drainage Study (Appendix G) would
properly handle runoff from the project site to meet
regulatory requirements and to ensure that post-
development runoff would occur at rates that are similar to, or less than, pre-development conditions. Appropriate design of on- and off-site drainage facilities,
implementation of a SWPPP, SWQMP, and BMPs, and
implementation of all recommendations from the
Preliminary Drainage Study and development-specific
drainage plans would ensure the project would not
substantially alter the drainage patterns on or off site or result in substantial polluted runoff.

Goal COS-11: Continue to identify and evaluate
cultural, historic, archeological, paleontological,
and architectural resources for protection from
demolition and inappropriate actions.

Consistent. A Cultural Resources Report was prepared for the project site to ensure existing resources are protected (Appendix D). Implementation of the project would not
impact any identified archaeological resources, historical resources, or any known human remains interred outside
a formal cemetery. However, based upon the analysis
presented in Section 3.4, Cultural Resources, the
potential exists for impacts to unknown cultural resources resulting from project construction.

These potentially significant impacts to archaeological resources and human remains would be mitigated to below

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-10
Table 3.10-2. General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy a level of significance through implementation of MM-CR-1 through MM-CR-4. Specifically, implementation of MM-CR-1 through MM-CR-4 provide for the presence of
archaeological and Native American monitors during
ground disturbing activities that would be able to identify any previously unidentified cultural resources and to
prevent inadvertent disturbance of any intact cultural
deposits that may be present. Should any resources be
identified, implementation of MM-CR-1 through MM-CR-4
would ensure proper handling and treatment of such
resources by providing for a proper evaluation to determine whether additional archaeological work is necessary.

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.

Consistent. The project is a previously graded and
disturbed site surrounded by existing development. While the project land use designation would not mirror
immediately adjacent industrial and commercial land uses to the south, it would be consistent with the residential uses located directly to the north of the project site. The project would include the development of townhomes,
which would provide a transition between the high-density residential development south of the project site and the low-density single-family residences to the north.

The project would be consistent with the goal to achieve a balanced distribution and compatible mix of land uses to meet the present and future needs of the City.

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

Consistent. Implementation of the project would
implement the overarching goals of the City’s General
Plan, through various proposed features and components
such as providing housing near transit and existing
commercial and industrial uses; providing diverse and
higher-density housing; designating opportunities for
recreational and open space areas; and supporting
vehicular, bicycle, and pedestrian modes of travel.

Goal LU-3: Develop land use patterns that are
compatible with and support a variety of mobility
opportunities and choices.

Consistent. NCTD operates the Palomar College SPRINTER
Station located approximately 0.35 miles from the project’s W Mission Road entrance. Additionally, multiple Breeze
transit stations are located within close proximity to the project site; the closest is approximately 150 feet from the project entrance. The project would also be located within walking and biking distance from retail, school, park and other facilities. The project would therefore support a variety of mobility opportunities and would promote
multimodal transportation, consistent with General Plan Land Use Element Goals LU-2, LU-3, and LU-7. The project would be designed to ensure aesthetic consistency with the surrounding area and compliance with General Plan Land
Use Element Goal LU-5. Consistent with Goal LU-8, the
project would be required to pay its fair share public facility

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-11
Table 3.10-2. General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy fees and other development impact fees consistent with
the City’s Municipal Code (refer to Sections 3.13, 3.14,

3.15, and 3.17 for a discussion of potential impacts to public infrastructure and facilities and required
development fees).

Goal LU-5: Promote community design that
produces a distinctive, high-quality built
environment with forms and character that create
memorable places and enrich community life.

Consistent. All final project plans, including project
elevations as shown in Figures 3.1-1A through 3.1-1D,
would be reviewed by the City and would be expected to
create a cohesive character with the surrounding
environment. The project would follow the architectural and landscape design guidelines to create memorable
places within the City.

Goal LU-6: Maintain a supportive business climate
and a healthy, sustainable economy to retain and
attract high quality businesses and
create additional employment opportunities.

Inconsistent. The project would develop residential uses at a site that is currently undeveloped and zoned for
commercial uses. The residential development as part of the project would take away the opportunity for
commercial development in proximity to existing industrial and commercial development.

Goal LU-7: Direct and sustain growth and
expansion in areas of San Marcos that can
support a concentration of a variety of uses and
are particularly suitable for multimodal
transportation and infrastructure expansion
and improvements.

Consistent. The project would promote sustainability
through locating residential uses on an underutilized
vacant site proximate to existing schools, markets, parks, transit, and shopping centers. Vehicle miles traveled
would be reduced by sustainably locating residential uses in this vacant area. Infrastructure and services plans are provided with the Gran Vista Specific Plan (Appendix M).

As discussed in Section 3.17 of this EIR, Public Utilities and Service Systems, impacts to utility and service
systems were determined to be less than significant.

Goal LU-8: Ensure that existing and future
development is adequately serviced by
infrastructure and public services.

Consistent. As discussed in Section 3.13, Public Services, of this EIR, the project would be adequately served by
San Marcos Fire Department, San Marcos Sheriff’s
Department, and SMUSD. Additionally, as discussed in
Section 3.17, impacts to utility and service systems were determined to be less than significant.

Goal LU-11: Schools: Ensure all residents have
access to high-quality education.

Consistent. As discussed in Section 3.13 of this EIR, the project would generate approximately 28 elementary
school students, 12 middle school students, and 15 high school students. Prior to project approval, the project would be required to obtain will-serve letters from SMUSD or
servicing schools to confirm such schools have adequate capacity. 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 the City’s Municipal Code Section 17.52.050. As concluded in Section 3.13, the project would have less than significant impacts on schools.

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-12
Table 3.10-2. General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy Goal LU-14: Wastewater: Ensure an adequate
wastewater system for existing and future
development.

Consistent. Implementation of the project would require the construction of private on-site sewer lines connecting to the public system at two locations. The connections to the
existing system will depend on on-site grading and utility design. The City requires that VWD provide a letter of Sewer Availability for proposed developments within VWD. Prior to issuing such a letter, VWD will conduct a sewer study for the project to determine whether the current infrastructure is sufficient to accommodate the development project, and/or to provide recommendations for capital improvements to
provide service. A Water and Sewer Study was prepared in March 2022 (Appendix L) and is further discussed in
Section 3.17. As concluded in Section 3.17, impacts to
wastewater facilities would be less than significant.

Goal LU-17: Utilities and Communications:

Encourage provision of power and communication
systems that provide reliable, effective and
efficient service for San Marcos.

Consistent. Communications systems for telephones,
computers, and cable television are serviced by utility providers such as AT&T, Cox, Spectrum, and other
independent cable companies. No specific systems
upgrades are proposed.

Mobility Element
Goal M-1: Provide a comprehensive multimodal
circulation system that serves the City land uses
and provides for the safe and effective movement
of people and goods.

Consistent. The project would promote sustainability
through locating residential uses on an underutilized vacant site proximate to existing schools, markets, parks, transit, and shopping centers. Vehicle miles traveled would be
reduced by sustainably locating residential uses on a
vacant site within this developed area. As discussed in Section 3.15, Transportation, roadways and intersection with the project study area would operate at LOS D or
better. In addition, the project would be required to comply with Title 24 requirements and would include amenities
such as electric vehicle charging stations, electric or solar water heaters, reduced landscaping water use, and trees.

Goal M-2: Protect neighborhoods by improving
safety for all modes of travel and calming traffic
where appropriate.

Consistent. The project would be required to provide a
proposed circulation plan outlining safe movement within the project site, including emergency access, subject to review by the City and the San Marcos Fire Department. The conceptual site plan for the project is provided as Figure 2-1. All final project plans would be subject to review and approval by the City. Under existing conditions, on-street parking is prohibited on N Las Posas Road and W Mission Road.

The internal circulation network for the project would not include any hazardous design features or incompatible uses.

The project would include circulation amenities and
improvements such as an interconnected mobility system for bicycles, pedestrians, and vehicles in order to provide residents with safe movement within the project site;
connections to existing roadways within the within the vicinity of the project site; and access to regional arterial and highway networks and SPRINTER/Breeze transit services.

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-13
Table 3.10-2. General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy Goal M-3: Promote and encourage use of
alternative transportation modes, including
transit, bicycles, neighborhood electric vehicles
(NEVs), and walking, within the City.

Consistent. NCTD provides public transportation within the City and the County of San Diego for Coaster rail service, SPRINTER light rail service, and Breeze bus service. The NCTD operates the Palomar College Station SPRINTER
and Breeze transit station located approximately 0.3 miles from the project’s W Mission Road entrance. The project would be required to comply with Title 24 requirements, would include amenities such as electric vehicle charging stations, and would implement a Transportation Demand
Management Plan.

Parks, Recreation, and Community Health Element
Goal PR-1: Plan for, acquire, develop, and
maintain a system of local parks connected
through an integrated network of trails and high
quality recreational facilities.

Consistent. As shown in Figure 2-1, the project proposes 108,200 square feet of recreation area on site for
residents, which would provide for private open
space/passive recreational use for residents on site.

Additionally, the project applicant/developer would be
required to pay the City’s Public Facilities Fees. Developer payment towards the City’s Public Facilities Fees would go towards the acquisition and development of local and
community park facilities throughout the City to offset the demand on public park space.

Safety Element
Goal S-1: Reduce risks to the community from
earthquakes by regulating new development and
redevelopment to prevent the creation of new
geologic and seismic hazards.

Consistent. There are no known active faults that run
through the project site. The project would be designed in accordance with applicable California Building Code
requirements, including for resistance to seismic shaking.

Furthermore, the project would be constructed in
accordance with other applicable regulations, the current seismic design specifications of the Structural Engineers Association of California, and all applicable requirements of the California Occupational Safety and Health
Administration. These required seismic design
considerations are used to minimize structural damage in the event of ground shaking.

Additionally, the project would implement all
recommendations per the Preliminary Geotechnical
Evaluation (Appendix E), as well as any project-specific recommendations with any potential supplemental
geotechnical evaluations, in compliance with
Section 17.32.040(f) of the City’s Municipal Code.

Goal S-2: Minimize the risk to people, property,
and the environment due to flooding hazards.

Consistent. Despite a small portion of the project site being located in a 100-year flood hazard area, the base flood elevation at the portion of the site that is within the 100-year flood hazard area would not reach to the top of the slope. As determined in Section 3.9, Hydrology and
Water Quality, risk related to flooding hazards would be less than significant.

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-14
Table 3.10-2. General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy Goal S-3: Minimize injury, loss of life, and damage
to property results from structure or wildland
fire hazards.

Consistent. The project site is not located in any fire hazard severity zone (CAL FIRE 2021, but the project is located approximately 0.25 miles from a VHFHSZ in a
local responsibility area. The existing project site is an undeveloped lot that is relatively flat and shows signs of previous disturbance. The proposed redesignation of the project site from commercial uses to residential uses
under the proposed Specific Plan would likely reduce the potential for wildfire hazards on site through the
replacement of flammable vegetation currently on site
with structures that are up to current fire code. The project would not include associated infrastructure that may
exacerbate fire risk. Additionally, the project would be required to comply with all applicable state and local fire codes, including the California Fire Code and the
San Marcos Fire Department, which require a design that affords fire and emergency responders suitable fire
access roads dimensions and surfaces (Chapter 5,
Sections 503.1 through 503.4 of the California Fire Code), as well as an adequate number of emergency rated
entrances to the community (Appendix D, Section D106 of the California Fire Code).

Goal S-4: Protect life, structures, and the
environment from the harmful effects of
hazardous materials and waste.

Consistent. Construction of the project would entail
transport, use, or disposal of potentially hazardous materials including, but not limited to diesel fuel, gasoline, equipment fluids, concrete, cleaning solutions and solvents, lubricant oils, adhesives, human waste, and chemical toilets. The project would be required to comply with all standards
required through federal, state, county, and municipal
regulations, in addition to project-specific plan review by the City, which would ensure potential impacts related to
hazardous materials would not be significant. Furthermore, hazards associated with development and operation of
residential developments would likely be less than that associated with commercial development, which is the
current designated land use for the project site.

Proposed uses would be limited to multifamily residences and residential amenities, which do not typically generate, release, or use large amounts of hazardous materials.

During operations of the project, the only hazardous
materials anticipated for transport, use, or disposal are routinely used household products such as cleaners,
paint, solvents, motor oil/automotive products, batteries, and garden maintenance products. The use, handling, and disposal of these products are addressed by household
hazardous waste programs that are part of the Integrated Watershed Monitoring Program of the County of San
Diego, and therefore the project is not expected to create a significant hazard to the public or environment through hazardous upsets or accidents.

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-15
Table 3.10-2. General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy Goal S-5: Establish and maintain an effective
emergency response program to respond to
disasters and maintain continuity-of-life support
functions during an emergency.

Consistent. According to the General Plan Safety Element, the San Marcos Emergency Operations Plan governs the
operations of the City during a disaster. This plan
addresses response to moderate evacuation scenarios,
including the identification of evacuation points and
general routes (City of San Marcos 2012b). The project
would be required to abide by standards as set forth in the San Marcos Emergency Operations Plan. The project
would not impact any roadway or staging areas that are
identified in any emergency planning documents and
would not impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan.

Goal S-6: Provide neighborhood safety through
effective law enforcement.

Consistent. Implementation of the project would be
expected to increase the frequency of emergency and
non-emergency calls to the Sherriff’s Department.

However, over 100 deputies, volunteers, and professional staff serve the residents of the City. Law enforcement
services include general patrol, criminal investigation, crime prevention, juvenile services, narcotics and gang investigations, communications and dispatch, and various management support services. Police units are
continuously mobile and service calls are responded to by the nearest available mobile unit. At the San Marcos
Station, patrol deputies are assigned to a geographical “beat” area, allowing deputies to become familiar with
citizens and problems within their “beats” (SDCSD 2022).

Accordingly, service ratios and response times are
anticipated to remain adequate with development of the
project. As such, the project is not expected to affect police protection such that new or physically altered
governmental facilities are needed.

Goal S-7: Comply with the McClellan-Palomar
Airport Land Use Compatibility Plan.

Consistent. The project site is not located within any of the McClellan-Palomar Airport Influence Areas and would not conflict with the McClellan-Palomar Airport Land Use
Compatibility Plan.

Noise Element
Goal N-1: Promote a pattern of land uses
compatible with current and future noise levels.

Consistent. The project site is surrounded by commercial and industrial uses to the south and residential uses to the east and west. The project site is located in an urban setting and is surrounded by existing development.

Surrounding land uses outside of the immediately
adjacent industrial and commercial land uses include
industrial uses, commercial uses, mixed-use development, single-family residential, and schools/educational
facilities. Noise generated by the project would be similar to that of existing land uses in the vicinity.

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-16
Table 3.10-2. General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy Goal N-2: Control transportation-related noise
from traffic, rail, and aviation sources near noise
sensitive land uses.

Consistent. As described in Section 3.11, Noise, of this EIR, the addition of traffic to the roadway network as a result of the project would result in a CNEL increase of less than 3 dB, which is below the discernible level of change for the average healthy human ear. Therefore, a
less than significant impact would occur related to
operational traffic noise. Furthermore, the project would meet the City’s and California Building Code’s requirement to reduce interior ambient noise levels to 45 dB CNEL
within habitable rooms of new residential development.

The project would not conflict with this City regulation or General Plan policy for purposes of evaluating the
project’s land use/planning impacts.

Goal N-3: Control non-transportation-related noise
from commercial, industrial, construction, and
other sources on noise sensitive land uses.

Consistent. Potential noise impacts during construction would be less than significant with implementation of
recommended design features. Noise impacts due to
operation of the project would be less than significant and no further mitigation is required. Further, the project would comply with the General Plan’s 45 dBA interior
noise standard.

Housing Element
Goal H-1: Provide a broad range of housing
opportunities with emphasis on providing housing
which meets the special needs of the community.

Consistent. Implementation of the project would change
the site’s land use designation and zoning from
Commercial to Specific Plan Area, allowing for
development of the proposed 120 residential units and
associated amenities on a vacant site with existing roads, alternative transportation and utilities in the immediate area. Additionally, the project proposes a townhome
development, which is a housing type that is limited in proximity to the project site.

Goal H-2: Protect, encourage, and provide housing
opportunities for persons of lower and
moderate incomes.

Consistent. The project would change the land use and
zoning designations at the project site to allow for
townhome residential development under the proposed
Specific Plan. Approval of the proposed GPA/Rezone could help the City address the substantial population growth within the City, and the need for housing. The project
would provide above moderate income housing
opportunities through project implementation. The project would not include any extremely low, very low, low, or
moderate income households, but would pay the in-lieu
fee that contributes to providing housing opportunities for target households in the City.

Note: MM = Mitigation Measure; MHCP = multiple habitat conservation program; EIR = environmental impact report; NPDES = National Pollution Discharge Elimination System ; BMP = best management practice; SWPPP = stormwater pollution prevention plan ; SWQMP = stormwater quality management plan; NCTD = North County Transit District; SMUSD = San Marcos Unified School District; VWD = Vallecitos Water District; LOS = level of service; VHFHSZ = very high fire hazard severity zone; CNEL = community noise equivalent level; dB = decibels; dBA = A-weighted decibels; GPA = General Plan Amendment.

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-17
As shown in Table 3.10-2, the project would not result in a significant environmental impact due to a conflict with the City’s General Plan Land Use Element goals. Land Use Element goals not referenced above, including LU -4, LU-5, LU-6, LU -9 through LU -13, LU-15, and LU -16 are not relevant to this discussion as they do not apply to individual projects or mitigating environmental effects. I nstead, these goals pertain to overall goals of the City related to education, business, and provision of community facilities and infrastructure. Project implementation would not impede the City’s ability to achieve these goals. 2050 Regional Transportation Plan/Sustainable Communities Strategy SANDAG’s 2050 RTP/SCS outlines projects for rail and bus services, highways, local streets, bicycling and walking, movement of goods, and systems and demand management. The 2050 RTP/SCS presents a transportation system designed to maximize transit enhancements, integrate biking and walking elements, and promote program s to reduce demand and increase efficiency. As described in Section 3.15, Transportation, of this EIR, the project would provide for residential land uses in an area that is surrounded by existing development, taking advantage of the site’s location near transit, retail, employment, schools, parks, and other uses. The project would be consistent with programs, plans, ordinances , and policies addressing the circulation system, including transit, roadway, bicycle , and pedestrian facilities. However, for the CEQA transportation vehicle miles traveled (VMT) analysis, the SANDAG Series 14 Base Year 201 6 regional travel demand model was used to calculate the project’s VMT per resident.

Based on the results, the project’s VMT per resident is more than 85% of the regional average, at 90% of the regional average.

Although the project would not be consistent with the existing zoning and land use designations and the project would exceed the VMT threshold , the project would generate fewer greenhouse gas emissions at buildout than potential development permitted under the existing land use designation. Thus, the project would not increase land use intensities as provided in the RTP/SCS and would therefore not result in envir onmental impacts due to inconsistency with this plan.

North County Multiple Habitat Conservation Program
As described under Section 3.10.2, the MHCP is a comprehensive conservation planning process that addresses the needs of multiple plant and animal species in northwestern San Diego County (SANDAG 2003). The project site is generally located within the boundaries of the MHCP Plan (Appendix C), and specifically within the Draft San Marcos Subarea Plan area. The Draft San Marcos Subarea Plan has not been completed, approved, or adopted (SANDAG 2001). However, it is the City’s General Plan policy to comply with the conservation policies identified in the MHCP through use of the Draft San Marcos Subarea Plan as an implementation tool.

As described throughout Section 3.3, Biological Resources , of this EI R, project implementation would result in potentially significant impacts to biological resources. However, compliance with existing regulations and implementation of Mitigation Measure (MM) BIO-1 and MM-BIO-2 outlined in Section 3.3.7 would ensure that th e project would not conflict with the MHCP, draft San Marcos Subarea Plan, or other applicable regulations related to biological resources. Implementation of proposed mitigation and City review of development plans for the project site would ensure impacts to biological resources would be less than significant. Furthermore, the project would be consistent with the Conservation and Open Space Element goals of the City’s General Plan.

3.10 – LAND USE AND PLANNING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.10-18
San Marcos Municipal Code Zoning Ordinance , Title 20
As described above, a rezone would be required to re -designate the project site from Commercial (C) to Specific Plan Area (SPA). Approval of the proposed GPA/Rezone would allow for development of the project site with the proposed residential land use s and associated amenities and improvements . Although the project would amend the land use designation to Specific Plan Area (SPA), the concurrent process of amending the Zoning designation does not necessarily equate to consistency with the Zoning Ordinance. However, as s hown in Table 3.10 -2, the project would be consistent with majority of the City’s General Plan goals that guide development within the City.

Therefore, the proposed rezoning of the site would be consistent with the City’s Zoning Ordinance.

Based on the considerations outlined above, the project would not conflict with an applicable land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Therefore, project impacts related to land use and planning would be less than significant.

3.10.5 Cumulative Impact Analysis
As described in Section 3.10.4, while the project seeks approval of a GPA and Rezone of the project site, the project would be consistent with the overarching goals of the City’s General Plan. In addition to the City’s General Plan, the project would also be consistent with the City’s Municipal Code, SANDAG’s 2050 RTP/SCS, and applicable plans and policies described in the regulatory setting sections throughout Chapter 3. Furthermore, as analyzed throughout Chapter 3, implementation of the project would not result in any significant unavoidable impacts that could further impact land use.

All cumulative projects would be s ubject to similar criteria as the project, which would ensure compliance with existing applicable land use plans with jurisdiction over the project area. Any cumulative projects that propose amendments to the General Plan or Zoning Ordinance would be requi red to show that proposed uses would not result in significant environmental impacts due to a conflict with applicable policies in a similar way as the project.

Since all current and future projects would be analyzed for compatibility and compliance with land use regulations prior to approval, cumulative impacts related to land use and planning would be less than significant.

3.10.6 Mitigation Measures
No mitigation specific to land use and planning would be required as a result of the project. However, the project would be required to incorporate mitigation measures proposed throughout Chapter 3 of this EIR to ensure project implementation would not result in significant land use impacts.

3.10.7 Conclusion
Based upon the analysis presented in Sections 3.10.4 and 3.10.5, development of the proposed 120 residential units, upon approval of the proposed GPA/Rezone of the project site from Commercial (C) to Specific Plan Area (SPA), would not result in significant impacts to land use and planning. The project would be required to incorporate technical report recommendations, design features , and mitigation measures identified throughout Chapter 3 of this EIR to ensure project implementation would not result in significant impacts or inconsistency with applicable land use plans and policies. The project would be consistent with the applicable goals and policies of the City’s General Plan. As analyzed throughout Chapter 3 of this EIR, implement ation of the project would not result in any significant unavoidable impacts, and all potentially significant impacts to biological resources, cultural resources, geology and soils, and tribal cultural resources would be reduced to a level of less -than-significant with mitigation incorporated. Furthermore, final project plans would be subject to City review and approval . For these reasons, impacts related to land use and planning would be less than significant.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-1

3.11 Noise
This section discusses the existing noise and vibration setting of the proposed Gran Vista Specific Plan Project (project), identifies associated regulatory requirements, and evaluates potential impacts related to implementation of the proposed project. This section is based on the Noise Technical Report prepared for the proposed project by Dudek in February 2023, which is included as Appendix I to this environmental impact report (EIR).

Table 3.11-1 summarizes the project- and cumulative-level noise impact analysis for the proposed project.

Table 3.11-1. Noise Summary of Impacts
Threshold of Significance
Project
Direct
Impact
Project
Cumulative
Impact
Significance
Determination
No. 1: Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

Less Than
Significant
Less than
Significant
Less Than
Significant
No. 2: Generation of excessive groundborne vibration or groundborne noise levels.

Less Than
Significant
Less than
Significant
Less Than
Significant
No. 3: Exposure of people residing or working in the project area to excessive noise levels, for a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport.

Less Than
Significant
Less Than
Significant
Less Than
Significant

3.11.1 Existing Conditions
This section provides background on noise characteristics and vibration fundamentals, as well as a description of the existing noise environment associated with the project site and the surrounding area.

Noise Characteristics
Sound is mechanical energy transmitted by pressure waves in a compressible medium, such as air. Noise is defined as sound that is loud, unpleasant, unexpected, or undesired. Sound pressure level (SPL) has become the most common descriptor used to characterize the loudness of an ambient sound level. The unit of measurement of sound pressure is a decibel (dB). The average healthy ea r can barely perceive noise level changes of 3 dB , a change of 5 dB is readily perceptible, and a change of 10 dB is perceived as twice or half as loud (Caltrans 2013). A doubling of sound energy results in a 3 dB increase in sound, which means that a doub ling of sound energy (e.g., doubling the number of daily trips along a given road) would result in a barely perceptible change in sound level.

Sound may be described in terms of level or amplitude (measured in dB), frequency or pitch (measured in hertz or cycles per second), and duration (measured in seconds or minutes). Because the human ear is not equally sensitive to sound at all frequencies, a special frequency-dependent rating scale is used to relate noise to human sensitivity.

The A -weighted decibel ( dBA) scale performs this compensation by discriminating against low and very high frequencies in a manner approximating the sensitivity of the human ear.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-2
Several descriptors of noise ( i.e., noise metrics) exist to help predict average community reactions to the adverse effects of environmental noise, including traffic -generated noise. These descriptors include the equivalent noise level over a given period (L eq), the day–night average noise level (L dn), and the community noise equivalent level (CNEL). Each of these descriptors uses units of dBA.

Leq is a decibel quantity that represents the constant or energy-averaged value equivalent to the amount of variable sound energy received by a receptor during a time interval. For example, a 1 -hour L eq measurement of 60 dBA would represent the average amount of energy contained in all the noise that occurred in that hour. L eq is an effective noise descriptor because of its ability to assess the total time -varying effects of noise on sensitive receptors, which can then be compared to an established Leq standard or threshold of the same duration. Another descriptor is maximum sound level, which is the greatest sound level measured during a designated time interval or event. The minimum sound level is often called the “floor” of a measurement period.

Ldn and CNEL descriptors represent 24-hour periods and differ from a 24-hour Leq value because they apply a time- weighted factor designed to emphasize noise events that occur during the non-daytime hours (when speech and sleep disturbance is of more concern). “Time weighted” refers to the fact that Ldn and CNEL penalize noise that occurs during certain sensitive periods. In the case of CNEL, noise occurring during the daytime (7:00 a.m. to 7:00 p.m.) receives no penalty, but noise during the evening (7:00 p.m. to 10:00 p.m.) is penalized by adding 5 dB to the actual levels, and nighttime (10:00 p.m. to 7:00 a.m.) noise is penalized by adding 10 dB to the actual levels. Ldn differs from CNEL in that the daytime period is longer (defined instead as 7:00 a.m. to 10:00 p.m.), thus eliminating the dB adjustment for the evening period. Ldn and CNEL are the predominant criteria used to measure roadway noise affecting residential receptors. These two metrics generally differ from one another by no more than 0.5–1.0 dB and are often considered or actually defined as being essentially equivalent by many jurisdictions (Appendix I).

Vibration Fundamentals
Groundborne vibration is fluctuating or oscillatory motion transmitted through the ground mass (i.e., soils, clays, and rock strata). The strength of groundborne vibration attenuates rapidly over distance. Some soil types transmit vibration quite efficiently; other types (primarily sandy soils) do not. Several basic measurement units are commonly used to describe the intensity of ground vibration. The descriptors used by the Federal Transit Administration (FTA) are peak particle velocity (PPV), in units of inches per second (ips), and velocity decibel, which is based on the root- mean square of the vibration signal magnitude (Appendix I).

Existing Noise Environment
The project site is currently vacant and does not currently contain any sources of noise or vibration generation.

However, the project site is located in an urbanized area surrounded by development, bordered by existing roadways and industrial and commercial uses. Sources of noise in the surrounding area primarily include traffic from the local roadways, including W Mission Road and N Las Posas Road.

SPL measurements were conducted near the project site on April 26, 2022, to quantify and characterize the existing outdoor ambient sound levels. Table 3 .11-2 provides the location, date, and time period at which these baseline noise level measurements were performed by an attending Dudek field investigator using a Rion -branded Model NL-52 sound level meter equipped with a 0.5-inch, pre-polarized condenser microphone with pre-amplifier.

The sound level meter meets the current American National Standards Institute standard for a Type 1 (Precision Grade) sound level meter. The accuracy of the sound level meter was verified using a field calibrator before and after the measurements, and the measurements were conducted with the microphone positioned approximately 5 feet above the ground.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-3
Four short -term noise level measurement locations (ST1 –ST4) that represent existin g noise -sensitive receivers were selected on and near the project site. These locations are depicted as receivers ST1 –ST4 on Figure 3.11-1, Noise Measurement Locations. The measured L eq and maximum noise levels are provided in Table 3. 11-2. The primary noise sources at the site consisted of traffic along adjacent roadways, the sounds of leaves rustling, and birdsong. As shown in Table 3 .11-2, the measured SPL ranged from approximately 47.3 dBA L eq at ST4 to

64.2 Dba Leq at ST1. Detailed noise measurement data are included as part of Appendix I to this EIR.

Table 3.11-2. Measured Baseline Outdoor Ambient Noise Levels Site Location/Address Date/Time Leq Lmax
ST1 Southwest in CVS parking lot 2022-04-26, 04:00 p.m. to 04:10 p.m. 64.2 73.6 ST2 Northern boundary of CVS parking lot 2022-04-26, 04:20 p.m. to 04:30 p.m. 63.5 74.5 ST3 In dirt lot west of project site at 1333
Granite Road, San Marcos CA, 92069,
east of N Las Posas Road
2022-04-26, 04:40 p.m. to 04:50 p.m. 60.2 68.5
ST4 Front yard of 389 Palmac Street,
San Marcos, CA 92069
2022-04-26, 05:00 p.m. to 05:10 p.m. 47.3 74.9
Source: Appendix A of Appendix I.

Notes: Leq = equivalent continuous sound level (time -averaged sound level); L max = maximum sound level during the measurement interval; dBA = A-weighted decibels.

Generally, the measured samples of daytime L eq agree with expectations: ST1, ST2, and ST3 L eq values are above 60 dBA, due largely to proximity to W Mission Boulevard and/or N Las Posas Road, which are major roadways; ST4 however, is behind residential walls west of the western boundary of the project site and more distant from these sources of roadway traffic noise, which results in a substantially lower sampled Leq value.

Sensitive Receptors
Sensitive receptors are uses that are typically considered noise sensitive and include residences, schools, hospitals, parks, and wildlife habitats. The nearest sensitive receptors to the project site would be the residential uses located along Palmac Street located adjacent to the project site to the west and single-family residential uses located across from the site on the eastern side of N Las Posas Road.

3.11.2 Regulatory Setting
Federal
Federal Transit Administration
In its Transit Noise and Vibration Impact Assessment guidance manual, FTA recommends a daytime construction noise level threshold of 80 dBA Leq over an 8-hour period (FTA 2018) when detailed construction noise assessments are performed to evaluate potential impacts to community residences surrounding a project. Altho ugh this FTA guidance is not a regulation, it can serve as a quantified standard in the absence of such limits at the state and local jurisdictional levels.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-4
State
California Code of Regulations, Title 24
Title 24 of the California Code of Regulations sets standards that new development in California must meet.

According to Title 24, interior noise levels are not to exceed 45 dBA CNEL in any habitable room, as demonstrated by a project-specific acoustical analysis.

California Department of Health Services G uidelines
The California Department of Health Services has developed guidelines of community noise acceptability for use by local agencies (OPR 2017). Selected relevant levels are listed here:
▪ Below 60 dBA CNEL: normally acceptable for low-density residential use ▪ 50 to 70 dBA: conditionally acceptable for low-density residential use ▪ Below 65 dBA CNEL: normally acceptable for high-density residential use and transient lodging ▪ 60 to 70 dBA CNEL: conditionally acceptable for high -density residential, transient lodging, places of worship, educational facilities, and medical facilities California Department of Transportation
In its Transportation and Construction Vibration Guidance Manual (Caltrans 2020), the California Department of Transportation (Caltrans) recommends 0.5 ips PPV as a threshold for the avoidance of structural damage risk to typical newer residential buildings exposed to continuous or frequent intermittent sources of groundborne vibration.

For transient vibration events, such as blasting, the dam age risk threshold would be 1.0 ips PPV (Caltrans 2020) at the same type of newer residential structures. For older structures, these guidance thresholds would be more stringent: 0.3 ips PPV for continuous/intermittent vibration sources, and 0.5 ips PPV for transient vibration events.

With respect to human annoyance, Caltrans guidance indicates that building occupants exposed to groundborne vibration of 0.2 ips PPV from continuous or frequently intermittent sources may find it “ annoying” (Caltrans 2020) and on such basis this would be considered a significant groundborne vibration impact for purposes of this assessment. Although these Caltrans guidance thresholds are not regulations, they can serve as quantified standards in the absence of such limits at the local jurisdictional level.

Local
City of San Marcos Municipal Code
San Marcos Municipal Code Chapter 10.24.020.b.9 addresses construction activity, with exemption from chapter provisions between 7:00 a.m. and 6:00 p.m. Monday through Friday and on Saturdays from 8:00 a.m. to 5:00 p.m.

The Municipal Codes does not set noise limits on construction activities; however, on occasion the City of San Marcos (City) has adopted the County of San Diego’s Noise Ordinance noise limit of 75 dBA Leq (8-hour average) attributed to construction activities as received by an occupied property.

Chapter 20.300 , Site Planning and General Development Standards , of the Municipal Code includes noise regulations in the form of noise standards by zone (Section 20.300.070, Performance Standards). Municipal Code noise standards typically pertain to stationary (i.e., non-transportation-related) noise sources. The relevant portions of these noise standards are outlined in Table 3.11-3.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-5
Table 3.11-3. Exterior Noise Standards by Zone
Zone
Allowable Noise Level (dBA L eq) Measured
from the Property Line
Single -Family Residential (A, R -1, R -2) 1,2
7:00 a.m. to 10:00 p.m. (daytime) 60
10:00 p.m. to 7:00 a.m. (overnight) 50
Multifamily Residential (R -3) 1,2
7:00 a.m. to 10:00 p.m. (daytime) 65
10:00 p.m. to 7:00 a.m. (overnight) 55
Commercial (C, O -P, SR) 3
7:00 a.m. to 10:00 p.m. (daytime) 65
10:00 p.m. to 7:00 a.m. (overnight) 55
Industrial
7:00 a.m. to 10:00 p.m. (daytime) 65
10:00 p.m. to 7:00 a.m. (overnight) 60
Source: City of San Marcos 2017 (Table 20.300-4)
Notes: dBA = A-weighted decibels; Leq = equivalent noise level over a given period. 1 For single-family detached dwelling units, the "exterior noise level" is defined as the noise level measured at an outdoor living area which adjoins and is on the same lot as the dwelling, and which contains at least the following minimum net lot area: (i) for lots less than 4,000 square feet in area, the exterior area shall include 400 square feet, (ii) for lots between 4,000 square feet to 10 acres in area, the exterior area shall include 10% of the lot area; (iii) for lots over 10 acres in area, the exterior area shall include 1 acre. 2 For all other residential land uses, "exterior noise level" is defined as noise measured at exterior areas which are provided for private or group usable open space purposes. "Private Usable Open Space" is defined as usable open space intended for use of occupants of one dwelling unit, normally including yards, decks, and balconies. When the noise limit for Private Usable Open Space cannot be met, then a Group Usable Open Space that meets the exterior noise level standard shall be provided. "Group Usable Open Space" is defined as usable open space intended for common use by occupants of a development, either privately owned and maintained or dedicated to a public agency, normally including swimming pools, recreation courts, patios, open landscaped areas, and greenbelts with pedestrian walkways and equestrian and bicycle trails, but not including off-street parking and loading areas or driveways. 3 For non-residential noise sensitive land uses, exterior noise level is defined as noise measured at the exterior area provided for public use.

With respect to vibration, Section 20.300.070 of the Performance Standards also indicates that “no person or use shall create, maintain, or cause ground vibration that is discernible without instruments to a person of normal sensitivity at any point on a property that is adjacent to the property of the vibration source. The ground vibration caused by moving vehicles, trains, aircraft, or temporary construction or demolition is exempted.” Due to these exemptions, vibration due to construction of the proposed project, or vib ration from nearby roads and rail received by new buildings or its occupants associated with the proposed project , would be compatible with these City standards.

City of San Marcos General Plan
To control transportation-related noise sources such as arterial roads, freeways, airports, and railroads, the City has established guidelines for acceptable community noise levels in the Noise Element of the City of San Marcos General Plan (General Plan) (City of San Marcos 2012a). For noise sensitive rural and single-family residential uses, schools, libraries, parks, and recreational areas , the Noise Element requires exterior noise levels of less than 60 dBA CNEL for outdoor usable areas. For multifamily developments, the standard is 65 dBA CNEL, and a standard of 70 dBA CNEL is typically applied to commercial uses. The City has also established an interior noise limit of 45 dBA CNEL for all residential uses.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-6
The following are applicable goals and policies from the General Plan Noise Element (City of San Marcos 2012a):

Goal N-1: Promote a pattern of land uses compatible with current and future noise levels.

Policy N-1.1: Address the potential for excessive noise levels when making land use planning decisions in accordance with Table 7-3 Land Use Compatibility Noise Standards.

Policy N-1.2: Ensure that acceptable noise levels are maintained near noise-sensitive uses.

Policy N-1.3: Incorporate design features into residential land use projects that can be used to shield residents from excessive noise. Design features may include, but are not limited to: berms, walls, and sound attenuating architectural design and construction methods.

Policy N-1.4: Require new development projects to provide barriers to reduce noise levels, or provide sufficient spatial buffers to separate excessive noise generating land uses and noise-sensitive land uses.

Policy N-1.5: Require an acoustical study for proposed developments in areas where the existing and projected noise level exceeds or would exceed the Normally Acceptable levels identified in Table 7-3.

Goal N-2: Control transportation-related noise from traffic, rail, and aviation sources near noise sensitive land uses.

Policy N-2.1: Encourage only noise -compatible land uses along existing and future roadways, highways, and freeways.

Policy N-2.2: Promote coordinated site planning and traffic control measures that reduce traffic noise on noise-sensitive land uses.

Policy N-2.3: Advocate the use of alternative transportation modes such as walking, bicycling, mass transit, and non-combustible engine vehicles to reduce traffic noise.

Goal N-3: Control non-transportation-related noise from commercial, industrial, construction, and other so urces on noise sensitive land uses.

Policy N-3.1: When adjacent to noise sensitive receptors, require developers and contractors to employ noise reduction techniques during construction and maintenance operations.

Policy N -3.2: Limit the hours of construct ion and maintenance operations located adjacent to noise - sensitive land uses.

The following are applicable goals and policies from the General Plan Safety Element (City of San Marcos 2012b):

Goal S-7: Comply with the McClellan-Palomar Airport Land Use Compatibility Plan.

Policy S -7.1: Record an overflight notification document in association with the approval of any new residential land use within the AIA overflight notification area consistent with the ALUCP.

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10, Land Use and Planning. As detailed in Section 3.10.4, the project would be consistent with the applicable goals and policies.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-7

3.11.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts related to noise are based on Appendix G of the California Environmental Quality Act ( CEQA) Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to noise would occur if the project would:
▪ Threshold No. 1: Result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.
▪ Threshold No. 2: Generation of excessive groundborne vibration or groundborne noise levels. ▪ Threshold No. 3: For a project located within the vicinity of a private airstrip or an airport l and use plan, or where such a plan has not been adopted, within 2 miles of a public airport or public use airport, e xpose people residing or working in the project area to excessive noise levels.

In light of the above significance criteria, this analysis uses the following standards to evaluate potential noise and vibration impacts.
▪ Construction noise – the City has adopted the County of San Diego threshold for construction equipment noise, which must not exceed an 8-hour Leq value of 75 dBA Leq when assessed at an occupied property .

Construction shall only occur between the hours of 7:00 a.m. through 6:00 p.m., Monday through Friday, and 8:00 a.m. and 5:00 p.m. on Saturday.
▪ Off-site project -attributed transportation noise – For purposes for this analysis, a direct roadway noise impact would be considered significant if increases in roadway traffic noise levels attributed to the proposed project would be greater than 3 dBA CNEL at an existing noise-sensitive land use. ▪ Off-site project-attributed stationary noise – For purposes for this analysis, a noise impact would be considered significant if noise from typical operation of heating, ventilation, and air conditioning and other electro-mechanical systems associated with the proposed project would exceed the following:
- 60 dBA hourly Leq at the property line of an off-site single-family residence from 7:00 a.m. to 10:00 p.m., and 50 dBA hourly Leq from 10:00 p.m. to 7:00 a.m.
- 65 dBA hourly Leq at the property line of an off-site commercial land use from 7:00 a.m. to 10:00 p.m., and 55 dBA hourly Leq from 10:00 p.m. to 7:00 a.m.
▪ Construction vibration – Although exempted by the City, guidance from Caltrans indicates that a vibration velocity level of 0.2 ips PPV received at a struct ure would be considered annoying by occupants within (Caltrans 2020). As for the receiving structure itself, Caltrans guidance recommends that a vibration level of 0.3 ips PPV would represent the threshold for building damage risk.

Further, while the CEQA noise criteria listed above do not consider project consistency with exterior and interior noise standards, such an analysis is relevant to the assessment of the land use and planning impacts of the proposed project. This analysis therefore also evaluates compatibility of on -site traffic noise exposure levels with the City exterior and interior noise standards of 65 dBA CNEL and 45 dBA CNEL, respectively.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-8

3.11.4 Project Impact Analysis
Threshold No. 1: Would the project result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Short -Term Construction Noise
Construction noise and vibration are temporary phenomena. Construction noise and vibration levels vary from hour to hour and day to day depending on the equipment in use, the operations performed, and the distance between the source and receptor.

Equipment that would be in use during construction would include, in part, graders, backhoes, rubber-tired dozers, loaders, cranes, forklifts, pavers, rollers, and air compressors. The typical maximum noise levels at a distance of 50 feet from various piec es of construction equipment and activities anticipated for use on the project site are presented in Table 3.11-4. The equipment noise levels presented in Table 3.11-4 are maximum noise levels. Usually, construction equipment operates in alternating cycles of full power and low power, producing average noise levels over time that are less than the maximum noise level. The average sound level of construction activity also depends on the amount of time that the equipment operates and the intensity of construction activities during that time.

Table 3.11-4. Typical Construction Equipment
Equipment Type Typical Equipment (L max , dBA at 50 Feet) All Other Equipment Greater than 5 HP 85
Backhoe 78
Compressor (Air) 78
Concrete Saw 90
Crane 81
Dozer 82
Excavator 81
Flat Bed Truck 74
Front End Loader 79
Generator 72
Grader 85
Man Lift 75
Paver 77
Roller 80
Scraper 84
Welder/Torch 73
Source: DOT 2006.

Note: Lmax = maximum sound level; dBA = A-weighted decibels; HP = horsepower Aggregate noise emission s from proposed project construction activities, broken down by sequential phase, was predicted at two evaluation distances to the nearest existing noise-sensitive receptor: from the nearest position of the construction site boundary and from the geographic center of the construction site, which serves as the time - averaged location or geographic acoustical centroid of activ e construction equipment for the phase under study.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-9
The intent of the former distance is to help evaluate anticipated construction noise from a limited quantity of equipment or vehicle activity expected to be at the boundary for some period of time, which would be most appropriate for phases such as site preparation, grading, and paving. The latter distance is used in a manner similar to the general assessment technique as described in the FTA guidance for construction noise assessment, when the location of individual equipment for a given construction phase is uncertain over some extent of (or the entirety of) the construction site area. In this studied scenario, because of the equipment location uncertainty, all the equipment for a construction phase is as sumed to operate —on average—from the acoustical centroid position.

Table 3.11-5 summarizes these two distances to the apparent closest noise-sensitive receptor for each of the seven sequential construction phases. At the site boundary, this analysis assumes that up to only one piece of equipment of each listed type per phase will be involved in the construction activity for a limited portion of the 8 -hour period.

In other words, at such proximity, the operating equipment cannot “stack” or crowd the vicinity and still operate.

For the acoustical centroid case, which intends to be a geographic average position for all equipment during the indicated phase, this analysis assumes that the equipment may be operating up to all 8 hours per day.

Table 3.11-5. Estimated Distances between Construction Activities and the Nearest Noise-Sensitive Receptors
Construction Phase (and Equipment
Types Involved)
Distance from Nearest
Noise -Sensitive Receptor
to Construction Site
Boundary (Feet)
Distance from Nearest
Noise -Sensitive Receptor
to Geographic Center of
Site (Feet)
Demolition (concrete saw, backhoe, dozer) 80 160
Site Preparation (grader, scraper, backhoe) 80 160
Grading (grader, dozer, backhoe) 80 160
Building construction (crane, man-lift,
generator, backhoe, welder)
80 160
Paving (paver, roller, concrete mixer truck) 80 160
Architectural Coating (compressor) 80 160
Source: Appendix I.

A Microsoft Excel –based noise prediction model emulating and using reference data from the Federal Highway Administration Roadway Construction Noise Model (FHWA 2008) was used to estimate construction noise levels at the nearest occupied noise-sensitive land use. (Although the Roadway Construction Noise Model was funded and promulgated by the Federal Highway Administration, it is often used for non -roadway projects because the same types of construction equipment used for roadway projects are often used for other types of construction.) Input variables for the predictive modeling consist of the equipment type and number of each (e.g., two graders, a loader, a tractor), the duty cycle for each piece of equipment (e.g., percentage of time within a specific tim e period when the equipment is expected to operate at full power or capacity and thus make noise at a level comparable to what is presented in Table 3.11 -4), and the distance from the noise -sensitive receiver. The predictive model also considers how many hours that equipment may be on site and operating (or idling) within an established work shift.

Conservatively, no topographical or structural shielding was assumed in the modeling. The Roadway Construction Noise Model has default duty -cycle values for the various pieces of equipment, which were derived from an extensive study of typical construction activity patterns. Those default duty -cycle values were used for this noise analysis, and the predicted results displayed in Table 3.11-6.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-10
Table 3.11-6. Predicted Construction Noise Levels per Activity Phase Construction Phase
(and Equipment Types Involved)
8-Hour L eq at Nearest
Noise -Sensitive Receptor
to Construction Site
Boundary (dBA)
8-Hour L eq at Nearest
Noise -Sensitive Receptor
to Geographic Cente r of
Site (dBA)
Demolition (concrete saw, backhoe, dozer) 74.8 71.6
Site Preparation (grader, scraper, backhoe) 74.2 70.3
Grading (grader, dozer, backhoe) 73.5 70.0
Building construction (crane, man-lift,
generator, backhoe, welder)

68.5 67.1
Paving (paver, roller, concrete mixer truck) 70.3 67.1
Architectural Coating (compressor) 62.6 59.1
Notes: Leq = equivalent noise level; dBA = A-weighted decibels.

As presented in Table 3.11-6, the highest estimated construction noise levels are predicted to stay below 75 dBA Leq over an 8-hour period at the nearest existing residences (as close as 80 feet away) when demolition activities take place near the western project boundaries. These estimated noise levels at a source -to-receiver distance of 80 feet would only occur when noted pieces of heavy equipment would each operate for a cumulative period of up to 2 hours a day. For example, a grader might make multiple passes this close to a rece iver, but for the remaining time during the day, the grader is performing work at a more distant location or simply not operating.

Should operation of construction equipment and processes be sufficiently proximate to the project’s western boundary for grea ter than 2 hours a day, construction activity noise levels might exceed an 8 -hour L eq value of 75 dBA Leq and thereby exceed the City’s adopted daytime threshold for construction noise exposure at an occupied property. Therefore, the following suggested pr actices would be incorporated into the project’s construction program as project design features:
▪ Administrative controls (e.g., reduce operating time of equipment and/or prohibit usage of equipment types within certain distances)
▪ Engineering controls (upgrade noise controls, such as install better engine exhaust mufflers) ▪ Install noise abatement on the site boundary fencing (or within the site, as practical and appropriate) in the form of sound blankets or comparable temporary barriers to occlude construction noise emissions between the site (or specific equipment operation as the situation may define) and off-site noise-sensitive receptors of concern ▪ At the outset of a project construction activity, an unattended noise level monitor might be deployed on site to measure and document that noise exposure levels attributed to project construction activity at adjacent off-site sensitive receptors are in conformance with the 75 dBA 8-hour Leq threshold The above design features would be implemented as site conditions may warrant. Proper application of temporary noise barriers or comparable sound abatement can feasibly reduce noise levels by at least 5 dB due to direct path occlusion between the noise source and receptor.

In summary, daytime construction noise would not exceed the City’s 75 dBA threshold and , thus, temporary construction-related noise impacts would be considered less than significant.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-11
Long -Term Operation al Noise
Off-Site Traffic Noise Exposure
Implementation of the proposed project would generate additional vehicle trips on local arterial roadways (i.e., W Mission Boulevard and N Las Posas Road), which could result in increased traffic noise levels at adjacent offsite existing noise-sensitive land uses. Appendix K-2 to this EIR contains a spreadsheet with traffic volume data (average daily traffic) for surrounding arterial roadways. Implementation of the proposed project is estimated to add 960 average daily trips to adjacent street segments.

Potential noise effects from vehicular traffic were assessed using the Federal Highway Administration’s Traffic Noise Model version 2.5 (FHWA 2004). Information used in the model included the roadway geometry, existing (year 2022), existing plus project, near-term (opening day) and near-term (opening day) plus project traffic volumes and posted traffic speeds. Noise levels were modeled at representative noise-sensitive receivers ST1 through ST4, as shown in Figure 3 .11-1. The receivers were modeled to be 5 feet above the local ground elevation. The noise model results are summarized in Table 3.11-7.

Table 3.11-7. Roadway Traffic Noise Modeling Results
Modeled
Receiver
No.

Existing
(202 2)
Noise
Level (dBA
CNEL)
Existing
(202 2) Plus
Project
Noise Level
(dBA CNEL)
Near -Term
(Opening
Day )
Noise
Level (dBA
CNEL)
Near -Term
(Opening
Day ) Plus
Project
Noise
Level (dBA
CNEL)
Horizon
Year
(2050)
Noise
Level
(dBA
CNEL)
Horizon
Year
(2050)
Plus
Project
Noise Level
(dBA CNEL
Maximum
Project -
Related
Noise
Level
Increase
(dB)
ST1 68.3 68.3 68.6 68.6 69.4 69.4 0.0
ST2 69.0 69.6 69.6 69.8 70.2 70.4 0.2
ST3 66.5 66.7 67.1 67.2 67.7 67.9 0.2
ST4 52.7 51.2 53.2 51.7 53.9 52.4 < 0.0*
Notes: dBA = A-weighted decibel; CNEL = Community Noise Equivalent Level; dB = decibel. * Noise level change is negative.

Based on results of the model, implementation of the proposed project would not result in readily perceptible increases in traffic noise. Table 3.11-7 shows that at all four listed representative receivers, the addition of proposed project traffic to the roadway network would result in an increase in the CNEL of less than 3 dB, which is below the discernible level of change for the average healthy human ear. Therefore, a less-than-significant impact would occur related to operational traffic noise.

On-Site Interior Noise Exposure
Aside from exposure to aviation traffic noise, current CEQA noise-related guidelines at the state level do not require an assessment of exterior-to-interior noise intrusion, environmental noise exposure to occupants of newly created project residences, or environmental noise exposure to exterior non-residential uses attributed to the development of the proposed project. Nevertheless, the City’s General Plan and the California Building Code require that interior background noise levels not exceed a CNEL of 45 dB within habitable rooms. Hence, the following predictive analysis of traffic noise exposure at the exteriors of occupied residences and outdoor living areas is provided below.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-12
In addition to the prediction results presented in Table 3.11-7, the Federal Highway Administration Traffic Noise Model software was also used to predict the Horizon -Year-Plus-Project scenario traffic noise levels at multiple on - site exterior areas, as listed in Table 3.11-8. These on -site modeled receptor locations, which appear in Figure 3.11-1, include representative positions for the exteriors of multiple floors and positi ons of six of the proposed project building facades. Predicted exterior sound levels presented in Table 3.11-8 that are higher than 65 dBA CNEL indicate locations where an exterior-to-interior noise analysis should be performed for the proximate occupied residential unit. Individual modeling locations are provided in Appendix I.

Table 3.11-8. Future Ambient Noise Levels at Residential Facades Modeled Receptor
Noise Level (A -weighted CNEL)
1st Floor 2nd Floor 3rd Floor
M1–1 65 65 65
M1–2 64 64.0 64
M2–1 58 60 60
M2–2 62 63 63
M3–1 56 59 59
M3–2 58 60 61
M4–1 64 65 65
M5–1 61 62 62
M5–2 65 65 65
M6–1 68 69 68
M6–2 68 68 68
OS–1 65
OS–2 65
Note: CNEL = community noise equivalent level.

The prediction results from Table 3.11-8 indicate that future traffic noise levels would not exceed 69 dBA CNEL.

With the 45 dBA CNEL interior background sound level limit, this means the minimum composite sound transmission class (STC) rating for the exterior shell separating the habitable interior space from the outdoor sound level should be at least 24. The composite STC rating for the portion of a building shell that separates an interior space from the outdoors is calculated from the area -dependent con tributions of its elements: windows, wall assemblies, and doors.

Many of the residential units feature porches or balconies on the 1st or 2nd floor, for which access would likely be provided by single -panel, out-swing fiberglass French doors with hinges c omparable to a Milgard Essence series model (or similar from another manufacturer). Alternately, they could be a sliding door type. For purposes of this analysis, either of these patio/balcony door design styles are assumed to feature a dual-pane glazing system similar to a standard residential window assembly (i.e., two 1/8 -inch-thick glass panes separated by a 3/8 -inch-wide airgap) in narrow-perimeter frames compatible with modern thermal insulation (and thus energy conserving) design.

The analysis also assumes that these door products feature good seals and related hardware, so that when closed, the effective sound insulating performance is represented by the glass. Viracon data indicate that such glazing should demonstrate an STC rating of 31 (Viracon 2019; Appendix I).

The Noise Report prepared for this project assumes an exterior wall assembly that includes one layer of 5/8 -inch gypsum wallboard on the interior -facing side, 2 -inch × 4-inch wood studs, glass fiber batt insulation in the stud cavities, and a dual -layer of 5/8 -inch gypsum wallboard on the exterior -facing side. Acoustical transmission loss

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-13
data are available on this representative assembly and are used as part of estimating the composite STC ratings reported herein (Appendix I). For purposes of this analysis, the dual-layer gypsum wallboard on the exterior surface approximates the mass and solidity of what may be other approved material options as determined by the project architect, such as cement fiber siding panels, brick masonry veneer, o r cement plaster attached to layers of fiberglass mat sheathing and plywood sheathing.

Table 3.11-9 summarizes the calculated noise levels after applying the STC ratings for a set of studied occupied room facades that are anticipated to be exposed to predicted exterior noise levels greater than 6 5 dBA CNEL.

Details of these calculations that account for the façade surface area and its composite areas of exterior wall assembly and windows are provided in Appendix I.

Table 3.11-9. Predicted Net Sound Transmission Class of Occupied Room façade Occupied Room Facade
Predicted Net Sound Transmission Class for
Proposed Project
Closed Windows
and Door*
Open Windows and
Closed Door*
1st floor living room w/porch, eastern facade 35 6
2nd floor living room w/balcony, eastern façade 35 6
3rd floor bedroom, eastern façade 38 15
Source: Appendix I.

Notes: n/a = not applicable
* Doors are only modeled for scenarios that contain the balcony door.

An open window or open door to an adjoining patio or balcony greatly compromises the sound insulation performance of the façade wall assembly, as presented for the sample units appearing in Table 3.11-9. However, when such windows and doors are closed, all facades are anticipated to exhibit a predicted STC rating of at least 35, and thus would provide sufficient exterior-to-interior sound insulation from outdoor traffic noise to yield interior background sound levels that are less than 45 dBA CNEL and compliant with the City and state standards. None of the predicted exterior traffic noise levels at the studied receptor locations exceeded 69 dBA CNEL; thus, the STC rating value (for closed windows and doors) subtracted from these exterior noise values would result in interior noise levels of less than 45 dBA CNEL (e.g., 69 − 35 = 34 dBA CNEL, which is less than 45). This apparent requirement for closed windows and doors means that the design of these habitable rooms should feature mechanical ventilation or an air -conditioning system to provide interior comfort for the occupants. Detailed transmission loss data are included in Appendix I. Thus, the City’s threshold of 45 dB CNEL within habitable rooms would not be exceeded and the project would be expected to comply with this standard.

Where predicted exterior noise levels exceed 65 dBA CNEL near common useable outdoor space (as shown on Table 3.11-8) and such space would count towards the outdoor usable space associated with the project, according to the City’s General Plan, feasible noise reduction techniques should be analyzed and incorporated to make outdoor activities acceptable at locations that are currently above the City’s 65 dBA CNEL standard. With the implementation of Project Design Feature (PDF) NOI-1, the resultant exterior noise levels would meet the City’s exterior noise standard of 65 dBA CNEL.

For proposed project residential units tha t feature patios or balconies as outdoor useable areas, predicted future traffic noise exposure levels presented in Table 3.11-8 suggest that up to 4 dBA of noise reduction would be needed to keep sound on such balconies at levels below the 65 dBA CNEL compatibility standard. With the implementation of PDF-NOI-2, the resultant exterior noise levels would meet the City’s exterior noise standard of 65 dBA CNEL.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-14
With implementation of PDF-NOI-1 and PDF-NOI-2, the City’s thresholds would not be exceeded and on-site noise impacts would be less than significant.

PDF-NOI-1 Where exterior noise levels are predicted to exceed 65 A-weighted decibels community noise equivalent level at useable open space areas, the project sh all install noise -reducing features external to or upon the useable open space areas (or within, as practical and appropriate) in the form of sound walls, fencing, landscape berms, or similarly performing barriers to occlude incoming roadway traffic noise.

PDF-NOI-2 Residential unit patios or balconies with roadway-facing building facades predicted to be exposed to external noise levels in excess of 65 A-weighted decibels community noise equivalent level shall feature railings or other partial -height barriers comprising sufficiently solid and dense materials (e.g., acrylic, glass, wood that exhibits a sound transmission class rating of at least 20) and of a 42-inch minimum height (from floor or deck of the balcony surface) that occludes direct sound path from the noise-producing roadway of concern and a seated patio or balcony occupant.

Stationary Operation al Noise
The proposed project would add a variety of noise-producing mechanical equipment and other stationary sources, including facility unit heating, venti lation, and air conditioning equipment. The incorporation of new multifamily homes and a mix of open space uses attributed to development of the proposed project will add a variety of noise- producing electro-mechanical equipment. Most of these noise -producing equipment or sound sources would be considered stationary or limited in mobility to a defined area.

For purposes of this analysis, each of the new occupied residential units would be expected to feature a split-system type air -conditioning unit, with an air -cooled refrigeration (2 -ton capacity) condenser unit in the patio area as currently depicted by the site plan (dated June 24, 2020). Assuming each condenser unit has an SPL of 68 dBA at 3 feet based on available data from a likely manufacturer (Carr ier 2012), the site plan suggests that these condenser units would generally be installed near the patio (i.e., apparent “front porch”). Therefore, the closest existing noise-sensitive residential receptor to the west of the proposed project’s westernmost unit would be as close as 90 horizontal feet to the nearest of these condenser units. However, due to the 6-foot-tall property line wall proposed along the western property boundary, the predicted sound emission level from the combination of all eight operating condenser units as received by this off-site single-family home would be 46 dBA Leq and would thus be compliant with the City’s nighttime threshold of 50 dBA hourly L eq. The operation of residential air-conditioning units would result in a less-than-significant noise impact.

Threshold No. 2: Would the project result in the generation of excessive groundborne vibration or groundborne noise levels?
Construction activities may expose people to excessive groundborne vibration or groundborne noise. On-site construction that would cause the most groundborne vibration and noise is associated with equipment used for grading, specifically large bulldozers for earthmoving. Caltrans has collected gro undborne vibration information related to construction activities (Caltrans 2020). Information from Caltrans indicates that continuous vibrations with a PPV of approximately 0.2 ips is considered “annoying.” Groundborne vibration attenuates rapidly—even over short distances. And when groundborne vibration encounters a building foundation, a coupling loss occurs depending on the mass and design. For typical wood-framed houses, like those near the proposed project, this coupling loss is 5 vibration velocity decibels according to FTA guidance

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-15
(FTA 2018). The attenuation of groundborne vibration as it propagates from source to receptor through intervening soils and rock strata can be estimated with expressions found in FTA and Caltrans guidance. For a bulldozer operating on site as close as the western project boundary (80 feet from the nearest receiving sensitive land use), the estimated vibration velocity level would be 0.024 ips, less than the annoyance threshold recommended by Caltrans. Therefore, vibration-induced annoyance to occupants of nearby existing homes would be less than significant.

Construction vibration at sufficiently high levels can also present a building damage risk. However, anticipated construction vibration from conventional heavy equipme nt associated with this proposed project would not yield levels that surpass this risk. Per Caltrans, the recommended PPV threshold for newer residential structures is

0.5 ips and for older residential structures it is 0.3 ips—both of which are less stringent that the threshold to annoy occupants of such structures; thus, vibration damage risk to nearby structures is considered less than significant.

During project operation, the proposed project would feature mechanical systems like heating, ventilation, and air- conditioning units . These systems are designed and manufactured to feature rotating (fans, motors) and reciprocating (compressors) components that are well -balanced with isolated vibration within or external to the equipment casings. On this basis, vibration due to proposed project operation would be less than significant.

Overall, impacts related to generation of excessive groundborne vibration or groundborne noise le vels as a result of project construction and operation would be less than significant.

Threshold No. 3: For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? There are no private airstrips within the vicinity of the project site. The closest airport to the project site i s the McClellen Palomar Airport approximately 5 miles west southwest of the site. No impact would occur.

3.11.5 Cumulative Impact Analysis
Noise levels tend to diminish quickly with distance from a source. Therefore, t he geographic scope of the analysis of cumulative impacts related to noise is limited to locations immediately surrounding and in close proximity to the project site . As described in Section 3.11.4, project implementation would result in less -than-significant noise impacts. No mitigation is required with implementation of the project design features.

Cumulative traffic noise impact could occur in combination with the project and cumulative projects during construction if traffic noise exceeded City standards. However, it is likely that any construction traffic, as related to export/import haul trucks associated with cumulative projects, would be distributed among different roadways based on the locations of cumulative projects. Similar to the proposed project , cumulative projects would include construction and operation noise reduction measures to reduce any potentially significant noise impacts to a level below significance , where feasible . Development plans for cumulative projects would be required to outline mitigation measures, des ign features, and required regulatory compliance. Implementation of project -specific mitigation and design features would ensure cumulative noise impacts would remain at a less-than-significant level.

3.11.6 Mitigation Measures
As analyzed in Section 3.11. 4, potential noise impacts during construction and operation of the project would be less than significant. No mitigation is required.

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-16

3.11.7 Conclusion
As discussed above, potential noise impacts during construction would be less than significant. Noise impacts due to operation of the proposed project (including traffic noise) would be less than significant with implementation of PDF -NOI-1 and PDF -NOI-2. N o further mitigati on is required. Further, the proposed project would comply with the General Plan’s 45 dBA interior noise standard. Proposed project impacts related to noise would be less than significant.

Date: 2/13/2023 - Last saved by: hmcomber - Path: Z:\Projects\j1352801\MAPDOC\DOCUMENT\EIR\Figure 3.11-1 Noise Measurement Locations.mxd

PALMAC ST

GRANITE RD

PALM RD

PALOMARCOS AVE
N

LASPOSA
S
RD

N PACIFIC ST

WMISSION
RD
ST3
ST4
ST2
ST1
OS-1
OS-2
M1
M2
M3 M4
M5
M6
Noise Measurement Locations
Gran Vista Specific Plan Project EIR
SOURCE: SANGIS 2020, 2021
01 5075
Feet
Project Boundary
Noise Measurement and Modeling Locations
Modeled Receptor
Open Space
Short Term Measurement
FIGURE 3.11-1

3.11 – NOISE
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.11-18

INTENTIONALLY LEFT BLANK

3.12 – POPULATION AND HOUSING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.12-1

3.12 Population and Housing
This section describes the existing setting of the proposed Gran Vista Specific Plan Project (project), identifies associated regulatory requirements, and evaluates potential impacts related to population and housing resulting from the project. This section considers population and housing characteristics in the area and discusses project consistency with regional growth projections.

Table 3.12-1 provides a summary of the project- and cumulative-level population and housing impacts by threshold.

Table 3.12-1. Population and Housing Summary of Impacts Threshold of Significance
Project Direct
Impact
Project
Cumulative
Impact
Significance
Determination
No. 1: Induce substantial unplanned population growth
in an area, either directly (for example, by proposing
new homes and businesses) or indirectly (for example,
through extension of roads or other infrastructure).

Less than
Significant
Less than
Significant
Less than
Significant
No. 2: Displace substantial numbers of existing people
or housing, necessitating the construction of
replacement housing elsewhere.

No Impact No Impact No Impact

3.12.1 Existing Conditions
This section provides background information regarding population and housing forecasts for the City of San Marcos (City) based on demographic information from the San Diego Association of Governments (SANDAG) and the City of San Marcos General Plan (General Plan) Housing Element (2021–2029).

Currently, the project site is vacant and undeveloped and does not support residential uses as it is zoned for Commercial land use.

Population
According to the General Plan Housing Element, San Marcos has been one of the fastest growing cities in t he San Diego region (City of San Marcos 2021). The City doubled its population in the 1980s and again between 1990 and 2010. The San Diego region grew by 8% from 2010 to 2020 and the City grew by 1 6% during this same timeframe (City of San Marcos 20 21). As of 2020, the City ha d an estimated population of 96,302 (DOF 2021).

Based on growth projections provided by the Series 13: 2050 Regional Growth Forecast prepared by SANDAG, it is estimated that the City’s population will reach 109,095 people by 2035 , and 113,015 people by 2050 (SANDAG 2013a).

The City’s growth has outpace d countywide growth, and the City’s population is anticipated to increase upon buildout of lands within the City limits, particularly in areas around transit facilities and near California State University San Marcos.

3.12 – POPULATION AND HOUSING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.12-2
Housing
As of 2021, the City had 32,700 housing units. The housing stock is comprised of approximately 58.40% single- family detached and attached units and approximately 31 .37% multifamily units (DOF 202 1). Approximately

10.18% of the housing stock as of 2020 consisted of mobile homes (DOF 2021). Based on the Series 13: 2050 Regional Growth Forecast, the City is expected to have 35,795 housing units by 2035 and 37,337 housing units by 2050 (SANDAG 2013a).

The General Plan Housing Element identifies overcrowding and overpayment (cost burden) as two housing problems within the City (City of San Marcos 2021). Overcrowded households usually reflect the lack of affordable housing available and suitable for the size of those families, which may result in poor physic al condition of the dwelling units. Of the total number of occupied units in the City in 2019, 1,959 (6.6%) housing units were overcrowded, which represents 2.6% of owner units and 13.2% of renter units. The average household size in the City was

3.17 persons in 2019, which is a slight increase from the average household size of 3.05 persons in 2010. The average household size was higher for renters (3.37 persons) than it was for owner households (3.05 persons) (City of San Marcos 2021).

Home sales in the City have generally trended upward , w ith median housing prices in the City rising from approximately $500,000 in 2015 to a high of $725,000 in March 2019. According to the 2015–2019 U.S. Census American Community Survey data, the median rent in the City was $1,704 per month in 2019 and very few rentals were available in December 2019. Median rents ranged from $1,449 for one-bedroom homes to $2,419–$3,067 for four -bedroom or larger homes (City of San Marcos 2021). Despite the trend of increasing housing prices, compared to the rest of the state, housing in San Marcos is considered relatively affordable. While San Marcos may be relatively affordable for some, housing is not affordable for all income levels, particularly very low- and low- income households, and many households in the City end up spending more than 30% of their income on housing, leading to overpayment (City of San Marcos 2021).

Actual or potential constraints on the provision of housing affect the development of new housing and the maintenance of existing units for all income levels. Governmental and non-governmental constraints in the City are similar to those in other jurisdictions in the region. One of the most significant and difficult constraints to housing in the City and elsewhere in the San Diego region is the high cost of land (City of San Marcos 2021).

The State of California mandat ed the preparation of a Regional Housing Needs Plan (RHNP) (Government Code, Section 65584) for regions to address housing issues and needs based on future growth projections for the area.

SANDAG is responsible for the development of the RHNP for San Diego County and allocates a fair share of regional housing needs to individual cities and unincorporated county lands. The RHNP ensure s that local jurisdictions address the needs of their jurisdiction and ensures that the needs for the entire region are fairly distributed to all communities. A major goal of the RHNP is to ensure that every community provides a mix of affordable housing to all economic segments of its population.

The City’s 2021–2029 Housing Element addresses SANDAG’s Regional Housing Need Allocation (RHNA) schedule for the 6th Cycle, from 2021 through 2029. The California Department of Housing and Community Development, in collaboration with SANDAG, allocated 171,685 housing units that the San Diego region must plan for between 2021 and 2029. T he housing units are divided into four income categories , extremely low income, low income, moderate income, and above moderate income. The RHNA allocation for the City includes 3,116 new units, of which 364 must be extremely low income units, 364 very low, 530 low, 542 moderate, and 1,316 above moderate income units. The Housing Element has identified that 7 extremely low/very low/low, 5 low, 489 moderate, and 45 above

3.12 – POPULATION AND HOUSING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.12-3
moderate income units have been constructed, are under construction, or have been iss ued permits since June 30, 2020. An additional 81 extremely low/very low income units, 50 low income units, 409 moderate income units, and 499 above moderate income units are approved/entitled within the City. The City has exceeded its Cycle 6th RHNA for the moderate income category between the units that have been constructed, are under construction, or have been issued permits since June 30, 2020 , and those units that are approved, entitled, or in process ; as such, the remaining units that must be accommodated for the 6th Cycle are those for extremely low/very low, low, and above moderate income households (City of San Marcos 2021).

3.12.2 Regulatory Setting
This section describes the regulatory setting as it relates to population and housing for the project.

Federal
There are no federal codes, policies, or regulations regarding population and housing that would apply to the proposed project.

State
California Planning and Zoning Law
The legal framework within which California counties and cities exercise local planning and land use functions is provided in the California Planning and Zoning Law (Sectio ns 65000 through 66499.58 of the California Government Code). Under that law, each county and city must adopt a comprehensive, long-term general plan. The law gives counties and cities wide latitude in how a jurisdiction may create a general plan, but there are fundamental requirements that must be met. The requirements include seven mandatory elements described in the Government Code. Each element must contain text and descriptions setting forth objectives, principles, standards, policies, and plan proposals; diagrams and maps that incorporate data and analysis; and implementation measures.

Once the general plan of a county or city is adopted, it should be construed as a dynamic document, for which adaptability is a key component. Each jurisdiction should frequently review its general plan for consistency and to ensure it addresses growth -related issues in a comprehensive manner. State law allows up to four general plan amendments per general plan element per year, so each jurisdiction can make changes as justified.

California Building Standards Code
In 2001, California consolidated the Uniform Building, Plumbing, Electrical, and Mechanical codes into the California Building Standards Code, which is contained in Title 24 of the California Code of Regulations. The California Building Standards Code contains 11 parts: Electrical Code, Plumbing Code, Administrative Code, Mechanical Code, Energy Code, Residential Building Code, Historical Building Code, Fire Code, Existing Building Code, Green Building Standards Code, and the Reference Standards Code. These codes promote public health and safety and ensure that safe and decent housing is constructed in San Diego County’s unincorporated areas.

Senate Bill 375
Senate Bill 375 (codified in the Government Code and California Public Resources Code) took effect in 2008 and provides a new planning process to coordinate land use planning, regional transportation plans, and funding priorities in order to help California meet the greenhouse gas reduction goals established in Assembly Bill 32.

3.12 – POPULATION AND HOUSING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.12-4
Senate Bill 375 requires metropolitan planning organizations to incorporate Sustainable Communities Strateg ies (SCSs) in their Regional Transportation Plans (RTPs) that will achieve greenhouse gas emissions reduction targets by reducing vehicle miles traveled from light -duty vehicles through the development of more compact, complete, and efficient communities.

Regional Housing Needs Assessment
As discussed above, a n RHNA is mandated by state housing law as part of the periodic process of updating local general plan housing elements. The RHNA quantifies the need for housing within each jurisdiction during specified planning periods.

Communities use the RHNA in land use planning, prioritizing local resource allocation, and deciding how to address identified existing and future housing needs resulting from population, employment, and household growth. The RHNA does not necessarily encourage or promote growth, but rather allows communities to anticipate growth, so that collectively the region and subregion can grow in ways that enhance quality of life, improve access to jobs, promote transportation mobility, and address social equity and fair share housing needs.

Local
San Diego Association of Governments
SANDAG is a public agency composed of 18 cities and the County of San Diego that builds strategic plans guiding the San Diego region in land use, growth, economics, and the environment. SANDAG also provides population and housing estimates for the region, which are based in part on local jurisdictional planning data and inform regional planning.

The SANDAG Regional Comprehensive Plan, adopted in 2004, provides a long -term planning framework for the San Diego region (SANDAG 2004) . The Regional Comprehensive Plan identified smart growth and sustainable development as important strategies to direct the region’s future growth toward compact, mixed-use development in urbanized communities that already have existing and planned infrastructure . The plan also emphas ized connecting those communities with a variety of transportation choices.

In 2011, SANDAG approved the 2050 RTP/SCS (SANDAG 2011). This approval marked the first time SANDAG’s RTP included an SCS, consistent with the Sustainable Communities and Climate Protection Act of 2008, also known as Senate Bill 375. This RTP/SCS provided a blueprint to improve mobility, preserve open space, and create communities, all with transportation choices to reduce greenhouse gas emissions and meet specific targets set by the California Air Resources Board (CARB) as required by Senate Bill 375. In 2010, CARB established targets for each region in California governed by a metropolitan planning organization. SANDAG is the metropolitan planning organization for the San Diego region.

The SANDAG target, as set by CARB, is to reduce the region’s per capita emissions of greenhouse gas emissions from cars and light-duty trucks by 7% by 2020, compared with a 2005 baseline. By 2035, the target is a 13% per capita reduction. There is no target set beyond 2035. To achieve the 2020 and 2035 targets, SANDAG and other metropolitan planning organizations were required to develop SCSs as an element of their RTPs. The SANDAG SCS integrates land use and transportation plans to achieve reductions in greenhouse gas emissions and meet the CARB-required targets.

3.12 – POPULATION AND HOUSING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.12-5
San Diego Forward: The Regional Plan
SANDAG is required by law to update its RTP every 4 years. In December 2021, SANDAG adopted the latest update to its RTP/SCS. SANDAG’s 2021 RTP/SCS, known as San Diego Forward: The Regional Plan (Regional Plan), integrates the elements of the prior Regional Comprehensive Plan and combines those elements with the Regional Plan (SANDAG 2021).

The Regional Plan contains updated growth forecasts and is based o n the most recent planning assumptions considering currently adopted land use plans, including the City’s General Plan and other factors from the cities in the region and the County of San Diego. SANDAG’s Regional Plan will change in response to the ongoin g land use planning of the City and other jurisdictions. For example, the City’s General Plan, as well as other local general plans, may change based on general plan amendments initiated by the jurisdiction or landowner applicants. The general plan amendme nts may result in increases in development densities due to amendments of the regional category designations or zoning classifications. Accordingly, the latest forecasts from the SANDAG RTP/SCS of future development in the San Diego region, including location, must be coordinated closely with each jurisdiction’s ongoing land use planning because that planning is not static, as recognized by the need for updates to SANDAG’s RTP/SCS every 4 years.

Regional Growth Forecast
SANDAG estimates future population, housing, land use, and economic growth throughout San Diego County and its comprising cities, including the City of San Marcos. On October 13, 2013, SANDAG accepted the Series 13: 2050 Regional Growth Forecast (SANDAG 2013a). This forecast serves as the foundation for the Regional Plan and other planning documents across the re gion. SANDAG growth projections for the region and for the City are outlined in Table 3.12-2. The City is expected to experience a higher growth rate for population, housing, and employment when compared to the entire region of San Diego. It should also be noted that the 2050 Regional Growth Forecast is not intended to be an exact formula to determine growth in the region and comprising jurisdictions; rather , it should be utilized as a starting point for regional planning.

Table 3.12-2. Forecasted Growth for the San Diego Region and the City of San Marcos Jurisdiction
Year Change 201 2–2050
201 2 2020 2035 2050 Numeric Percent
Population
San Diego Regional 3,143,429 3,435,713 3,853,698 4,068,759 925,330 29% City of San Marcos 85,560 98,915 109,095 113,015 27,455 32% Housing
San Diego Regional 1,165,818 1,249,684 1,394,783 1,491,935 326,117 28% City of San Marcos 28,539 32,625 35,795 37,337 8,798 31% Employment
San Diego Regional 1,450,913 1,624,124 1,769,938 1,911,405 460,492 32% City of San Marcos 37,608 45,783 54,902 64,328 26,720 71% Source: SANDAG 2013a, 2013b.

3.12 – POPULATION AND HOUSING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.12-6
Regional Housing Needs Assessment
The Regional Housing Needs Assessment for the 6th Housing Element Cycle, 2021 –2029, was approved on July 10, 2020 (SANDAG 2020). Based on a methodology that weighs several factors (i.e., projected population growth, employment, commute patterns, and available sites), SANDAG quantifi ed needs for housing u nits in the region according to various income categories. In its final Regional Housing Needs Assessment figures, SANDAG allocated 3,116 housing units to the San Marcos area for the 2021–2029 Housing Element Cycle, including 1,258 housing units for very low and low income households (SANDAG 2020).

City of San Marcos General Plan
The City’s Housing Element identifies goals and associated policies to provide a basis for housing and growth projections in the City for the 20 21–2029 planning period . The following goals and policies from the Housing Element of the General Plan pertain to population and housing (City of San Marcos 2021):

Goal 1: Provide a broad range of housing opportunities with emphasis on providing housing which mee ts the special needs of the community.

Policy 1.1: Designate land for a variety of residential densities sufficient to meet the housing needs for a variety of household sizes and income levels, with higher densities being focused in the vicinity of transit stops and in proximity to significant concentrations of employment opportunities.

Goal 2: Protect, encourage, and provide housing opportunities for persons of lower and moderate incomes.

At the time of adoption of the City’s Housing Element (July 2021), the City had achieved approximately half of its RHNA from the 6th cycle (or approximately 1,531 units) with housing units construct ed, under construction, or approved, fulfilling its allocation of moderate income units. Based on a sites inventory assessment, the City has the ability to adequately accommodate the remaining RHNA requirements for all income levels within land that currently permits residential development (comprised of proposed applications, vacant residential sites, and vacant land in Specific Plan Areas). The project site is not identified within the City’s Housing Element as a site that could contribute to the RHNA allocation (City of San Marcos 2021).

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10, Land Use and Planning, of this environmental impact report (EIR). As detailed in Section 3.10.4, the project is consistent with the applicable goals and policies pertaining to population and housing.

3.12.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to population and housing are based on Appendix G of the California Environmental Quality Act ( CEQA) Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact would occur if the project would:
▪ Threshold No. 1: Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (fo r example, through extension of roads or other infrastructure).
▪ Threshold No. 2: Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

3.12 – POPULATION AND HOUSING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.12-7

3.12.4 Project Impact Analysis
Threshold No. 1: Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
As described in Chapter 2, the project proposes development of 120 multifamily residential dwelling units on

7.6 acres for an approximate total density of 15.8 d welling units per acre. The project would include a total of 260 parking spaces in addition to 37 existing spaces on site , approximately 92,645 square feet of common recreation area, and an average of 130 square feet of private open 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 N Las Posas Road frontage. The proposed project also includes landscaping, bi o-retention areas, and circulation improvements. The project would include two points of entry ; the first entry point is located off N Las Posas Road and the second entry point is located off W Mission Road (please refer to Figure 2-1, Conceptual Site Plan).

The project would include a variety of floorplans for the proposed townhomes. Floorplans include two - and three- bedroom units that vary in size from approximately 1,200 square feet to 1,80 0 square feet and include differing garage configurations. All to wnhomes would be three stories high. The number of townhomes per building would vary from 4 to 10. Proposed residential units are designed as entry-level, market-rate housing with a range of unit sizes and price points in order to create opportunities for home ownership that would be attractive to varying income levels. The proposed townhomes would also provide for a transition between single-family homes to the north and high-density apartments to the south. All proposed buildings would be equipped with p hotovoltaic panels (solar panels) on the rooftops to provide solar energy to the proposed homes, in accordance with current building code.

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) (refer to Figures 2 -4 and 2-6). Design of the project would be required t o follow the design guidelines outlined in the Gran Vista Specific Plan prepared for the project site (Appendix M). The design guidelines propose architectural styles for the project to be transitional in nature to allow the project to blend in with the su rrounding neighborhood. Landscape screening would be provided along the top of the drainage channel slope to preserve the privacy of adjacent neighbors.

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, a public community college consisting of a 200-acre campus, is located east of the project site. Palomar College Transit Center, a North County Transit District 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 W Mission Road, near the main entrance to Palomar College, and a train station on the south side of W 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 W Mission Road in front of CVS. The Inland Rail Trail, a proposed 21-mile Class I bikeway, runs along the south side of W Mission Road and connects the Cities of Oceanside, Vista, San Marcos, and Escondi do, as well us areas of unincorporated San Diego County.

As of 202 1, the City has a person per household ratio of 3.0 8 (DOF 2021). Using this household ratio of 3.0 8, development of 120 residential dwelling units at the project site would house approximately 370 people.

Although not all residents of the development would be new to the City, residential development on the project

3.12 – POPULATION AND HOUSING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.12-8
site would still result in unplanned growth within the City because the project site is zoned for Commercial use and the project proposes a residential land use. The residential land use for the project site was not accounted for in the City’s General Plan.

The project’s generation of housing for approximately 370 people is not expected to substantially induce population growth in the area. This is because the area surrounding the project site is already developed. Further, because the project site is in an infill area with existing roads and utilities, no indirect impacts associated with the extension or construction of roads or expansion of public utilities are expected to occur as a result of the project.

As discussed above, 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 Cycle (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.

The project would be subject to compliance with the City’s General Plan Housing Element goals and policies, housing-related ordinances in the San Marcos Municipal Code, and applicable development fees.

The City’s Growth Management Ordinance (Chapter 20.315 of the Municipal Code) was adopted to implement the General Plan and to manage the projected growth of residential, industrial, and commercial development. The ordinance requires that all new development bear the cost of providing the public facilities and services needed to effectively serve the new development. The Growth Management Ordinance does not limit density of development or cap the number of residential building permits that can be issued within the planning period. To the contrary, the ordinance will ensure that public facilities and services are, or will be, provided to serve future residential development anticipated by the RHNA.

The City’s Inclusionary Housing Ordinance, established in May 2000, requires housing developers of one or more units to contribute to housing for extremely low, very low, low, and moderate income households as defined by the U.S. Department of Housing and Urban Development. Developers of for -sale single-family projects and rental projects of six or fewer units may pay an in-lieu fee in accordance with Section 20.310.050 of the Municipal Code.

In-lieu fees are deposited into an interest-accruing account to provide housing opportunities for target households.

The City has the discretion to accept an irrevocable dedication of land or other non -monetary contribution that is not less in value than the otherwise required in -lieu fee if the non -monetary alternative furthers the goals and policies of the Housing Element. The project would not include any designated affordable housing units and has opted to pay the in-lieu fee.

The City charges fees to process plans submitted for residential projects and to finance t he provision of important services that are needed to accommodate housing and population growth. Fees and exactions are used to finance public facilities, roadways, water and sewer infrastructure, schools, and other community services. Nearly all of these fees are assessed through a pro rata share system, based on the magnitude of the project’s impact or the extent of the benefit that will be derived. Failure to adequately plan for residential development is a key reason why jurisdictions are so financially constrained today. Furthermore, the City’s fees have not been found to act as a constraint to the development of housing in San Marcos. For new residential projects, developers in San Marcos may be required to pay one or more of the following fees dependi ng on the location, type, and size of the project:

Planning, Building and Environmental Fees; City Impact Fees; and Regional Impact Fees (City of San Marcos 2023).

In summary, implementation of the project would change the site’s land use designation and z oning from Commercial to Specific Plan Area in a manner that would accommodate development of 120 residential units and generate housing for approximately 370 people not previously accounted for by the City . However, because the

3.12 – POPULATION AND HOUSING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.12-9
project area is already developed, the project is not expected to substantially induce unplanned population growth in the vicinity of the site. Further, because the project site is in an area with existing roads and utilities, no indirect impacts associated with the extension or construction of roads or expansion of public utilities are expected to occur as a result of the project. City requirements for funding and pre -planning for implementation of housing projects would also ensure that project growth is adequately planned for prior to development. As the project would be required to comply with City regulations and applicable fees outlined above, impacts associated with unplanned population growth would be less than significant.

Threshold No. 2: Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
The project site is currently vacant and undeveloped. Implementation of the project would not displace any existing housing or people or necessitate the construction of replacement housing elsewhere. Therefore, no impact would occur.

3.12.5 Cumulative Impact Analysis
Cumulative projects in addition to the project could result in both dir ect and indirect cumulative impacts to population and housing in the City. Projects outlined in Table 2-2 in Chapter 2, Project Description, of this EIR that include residential development could result in direct impacts to population growth in the City, and non-residential projects located on undeveloped land could result in indirect growth due to the need for new roads and/or utilities or expansion of existing infrastructure.

Cumulative projects outlined in Chapter 2 of this EIR include both residential and mixed-use development projects.

The introduction of a new population is not, in and of itself, a significant impact. As with a project-level analysis, the significance of a cumulative population impact is determined by whether the popula tion growth resulting from the combined cumulative projects would be considered to induce substantial unplanned population growth in the area.

Similar to the City, the neighboring jurisdictions manage population growth and housing stock to meet their RHNA requirements. All cumulative projects would be required to prepare an environmental document addressing potential impacts to population and housing and would be required to comply with the City’s General Plan Housing Element, City Ordinances related to hou sing, and applicable development fees. Compliance with City regulations and fees would ensure that cumulative impacts related to population and housing would be adequately addressed.

Further, the project and cumulative projects would not result in the rem oval of a barrier of growth that would reasonably result in the intensification or development of land or any cumulative utility or infrastructure expansion.

Additionally, because the project is surrounded by existing development, approval of the project would not lead to substantial intensification of the land use in the area. Similar to the project, a CEQA analysis would be required for all cumulative projects to determine potential environmental impacts. Therefore, cumulative impacts would be less than significant.

3.12.6 Mitigation Measures
No significant impacts are identified; therefore, no mitigation measures are required.

3.12 – POPULATION AND HOUSING
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.12-10

3.12.7 Conclusion
Although the project would introduce a residential land use and an increase in population at the project site not previously accounted for by the City, because the surrounding project area is already developed, the project would not serve to induce substantial unplanned population growth in the vicinity of the site. Further, because the project site is in an area surrounded by development with existing roads and utilities, no indirect impacts associated with the extension or construction of roads or expansion of public utilities are expected to occur as a result of the project.

As analyzed in Section 3.12.4, approval of the project could help the City accommodate the substantial population growth projected to occur within the City and the need for housing.

City requirements fo r funding and pre -planning for implementation of housing projects would also ensure that project growth is adequately planned for prior to development. The project would be required to comply with goals and policies outlined in the City’s Housing Element and applicable City regulations and fees as outlined above.

Approval of the proposed General Plan Amendment and Rezone of the project site from Commercial (C) to Specific Plan Area (SPA) and compliance with applicable City regulations would ensure project i mpacts related to the increase in population and housing would be less than significant.

Since the project site is located on undeveloped land, implementation of the project would not displace any existing housing or people in a manner that would necessitate the construction of replacement housing elsewhere.

Overall, impacts related to population and housing as a result of project implementation would be less than significant.

3.13 – PUBLIC SERVICES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.13-1

3.13 Public Services
This section describes the existing setting of the proposed Gran Vista Specific Plan Project (project) site, identifies associated regulatory requirements, and evaluates potential impacts related to public services, including fire protection services, police protection services, schools, parks, and libraries.

Table 3.13-1 summarizes the project- and cumulative-level public services analysis impact by thresholds of significance.

Table 3.13-1. Public Services Summary of Impacts
Threshold of
Significance Project -Level Impact Cumulative -Level Impact Significance
Determination
No. 1: Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:

Fire protection services Less than Significant Less than Significant Less than Significant Police protection services Less than Significant Less than Significant Less than Significant Schools Less than Significant Less than Significant Less than Significant Parks Less than Significant Less than Significant Less than Significant Other public facilities Less than Significant Less than Significant Less than Significant

3.13.1 Existing Conditions
This section details the existing service providers and resources related to fire protection, police protection, schools, parks, and libraries.

Fire Protection
The project site is located within the San Marcos Fire Protection District (SMFPD) boundary, which covers an area of 33 square miles and serves a population of approximately 95,000 residents (City of San Marcos 20 22a). The San Marcos Fire Department (SMFD) would provide fire protection and emergency medical services to the project site.

The SMFD currently operates 4 fire stations, 4 paramedic assessment engine companies, 1 paramedic assessment truck company, 5 paramedic transport ambulances (24-hour units), 1 shift battalion chief, and 1 on-call duty chief. SMFD also cross-staffs three wildland fire engines and a State of California/Office of Emergency Services wildland fire engine (City of San Marcos 2022a). The SMFD Station 1, located at 180 W. Mission Road, San Marcos, California 92069, is the closest station to the project site and would likely serve the project site should fire response or emergency services be needed (City of San Marcos 2023a). SMFD Station 1 is located approximately 1.5 miles southwest of, or 4 minutes away from, the project site. SMFD Station 1 houses an engine, truck, brush engine, ambulance, and battalion chief.

Police Protection
According to the City of San Marcos (City) General Plan, Land Use and Community Design Element, the City contracts their law enforcement services from the San Diego County (County) Sheriff’s Department (City of San Marcos 2012a).

The project would be served by the Sheriff’s San Marcos Station, located at 182 Santar Place in the northeast quadrant of the City (City of San Marcos 2012a). This sheriff station is located approximately 2.5 miles east of, or 8 minutes from, the project site.

3.13 – PUBLIC SERVICES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.13-2
The Sheriff’s San Marcos Stati on provides law enforcement services to the City and unincorporated communities of Harmony Grove, Elfin Forest, Lake San Marcos, Hidden Meadows, Ivy Del, Del Dios, Lake Hodges, and the San Pasqual Valley (SDCSD 2022). Law enforcement services include general patrol, criminal investigation, crime prevention, juvenile services, narcotics and gang investigations, communications and dispatch, and various management support services (City of San Marcos 2012a). Services are available 24 hours a day, 7 days a week.

The San Marcos Station serves more than 111,000 residents and staffs more than 100 deputies, volunteers, and professional staff members (SDCSD 2022). Additionally, Community Oriented Police and Problem Solving teams are assigned to investigate community quality-of-life issues (SDCSD 2022). Lastly, the Sheriff’s San Marcos Station has the only ASTREA (Sheriff’s Aviation) helicopter landing pad in the County, which provides assistance to ground units and extends the range deputies can patrol (SDCSD 2022).

The County Sheriff’s Department does not set response time goals. The Sheriff’s Department does, however, prioritize different types of calls to better facilitate deputy dispatches. The Sheriff Department’s priority categories are as follows: priority level 1 (lifesaving response calls), priority level 2 (expeditious response calls within confines of vehicle codes), priority level 3 (calls responded to as soon as possible), and priority level 4 (calls responses to when clear, still being alerted to violations that require immediate law enforcement action) (City of San Marcos 2012a).

Schools
According to the City’s General Plan, Land Use and Community Design Element, primary education throughout the City is served b y the San Marcos Unified School District (SMUSD) (City of San Marcos 2012a ). The SMUSD is approximately 44 square miles and serves the City, portions of the City of Carlsbad, the City of Escondido, the City of Vista, and unincorporated areas of the County (SMUSD 2021). As of 2021, there were 10 elementary schools, 1 K–8 school, 1 K–8 International Baccalaureate World School, 3 middle schools, 2 comprehensive high schools, 1 continuation high school (which includes an adult transition program) , and 1 independent high school program that are a part of the SMUSD. There are approximately 19,767 students enrolled in the SMUSD (SMUSD 2021).

Using the address of a business site immediately adjacent to the south east of the project site, it was determined through SMUSD’s school locator web application (SMUSD 2022a) that the project site falls within the following school boundaries (Appendix M, Gran Vista Specific Plan):
▪ Paloma Elementary School (serving grades K–5), located at 660 Camino Magnifico, San Marcos, California, 92069—approximately 1 mile north of the project site
▪ San Marcos Middle School (serving grades 6–8), located at 650 W Mission R oad, San Marcos, California, 92069—approximately 1 mile east of the project site
▪ Mission Hills High School (serving grades 9 –12), located at 1 Mission Hills Court, San Marcos, California, 92069—approximately 3 miles from the project site
Parks
The purpose of the City’s Parks, Recreation, a nd Community Health Element of the General Plan is to provide recreational opportunities, which contribute to the health and well -being of the residents of San Marcos , and to provide goals and policies that outline the role recreational amenities plan in achieving the City’s vision for the future (City of San Marcos 2012b).

3.13 – PUBLIC SERVICES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.13-3
There are 24 community parks, 13 neighborhood parks, and 3 recreation centers located throughout the City (City of San Marcos 2022b) . The City residents in the project area are currently served by several nearby parks.

Specifically, the closest park to the project site is Innovation Park located at 1151 Armorlite Drive, which is located

0.6 miles southeast of the project site . Innovation Park consists of a dog park, restrooms, picnic tables, play equipment, and pickleball courts (City of San Marcos 20 22b). Other nearby parks include Mission Sports Park , located approximately 0.5 miles southeast of the project site, and Creek Park, located approximately 0.4 miles east of the project site.

Libraries
The City is served by the San Diego County Library, San Marcos Branch, which is located at 2 Civic Center Drive, approximately 2 miles east of the project site (City of San Marcos 2023b). The San Marcos Branch is 15,394 square feet (sf) (City of San Marcos 201 2a), contains a MakerBot 3D printer and a 28-person capacity meeting room, is Americans with Disabilities Act accessible, and is open 7 days a week (prior to closures resulting from the 2020 COVID-19 pandemic) (San Diego County Library 2022).

3.13.2 Regulatory Setting
This section provides an overview of the applicable federal, state, and local regulations governing public services.

Federal
There are no federal codes, policies, or regulations regarding public services that would apply to the proposed project.

State
Quim by Act
Since the passage of the 1975 Quimby Act (California Government Code Section 66477), cities and counties have been authorized to pass ordinances requiring that developers set aside land, donate conservation easements, or pay fees for park improvemen ts. Revenues generated by the Quimby Act cannot be used for the operation and maintenance of park facilities. The goal of the Quimby Act was to require developers to help mitigate the impacts of property improvements. The act gives authority for passage of land dedication ordinances only to cities and counties.

California Fire Code
The California Fire Code (CFC) and Office of the State Fire Marshal provide regulations and guidance for local agencies in the development and enforcement of fire safety standards. The CFC also establishes minimum requirements that would provide a reasonable degree of safety from fire, panic, and explosion.

Senate Bill 50 —Leroy F . Greene Schools Facilities Act of 1998 Senate Bill (SB) 50, or the Leroy F. Greene School Faci lities Act of 1998, restricts the ability of local agencies to deny project approvals on the basis that public school facilities (classrooms, auditoriums, etc.) are inadequate.

School fees are also collected at the time when building permits are issued. Payment of school fees is required by SB 50 for all new residential development projects and is considered full and complete mitigation of any school impacts (Government Code Section 65996). As required by SB 50, school impact fees are payments to offset capital

3.13 – PUBLIC SERVICES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.13-4
cost impacts associated with new developments, which result primarily from costs of additional facilities, related furnishings and equipment, and projected capital maintenance requirements. As such, agencies cannot require additional mitigation for any school impacts. School impact fees and fees collected pursuant to SB 50 are collected at the time when building permits are issued.

Local
San Marcos Municipal Code Chapter 17.36 —Park and Recreational Development Construction Unit Fee
San Marcos Municipal Code (SMMC) Chapter 17.36, Park and Recreational Development Construction Unit Fee, describes the need for developers of dwelling units within the City to pay applicable fees toward the City for the planning, acquisition, improvement, expansion , and oper ation of pub lic parks, playgrounds, and recreational facilities to help mitigate the potential impacts on recreational facilities due to population increases (City of San Marcos 2022c). The payment of fees shall be collected prior to the issuance of building permit by the City.

San Marcos Municipal Code Chapter 17.44 —Development Services and Public Facilities Exactions, Fees and/or Costs
SMMC Chapter 17.44, Development Services and Public Facilities Exactions, Fees and/or Costs , describes the payment of fees toward public services, facilities, and infrastructure in the City to mitigate increased demand on these facilities due to development of dwelling units (City of San Marcos 2022d). The developer of new dwelling units in the City would pay development service fees to the City alongside submission of an application for grading, construction, building, and/or development permit or entitlement by any person, or at the time of permit issuance, as specified by the City (City of San Marcos 2021b).

San Marcos Municipal Code Chapter 17.52 —School Fees and Land Dedication SMMC Chapter 17.52, School Fees and Land Dedication , describes the school facility fee dedications needed in the City to alleviate potential overcrowding in schools resulting from increased population from the development of dwelling units (City of San Marcos 2022e).

The City may require, as a condition to the approval of a residential development, the dedication of land, the payment of fees in lieu, or a combination of both, as determined by the decision-making body during the hearings and other proceedings, on specific residential development applications falling within their respective jurisdiction.

Prior to imposition of the fees and/or dedications of land, it shall be necessary for the decision-making body acting on the application to make the following findings:
▪ The City’s General Plan provides for the location of public schools. ▪ The land or fees, of both, transferred to a school district shall be used only for the p urpose of providing interim elementary, junior high, or high school classroom and related facilities as defined by the governing body of the district.
▪ The location and amount of land to be dedicated or the amount of fees to be paid, or both, shall bear a reasonable relationship and would be limited to the needs of the community for interim elementary, junior high, or high school facilities and shall be reasonably related and limited to the need for schools caused by the development.
▪ The facilities to be constructed, purchased, leased, or rented from such fees or the land to be dedicated or both is consistent with the City’s General Plan.

3.13 – PUBLIC SERVICES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.13-5
City of San Marcos General Plan
Land Use and Community Design Element
The following are applicable goals and policies from the City ’s General Plan, Land Use and Community Design Element, related to public services (City of San Marcos 2012a):

Goal LU-8: Ensure that existing and future development is adequately serviced by infrastructure and public services.

Policy LU-8.1: New development shall pay its fair share of required improvements to public facilities and services.

Policy LU-8.2: Promote development timing that is guided by the adequacy of existing and/or expandable infrastructure, services, and facilities.

Goal LU -10: Fire protection, emergency services, and law enforcement . Provide effective, high -quality and responsive services.

Policy LU -10.1: Provide demand -based fire -fighting and emergency medical services infrastructure, equipment, and personnel to provide a high level of fire, emergency medical, and law enforcement service in San Marcos to meet existing and future demands.

Policy LU-10.2: Work closely with the County of San Diego Sheriff’s Department to determine and meet the community needs for adequate personnel, equipment and state -of-the-art technology to effectively combat crime, and meet existing and projected service demands.

Policy L U-10.3: Continue to conduct Public Outreach and education regarding fire safety and crime prevention within San Marcos.

Goal LU-11: Schools: Ensure all residents have access to high-quality education.

Policy LU-11.1: Collaborate with the local public school district (SMUSD), private schools, and institutions of higher learning to ensure a range of traditional and distance-learning educational opportunities are provided in superior, accessible facilities that complement the surrounding land uses.

Policy LU-11.2: Work with San Marcos Unified School District and developers to ensure adequate school facilities are funded as required by State law and through developer mitigation agreements between the school district and the developer. The City shall require a “w ill serve” letter substantiating that the developer has paid fees to the satisfaction of the school district prior to issuance of building permits.

Goal LU-12: Libraries. Provide library resources and services that meet the needs of the community.

Policy LU-12.1: Provide adequate library facilities and technological access that enhance San Marcos’s quality of life and create a civic environment with vast opportunities for self-learning and academic enrichment.

Policy LU-12.2: Accommodate technology needs of the community and locate accessible technology in the library.

3.13 – PUBLIC SERVICES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.13-6
Safety Element
The following are applicable goals and policies from the City’s Marcos General Plan, Safety Element related to public services, including fire protection, police protection, parks, and libraries (City of San Marcos 2012c):

Goal S-3: Minimize injury, loss of life, and damage to property resulting from structural or wildland fire hazards.

Policy S -3.1: Require development to be located, designed and constructed to provide adequate defensibility and reduce the risk of structural loss and life resulting from wildland fires.

Development will consider hazards relative to terrain, topography, accessibility and proximity to vegetation. One such provision for development to minimize the risk of structural loss and life shall be the inclusion of overhead fire sprinklers.

Policy S-3.2: Provide sufficient level of fire protection service to reduce risk from urban and wildland fire.

Advocate and support regional coordination among fire protection and emergency service providers.

Policy S-3.3: Require development to provide additional access roads when necessary to provide for safe access of emergency equipment and civilian evacuation concurrently.

Policy S-3.4: Coordinate with fire protection and emergency service providers to assess fire hazards before and after wildfire events to adjust fire prevention and suppression needs, as necessary, commensurate with both short- and long-term fire prevention needs.

Goal S-6: Provide neighborhood safety through effective law enforcement.

Policy S-6.1: Continue to maintain demand -based law enforcement service levels to reduce the risk of criminal activity.

Policy S-6.2: Continue public education efforts and community outreach programs to promote community involvement in crime and drug prevention.

Policy S -6.3: Use Crime Prevention through Environmental Design (CPTED) principles in the design or redevelopment of projects and buildings.

Parks, Recreation, and Community Health Element
The following are applicable goals and policies from the City ’s General Plan, Pa rks, Recreation and Community Health Element, related to parks (City of San Marcos 2012b):

Goal PR -1: Plan for, acquire, develop, and maintain a system of local parks connected through an integrated network of trails and high-quality recreational facilities.

Policy PR-1.1: Develop and maintain a complete system of public parks and recreational amenities that provide opportunities for passive and active recreation at a minimum standard of 5 acres per 1,000 residents. Parks, trails, and recreational facilitie s will enhance community livability, public health, and safety; should be equitably distributed throughout the City; and be responsive to the needs and interests of residents, employees, and visitors.

3.13 – PUBLIC SERVICES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.13-7
Policy PR-1.3: Ensure that the development of parks, tr ails, and recreation facilities and services keeps pace with development and growth within the City.

Policy PR-1.4: Promote increased access to parks and open spaces, pedestrian- and bike-oriented routes to parks and open space, greening of public rights-of-way, and a variety of active and passive uses of parks and open space.

Policy PR-1.5: Require new development to be designed and constructed in accordance with the approved Parks Master Plan to meet or exceed the City’s parkland standard of 5 acres per 1,000 residents.

Policy PR-1.6: Require new infill development to provide plazas, mini parks, or other civic spaces as part of their parkland requirement.

Policy PR-1.7: Promote park and facility design that discourages vandalism, deters crime, provides natural surveillance, and creates a safe and comfortable environment.

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10, Land Use and Planning. As detailed in Section 3. 13.4, Project Impact Analysis, the project is consistent with all applicable goals and policies pertaining to public services.

3.13.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to public services are based on Appe ndix G of the California Environmental Quality Act (CEQA) Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to public services would occur if the project would:
▪ Threshold No. 1: Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
- Fire protection
- Police protection
- Schools
- Parks
- Other public facilities

3.13.4 Project Impact Analysis
Threshold No. 1: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significa nt environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:

Fire Protection?
Residential uses were not considered at the project site in the City’s General Plan, and the land use change from Commercial to Specific Plan Area to accommodate the proposed residential development could result in an increased demand on SMFD. As analyzed in Section 3.12 Population and Housing, the project would result in

3.13 – PUBLIC SERVICES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.13-8
development of 120 residential dwelling units , housing approximately 370 residents. The estimated generation of 370 residents is calculated based on an average of 3 .08 occupants per household. The project would increase the demand on SMFD resources in comparison to development of a commercial use under the current allowed land use designation as a result of the increase of residents in the area. Although not all residents of the project would be new or additional to the City, the estimated additional numbers of residents at the project site would increase the need for fire protection services related to routine fire and emergency medical calls. The project would generate emergency calls, primarily medical, proportionally with its population. At build out, there may be as many as 44 calls per year generated by the on-site population. The addition of 1 call per 8 days to a station that is currently running approximately 17 to 18 calls per day is not considered a significant increase.

A Preliminary Fire Emergency Response Analysis prepared for the project (Appendix J to this EIR) included a response time analysis and call volume analysis. The Preliminary Fire Emergency Response Analysis (Appendix J) determined that SMFD could provide emergency response to the project site within its internal 7-minute response time from SMFD Station 1. Based on the conservative modeling in this analysis and the response times meeting the SMFD’s internal response standards, there is no response time trigger for a new fire station to be provided in closer proximity to the project site. The existing Fire Station 1 would be able to adequately respond within the City’s response time standard.

The project would be required to comply with SMFD and CFC requirements. In addition, the project would be required to comply with the City’s Development Services Fees outlined in Section 17.44.030 of the SMMC. Payment of the Development Services Fees go toward City services . The project would be required to annex into the Community Facilities District (CFD 2001-01: Fire and Paramedic), which would help support the increased demand for services on existing public services and facilities. For the reasons stated above , potential impacts to fire response time as a result of the project would be less than significant.

Police Protection ?
As discussed above under Fire Protection, the proposed residential development would develop 120 residential dwelling units, generating approximately 370 residents at the project site. Residential development at the project site would increase the demand on police protection services in comparison to the commercial uses allowed under the current land use designation because of the substantial increase in area residents. Although not all residents would be new /additional residents to the C ity, the project could increase the need for police protection services through routine police and emergency calls, and could increase the demand on the County Sheriff’s Department San Marcos Station, which would serve the project site. The San Marcos Station is located approximately 2.5 miles east of the project site.

Implementation of the project would be expected to increase the frequency of emergency and non-emergency calls to the Sheriff’s Department. However, as discussed in Section 3.13.1, Existing Conditions, more than 100 deputies, volunteers, and professional staff serve the residents of the City. Law enforcement services include general patrol, criminal investigation, crime prevention, juvenile services, narcotics and gang investigations, communications and dispatch, and various management support services. Unlike fire services, which respond solely to emergencies, law enforcement services consist of patrolling large areas 24 hours a day, 365 days a year. Police units are continuously mobile, and service calls are responded to by the nearest available mobile unit. At the San Marcos Station, patrol deputies are assigned to a geographical “beat” area, allowing deputies to become familiar with citizens and problems within their beats (SDCSD 2022). Accordingly, service ratios and response times are anticipated to remain adequate with implementation of the project. As such, the project is not expected to affect police protection such that new or physically altered governmental facilities are needed.

3.13 – PUBLIC SERVICES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.13-9
Additionally, the project would be required to comply with the City’s Development Services Fees outl ined in Section 17.44.030 of the SMMC. The project also would be required to annex into the Community Facilities District (CFD 98-01: Improvement Area No. 1 [Police Only]), which would provide funding to police services as the demand for services increases with new development. Payment of the Development Services Fees funds needed City services, which include the Sheriff’s Department.

Therefore, while the project would place a slight increased demand on police protection services, it is not anticipated that the project would result in the need for construction or expansion of existing police facilities , and impacts to police response resulting from the project would be less than significant.

Schools ?
As outlined above, the project would develop 120 residential dwelling units, generating approximately 370 residents, some of which are expected to be students. As described under Section 3.13.1, primary education throughout the City is served by the SMUSD. Paloma Elementary School (serving grades K–5), San Marcos Middle School (serving grades 6–8), and Mission Hills High School (serving grades 9–12), are the schools within the SMUSD that would be expected to serve grade-school residents at the project site. Using the SMUSD student generation rates as described in the City’s General Plan, Land Use and Community Design Element (elementary students = 0.2297, middle school students = 0.0993, high school students = 0.1234), the project would generate approximately 28 elementary school students, 12 middle school students, and 15 high school students, respectively (City of San Marcos 2012a) . This number of students generated by the project is not considered substantial.

Prior to project approval, the project would be required to obtain will-serve letters from the SMUSD or servicing schools to confirm such schools have adequate capacity. Furthermore, the project would be required to contribute development fees to SMUSD pursuant to California Education Code Section 17620 et seq. and Governme nt Code Sections 65995(h) and 65996(b), as well as SMMC Section 17.52.050. The project developer/applicant would be required to pay the school mitigation fees that are in effect at the time of building permit issuance, unless a direct agreement otherwise has been made with the SMUSD. The current school fee for residential development required by SMUSD is $4.08 per square foot; however, this fee amount could change between the drafting of this EIR and the time of building permit issuance (SMUSD 2022b). Further, consistent with General Plan Policy LU-11.2, the project would be required to provide a letter from the school district(s) to the City prior to the issuance of building permits confirming these fees have been paid (City of San Marcos 2012a). 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 any legislative or adjudicative act...on the provision of adequate school facilities” (Government Code Section 65995(h)). As such, with contribution of required development fees, impacts to schools as a result of the project would be less than significant.

Parks?
As previously described, the project would develop 120 residential dwelling units , generating approximately 370 residents. This increase in residents would increase demands for neighborhood and regional parks and other recreational facilities. Assuming 5 acres of park space per 1,000 residents (the minimum standard goal of the City’s General Plan discussed in Section 3.1 3.2, Regulatory Setting ), the addition of 370 residents at the project site equates to a dem and of approximately 1.85 acres of public park space generated by the proposed residential development. Pursuant to the City’s Multifamily Residential Development Design Guidelines, an area equal to 30% of livable ground floor area of all units shall be provided as common open space. For the project, this equates to 24,431 sf of common open space. As outlined in the Gran Vista Specific Plan (Appendix M), since the main living

3.13 – PUBLIC SERVICES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.13-10
areas proposed for all floor plans occur on the second floor, the common open sp ace requirement has been calculated based upon the second floor’s square footage. As calculated, the project would provide 92,645 sf of common open space area, which exceeds this requirement. Additionally, SMMC provides specific requirements for children’s amenities on site for multifamily residential projects. The total required children’s amenities for the project would be 2,720 sf, and the project proposes to include 5,811 sf, which exceeds the City’s requirement. In addition to common open space, the project would provide an average of 130 sf of private open space per unit in the form of a deck or patio. Amenities on site would include tot lots and recreational areas, a dog park, a community garden, and landscaped pedestrian paths. The provided common and private open space areas would further offset demand on existing recreational facilities in the City, as required by the SMMC (Section 20.215.050).

The project would be required to pay the City’s Public Facility Fees (PFFs), which are required of all projects that increase the demand for park and recreation needs in the City . The PFF would be used for developing public neighborhood and regional parks and recreational facilities, as outlined in the City’s Parks Master Plan Update (City of San Marcos 2018). The provision of usable common open space, private open space, and payment of the PFF would maintain the City’s service standard for parks within the City.

Therefore, impacts related to the use of park facilities would be less than significant. Further details regarding parks and recreation can be found in Section 3.14, Recreation.

Other Public Facilities?
The project would develop 120 units, generating approximately 370 residents at the project site . Although not all of these residents would be new residents to the City, the generation of residents at the project site would increase the demands on other public facilities, including library services and additional resources in comparison to the project site’s current commercial land use designation . However, additional library services are available in the County through a cooperation of County libraries, independent city libraries, and the Imperial County Library, which collectively form the Serra Library System. This system en ables County library cardholders to check out library materials from the other Serra member libraries (Serra Cooperative Library System 2016). In addition, community members can purchase a community borrower card to obtain borrowing privileges at the California State University San Marcos campus (California State University San Marcos 2023). Community members can also borrow materials at Palomar College with a valid picture ID and proof of current mailing address (Palomar College 2021). These additional lib rary resources are located in the San Marcos community and provide more than 200,000 sf of additional library space. Therefore, impacts to other public facilities in the City as a result of the project would be less than significant.

3.13.5 Cumulative Impact Analysis
Fire Protection Services
The geographic area for the cumulative analysis of fire protection and emergency services consists of those areas that are serviced by the SMFPD. The cumulative projects that fall within this geographic area would add to the increased demand for fire protection and emergency services. The SMFPD provides service to the City and has existing automatic mutual aid fire agreements in place with the cities of Carlsbad, Vista, Escondido, Encinitas, and the Rancho Santa Fe Fire Protection District.

3.13 – PUBLIC SERVICES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.13-11
As discussed in Section 3.13.4 above, the project would increase the demand on SMFD resources in comparison to development of a commercial use under the current allowed land use because of the increase of residents i n the area. The project in addition to cumulative projects could increase the need for fire protection services through routine fire and emergency medical calls, and would increase the demand on SMFD stations, specifically Station 1 which would serve the project site.

However, similar to the project, cumulative projects would be required to comply with SMFD and CFC requirements.

Additionally, the developer/applicant of cumulative projects would be required to comply with the City’s Development Services Fees outlined in Section 17.44.030 of the SMMC. Payment of the Development Services Fees fund City services, which include the Fire Protection District.

Furthermore, the Preliminary Fire Emergency Response Analysis prepared for the project (Appendix J to this EIR) determined that SMFD could provide emergency response to the project site within its internal 7 -minute response time, and development at the project site would not trigger the need for a new fire station closer to the project site.

Therefore, the project would not result in substantial adverse physical impacts associated with the provision of new or physically altered facilities. Cumulative projec ts are anticipated to prepare similar analyses and provide mitigation if the response time cannot be met. Therefore, cumulative impacts to fire protection as a result of the project would be less than significant.

Police Protection Services
The geographic area for the cumulative analysis of police protection is those areas that are serviced by the San Marcos Sheriff’s Department. All cumulative projects would result in an increased demand for police protection services from the San Marcos Sheriff ’s Department. The project site would be served by the San Marcos Station, located approximately 4 miles from the project site. As discussed in Section 3.13.4, the project would not result in substantial adverse physical impacts associated with the provision of new or physically altered facilities. Therefore, cumulative impacts to police protection services would be less than significant.

For informational purposes, c umulative projects could result in additional demand for police protection services and the potential need for additional police protection resources. Similar to the project, all cumulative projects would be required to offset increased demand to police protection services through the payment of Development Services Fees , which go toward City services including the Sheriff’s Department. These fees would provide for additional staff and equipment to assist in the provision of law enforcement services.

Schools
Cumulative projects that have a residential component would generate students that need to be accommodated by either the SMUSD or another school district in the area. As discussed in Section 3.13.4, the project would be required to contribute development fees to the SMUSD, pursuant to California Education Co de Section 17620 et seq. and Government Code Sections 65995(h) and 65996(b), as well as SMMC Section 17.52.050. Furthermore, will-serve letters from the SMUSD or servicing schools would be required to confirm such schools have adequate capacity to serve gr ade-school students generated by residential development. This would apply to similar cumulative projects as well. 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. As such, with contribution of required development fees by the project and cumulative projects, cumulative impacts to schools would be less than significant.

3.13 – PUBLIC SERVICES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.13-12
Parks
The project and the cumulative projects in the City would add to the cumulative demand for park and recreation facilities in the City. All residential projects that increase the demand for park and recreation needs in the City are required to provide park space and/or pay park in lieu -fees. The environmental documentation prepared for each project would analyze impacts associated with the construction of any parks within each overall development footprint. As discussed in Section 3.13.4, the project developer/applicant would be required to pay the City’s PFF, required of all projects that increase the demand for park and recreation needs in the City, and which is used for developing neighborhood and regional parks. It is expected that all cumulative projects that increase demand for parks and recreation needs would also be required to pay these fees. It is also anticipated that similar to the project, all cumulative residential projects would provide on-site open space and/or recreational amenities consistent with the requirements of the SMMC (Section 20.215.050). With payment into the City’s PFF and incorporation of on-site recreation, cumulative impacts on recreational facilities in the City would be less than significant.

Libraries
Cumulative projects within the service s area of the San Marcos Branch Library would potentially result in an increased demand for library services. Aside from the San Marcos Branch, additional library services are available in the County through the Serra Library System. In addition, community members can get borrowing privileges at the California State University San Marcos campus and Palomar College. These additional library resources provide more than 200,000 sf of additional library space. Therefore, cumulative impacts to library facilities in the City as a result of the project would be less than significant.

3.13.6 Mitigation Measures
No significant impacts to public services were identified; thus, no mitigation measures are required.

3.13.7 Conclusion
As analyzed above, the project would develop 120 residential units, generating approximately 370 residents at the project site . This would result in an increased demand for fire protection, emergency medical services, police protection, school services, and library facilities. However, the project and cumulative projects would be required to comply with applicable regulations and pay all applicable development fees discussed above, including payment of school mitigation fees 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; payment toward the City’s Development Services Fees outlined in Section 17.44.030 of the SMMC, which goes toward City services that include the fire and police services; and payment of the City’s PFF required of all projects that increase the demand for park and recreation needs in the City to avoid direct and cumulative impacts to schools and parks. With compliance with applicable regulations and payment of the applicable fees outlined above, direct and cumulative impacts to public services would be less than significant.

3.14 – RECREATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.14-1

3.14 Recreation
This section describes the existing recreation setting of the project site, identifies associated regulatory requirements, and evaluates potential impacts related to implementation of the Proposed Gran Vista Specific Plan Project (project).

Table 3.14-1 summarizes the project- and cumulative-impact analysis by threshold for the project.

Table 3.14-1. Recreation Summary of Impacts
Threshold of Significance
Project Direct
Impact
Project
Cumulative
Impact
Significance
Determination
No. 1 – The project increases the use of existing
neighborhood and regional parks or other recreational
facilities such that substantial physical deterioration of the facility would occur or be accelerated.

Less than
Significant
Less than
Significant
Less than
Significant
No. 2 – The project includes recreational facilities or requires the construction or expansion of recreational
facilities which might have an adverse physical effect on the environment.

Less than
Significant
Less than
Significant
Less than
Significant

3.14.1 Existing Conditions
This section describes existing park s, recreation facilities, and trails on the project site and in the project vicinity.

The City of San Marcos has more than 290 acres of park land and 37 parks (City of San Marcos 2022). The City of San Marcos’s Parks Master Plan classified parks into eight categories: Regional Park ; Community Park ; Neighborhood Park ; Mini (Urban) Park ; Special Use Facility; Historical, Monument, and Memorial ; Recreation Center; and Aquatic Center (City of San Marcos 2018). Details on each of these park categories are details below.

Regional Parks
Regional Parks are defined as parks that are a minimum of 50 acres, with 75 or more acres being optimal (City of San Marcos 2018). The drive time to a Regional Park is approximately 1 hour or less, and offers a variety of terrain, scenic views, cultural amenities, and extensive natural areas with both passive and active opportunities.

Community Parks
Community Parks are defined as parks that are a minimum of 10 acres and up to 100 acres (City of San Marcos 2018). Community Parks serve two or more neighborhoods with a service area of 0.5 to 3 miles.

There are five Community Parks in the City of San Marcos: Bradley Park, Woodland Park, Walnut Grove Park, Discovery/Lakeview Park, and Double Peak Park. Bradley Park, Walnut Grove Park, Discovery/Lakeview Park, and Double Peak Park would serve the project site because the project site is within the service area of these four parks. Bradley Park is the closest to the project site and is approximately 1 mile southwest of the project site.

3.14 – RECREATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.14-2
Neighborhood Parks
Neighborhood Parks are defined as parks that are generally 5 acres, although 7 to 10 acres is optimal (City of San Marcos 2018). Neighborhood Parks have a service area of 0.25 to 0.5 miles and should be accessible by arterial roads. There are 14 Neighborhood Parks in San Marcos : Buelow Park, Connors Park, Hollandia Park, Innovation Park, Knob Hill Park, Jacks Pond Park, Cerros de La s Posas Park, Mission Sports Park, Montiel Park, Mulberry Park, Richmar Park, San Elijo Park, Simmons Family Park, and Sunset Park.

Mini (Urban) Parks
Mini (Urban) Parks are defined as parks that are 2,500 square feet to 1 acre in size, although a park ar ea of less than 5 acres could be considered a Mini Park (City of San Marcos 2018). A Mini Park’s service area is 0.25 miles or less and is in a residential setting. There are 18 Mini (Urban) P arks in San Marcos : Alder Glen Park, Amigo Park, Bougher Park, Children’s Park, Civic Center Park, Creek View Park, Discovery Meadows, Foothill Park, The Laurels Park, Optimist Park, Pebblestone Park, Quail Valley Park, Questhaven Park, Regency Hills Park, Ridgeline Trailhead, Santa Fe Hills Park, Summer Hill Park, and Valley View Park.

Special Use Facility
A Special Use Facility includes three categories of facilities (City of San Marcos 2018):
▪ Historic/Cultural/Social Sites – A unique local resource offering historical, education al, and cultural opportunities. Examples include historic downtown areas, performing arts parks, arboretums, display gardens, performing arts facilities, indoor theaters, churches, public buildings, and amphitheaters. ▪ Recreation Facilities – A specialized or single -purpose facility. Examples include community centers, senior centers, community theaters, hockey arenas, marinas, golf courses, and aquatic parks. ▪ Outdoor Recreation Facilities – Examples include tennis centers, softball complex es, sports stadiums, skateboard parks, and bark parks.

The size and service area of a Special Use Facility varies greatly.

Historical, Monuments , and Memorials
Historical, Monuments, and Memorials parks preserve monuments and memorials, provides programmed historical interpretation, attracts tourists , and offers passive recreation opportunities (such as trails) (City of San Marcos 2018). The size and service area varies.

Recreation Centers
Recreation Centers are intended to provide indoor leisure facilities and programs at a reasonable cost. Recreation centers also serve as meeting facilities for local social gatherings and public events, and are designed to be a hub of recreation activity (City of San Marcos 2018). The size and service area varies.

Aquatic Centers
Aquatic Centers are swimming facilities that provide active recreation for resident. The size of these facilities varies. The service area is a minimum population of 25,000, and the recommended level of service is one Aquatic Center site per 40,000 persons in San Marcos (City of San Marcos 2018).

3.14 – RECREATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.14-3
Trails
The City of San Marcos (City) currently owns and manages 63 miles of completed trails , with plans to expand the trail network to 72 miles (City of San Marcos 2018). The goal of the trail system is t wo-fold: to serve as a recreational amenity, and to provide an alternative means of circulation for non -motorized travelers through an inter-linked citywide system of trails connecting residential neighborhoods to parks, schools, colleges, stores, restaurants, movie theaters, other important destinations within San Marcos, and the wider regional trails system.

3.14.2 Regulatory Setting
This section describes the federal, state, and local laws and regulations that are applicable to recreation and the project.

Federal
There are no federal codes, policies, or regulations regarding recreation that would apply to the proposed project.

State
Quimby Act
Since the passage of the 1975 Q uimby Act (California Government Code Section 66477), cities and counties have been authorized to pass ordinances requiring that developers set aside land, donate conservation easements, or pay fees for park improvements. Revenues generated by the Quimby A ct cannot be used for the operation and maintenance of park facilities. The goal of the Quimby Act was to require developers to help mitigate the impacts of property improvements. The act gives authority for passage of land dedication ordinances only to cities and counties.

Landscape and Lighting Act of 1972
The Landscape and Lighting Act of 1972 enables cities, counties , and special districts to landscape and light public areas for parks, recreation facilities, and open space. A local government may also use the assessments to pay for improvements and maintenance in these areas.

Mello -Roos Community Facilities Act
The Mello -Roos Community Facilities Act (Government Code Section 53311 et seq.) is a tax -based financing method available to cities, counties, and special districts. It authorizes local governments to establish community facilities districts within which they may levy special taxes and issue bonds to finance open space acquisition, maintenance, and other programs. Approval of the specia l tax and any related bond issue requires approval by two-thirds of the district electorate.

Local
San Marcos Municipal Code Chapter 17.36 – Park and Recreational Development Construction Fee As described in Chapter 17.36 , Park and Recreational Development Construction Unit Fee , of the San Marcos Municipal Code (SMMC), the continued increase in the development of dwelling units and population within San Marcos has created the need for planning, acquisition, improvement, expansio n, and operation of public

3.14 – RECREATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.14-4
parks, playgrounds, and recreational facilities , and thus the need for additional revenue with which to finance such facilities. This chapter of the SMMC requires that each builder of each dwelling unit to be constructed within San Marcos must, prior to the construction, pay a fee, as adopted by Resolution by the City Council.

San Marcos Municipal Code Chapter 17.44 – Development Services and Public Facilities, Exaction, Fees, and/or Costs
The City recognizes that the continued development of property within the City ’s jurisdictional boundaries has resulted in an increased demand on existing public services, facilities , and infrastructure; the need for expansion of public services, facilities , and infrastructure; and/or the need for the installation of new public services, facilities, and infrastructure. It is the intent of the City that each applicant for a grading, construction, building , and/or development permit or entitlement must, prior to the issuance of such perm it or entitlement, pay a Public Facilities Fee. The funds generated by the payment of fees described Chapter 17.44 are deposited into separate accounts established for the purposes of maintaining, expanding, and installing public infrastructure. Such publi c infrastructure includes active and passive open space and parks.

City of San Marcos General Plan
Parks, Recreation, and Community Health Element
The following are applicable goals and policies from the City of San Marcos General Plan, Parks, Recreation, and Community Health Element (City of San Marcos 2012):

Goal PR -1: Plan for, acquire, develop, and maintain a system of local parks connected through an integrated network of trails and high-quality recreational facilities.

Policy PR-1.1: Develop and maintain a complete system of public parks and recreational amenities that provide opportunities for passive and active recreation at a minimum standard of 5 acres per 1,000 residents. Parks, trails, and recreational facilities will enhance community livability , public health, and safety; should be equitably distributed throughout the City; and be responsive to the needs and interests of residents, employees, and visitors.

Policy PR-1.3: Ensure that the development of parks, trails, and recreation facilities and services keeps pace with development and growth within the City.

Policy PR-1.4: Promote increased access to parks and open spaces, pedestrian- and bike-oriented routes to parks and open space, greening of public rights -of-way, and a variety of active and passive uses of parks and open space.

Policy PR-1.5: Require new development to be designed and constructed in accordance with the approved Parks Master Plan to meet or exceed the City’s parkland standard of 5 acres per 1,000 residents.

Policy PR-1.6: Require new infill development to provide plazas, mini parks, or other civic spaces as part of their parkland requirement.

Policy PR -1.7: Promote park and facility design that discourages vandalism, deters crime, provides natural surveillance, and creates a safe and comfortable environment.

3.14 – RECREATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.14-5
The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.1 0, Land Use and Planning, of this environmental impact report (EIR) . As detailed in Section 3.10 .4, the project is consistent with the applicable goals and policies pertaining to recreation.

Parks Master Plan
The City adopted its first Parks Master Plan in 1990, which presented a vision of parks and recreation facilities for the City. Since that time, the City has changed significantly, so a Master Plan Update was adopted in 201 8. The goal of the Parks Master Plan Update is to identify potential improvemen ts to the park system and, as funding becomes available, suggest additional amenities for new parks and improvements to existing park facilities (City of San Marcos 2018).

Master Trails Plan
The City’s Master Trails Plan, adopted in 1991, details a trails implementation strategy and description of each proposed trail segment. The plan envisions a system of connectivity through trail corridors networked across San Marcos. To meet this goal, the Master Trails Plan recommends the creation of 72 miles of trail s that will provide an alternative means of circulation and recreational opportunities to San Marcos residents and visitors.

These trails will include 21 miles of urban trails, 36 miles of multiuse trails, and 15 miles of soft-surface trails that connect neighborhoods to parks, schools , and workplaces, as well as to the trails systems of neighboring cities and the County of San Diego (City of San Marcos 1991).

3.14.3 Thresholds of Significance
The significance criteria used to evaluate project impacts to recreation are based on Appendix G of the California Environmental Quality Act ( CEQA) Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to recreation would occur if the project would:
▪ Threshold 1: Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. ▪ Threshold 2: Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

3.14.4 Project Impact Analysis
Threshold 1: Would the project increase the use of existing ne ighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? According to the State of California Department of Finance, there are approximately 3. 08 persons per housing unit in San Marcos (DOF 2021). The project proposes development of 120 residential dwelling units , which is estimated to generate approximately 370 residents using the California Department of Finance ’s 3.08 persons per household unit estimate (see Section 3.12, Population and Housing , of this EIR ). This increase in residents would increase demands for neighborhood and regional parks and other recreational facilities. Assuming 5 acres of park space per 1,000 residents (the minimum stand ard goal of the City’s General Plan , discussed in Section 3.14.2, Regulatory Setting ), the addition of project residents equates to a demand of approximately

1.85 acres of public park space generated by residents of the project site.

3.14 – RECREATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.14-6
As described in Secti on 3.12 of this EIR, pursuant to the City’s Multifamily Residential Development Design Guidelines, an area equal to 30% of livable ground floor area of all units must be provided as common open space. For the proposed project, this equates to 24, 431 square feet of common open space. As outlined in the Gran Vista Specific Plan (Appendix M), because the main living areas proposed for all floor plans occur on the second floor, the common open space requirement has been calculated based on the second floor’s sq uare footage. As calculated, the project would provide 92,645 square feet of common open space area, which exceeds the requirements of the Design Guidelines . Additionally, the SMMC provides specific requirements for children’s amenities on site for multifamily residential projects. The total required children’s amenities for the project would be 2,720 square feet, and the project proposes to provide 5,811 square feet, which exceeds the City’s requirement. In addition to common open space, the project would provide an average of 130 square feet of private open space per unit in the form of a deck or patio. Amenities on site would include tot lots and recreational areas, a dog park, a community garden, and landscaped pedestrian path s. These provided common and private open space area s would further off -set demand on existing recreational facilities in San Marcos, as required by SMMC Section 20.215.050.

In total, the project would provide 2.12 acres of useable common open space area with grades of less than 10 %, as outlined in Figure 2.2, Distribution of Allowable Uses, in the Gran Vista Specific Plan (Appendix M).

In addition to the proposed open space and amenities on site, the project would be required to pay the City’s Public Facility Fees (PFF s), as applicable, required of all projects that increase the demand for park and recreation needs in the City. PFF s go toward the acquisition and development of local and community park facilities throughout San Marcos to offset the demand on public park spac e, as described in SMMC Chapters 17.36 and 17.44. Payment of the PFF would be made prior to City issuance of the first building permit for the project . Therefore, payment , which would ultimately contribute to development of new parks and recreational facil ities, would offset the increase in demand of parks and recreational facilities generated by residential development at the project site, such that existing facilities would not substantially deteriorate .

Therefore, project impacts to existing neighborhood and regional parks would be less than significant.

Threshold 2: Would the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? As stated under Threshold 1, the project would provide 2.12 acres of useable common open space area with amenities on site that include tot lots and recreational areas, a dog park, a community garden, and landscaped pedestrian paths. The project’s proposed open space amenities are analyzed as part of this EIR. Furthermore, the project developer would be required to pay the City’s PFF, which would go toward the acquisition and development of local and community park facilities throughout San Marcos to offset the demand on public park space. Therefore, impacts related to the construction or expansion of recreational facilities would be less than significant.

3.14.5 Cumulative Impact Analysis
The project, in addition to cumulative projects, would increase the demand for park and recreation facilities in San Marcos . Similar to the proposed project, a ll cumulative projects that increase the demand for park and recreation needs would be required to provide park space and/or pay the City’s PFF. Furthermore, any substantial expansion or development of new recreational facilities would be subject to the appropriate CEQA environmental review, which would identify and address any site -specific impacts. Therefore, with payment of the City’s PFF and project-specific environmental review, cumulative impacts to recreational facilities would be less than significant.

3.14 – RECREATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.14-7

3.14.6 Mitigation Measures
No significant impacts to recreation were identified; thus, no mitigation is required.

3.14.7 Conclusion
As analyzed in Section 3.14.4 , Project Impact Analysis , the project is required to present site plans outlining proposed open space and recreational am enities on site, and the project applicant/developer would be required to pay the City’s PFF. Payment would be determined by the City based on the presented plans for the site. As described above, developer payment of the PFF would go toward the acquisitio n and development of local and community park facilities throughout San Marcos to offset the demand on public park space. With payment of the PFF and provision of the proposed on-site open space , impacts related to recreation would be less than significant .

3.14 – RECREATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.14-8

INTENTIONALLY LEFT BLANK

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-1

3.15 Transportation
This section describes the transportation impact analysis for the proposed Gran Vista Specific Plan Project (project).

It includes a description of existing traffic conditions, trip generation for the project, traffic modeling, and identification of mitigation measures. This section is based on the Local Transportation Analysis (LTA), and Vehicle Miles Traveled (VMT) Analysis Technical Memorandum prepared by CR Associates in February 2023. These reports are included as Appendix K-1 and K-2 to this environmental impact report (EIR), respectively.

Table 3.15-1 summarizes the project- and cumulative-level impact analyses by threshold.

Table 3.15-1. Transportation Summary of Impacts
Threshold of Significance
Project -Level
Impact
Cumulative -
Level Impact
Significance
Determination
No. 1: Conflict with a program plan, ordinance,
or policy addressing the circulation system,
including transit, roadway, bicycle and
pedestrian facilities.

Less than
Significant
Less than
Significant
Less than
Significant
No. 2: Conflict or be inconsistent with CEQA
Guideline section 15064.3, subdivision (b).

Potentially
Significant
Significant and
Unavoidable
Significant and
Unavoidable
No. 3: Substantially increase hazards due to a
geometric design feature (e.g., sharp curves or
dangerous intersections) or incompatible uses
(e.g., farm equipment).

Less than
Significant
Less than
Significant
Less than
Significant
No. 4: Result in inadequate emergency access. Less than Significant
Less than
Significant
Less than
Significant

3.15.1 Existing Conditions
This section describes the existing circulation and transportation system in the project area and the methodology used to prepare the transportation analysis.

Project Location
The approximately 7.6-acre project site is surrounded by existing development located in the northwestern portion of the City of San Marcos (City), at the northwest corner of N Las Posas Road and W Mission Road. The project site is bounded by N 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 north and west, as well as to the east across N Las Posas Road . Nearby land uses in the vicinity of the project site include industrial and commercial uses to the south and east , the Santa Fe Hills residential community to the north, and Palomar College approximately 0.2 miles to the east. The closest freeway is State Route 78 located approximately 0.4 miles south of the project site.

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 Amendment and Rezone to change the land use designation to Specific Plan Area (SPA).

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-2
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, a public community col lege consisting of a 200-acre campus, is located east of the project site. Palomar College Transit Center, a North County Transit District (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 W Mission Road, near the main entrance to Palomar College, and a train station on the south side of W 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 W Mission Road in front of CVS. The Inland Rail Trail, a proposed 21-mile Class I bikeway, runs along the south side of W Mission Road and connects the Cities of Oceanside, Vista, San Marcos, and Escondido , as well us areas of unincorporated San Diego County.

Methodology
Transportation Impact Analysis Approach and Methodology As part of the TIA prepared for the project, t he vehicle miles traveled (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 (City of San Marcos 2020). Improvements should be identified for any study facilities that do not meet City LOS standards to increase performance to acceptable or pre-project conditions.

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. 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 impa ct under CEQA. For informational purposes, trip generation rates and distribution information are provided from the TIA. However, the potential CEQA environmental impact of the project in terms of vehicle trips is analyzed in terms of VMT below.

VMT Metric s
Consistent with the City’s Transportation Impact Analysis Guidelines (City of San Marcos 2020) , the proposed project shall be analyzed by the following VMT metric:

VMT/Capita which includes, for all San Diego County residents, all vehicle -based resident travel grouped and summed to the home location of the individual. It includes all resident vehicle travel:
home-based and non-home-based. The VMT for each individual is then summed for all individuals residing in a particular census tract and divided by th e population of that census tract to arrive at Resident VMT/Capita. A significant impact will occur if the project generates VMT per resident greater than 85 percent of the regional average.

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-3
The City’s Transportation Impact Analysis Guidelines provide screening criteria to screen out VMT based on project size, location, provision of affordable housing, and transit availability. The City uses screening thresholds to quickly identify when a project should be expected to cause a less -than-significant impact without conducting a detailed VMT study. Relevant screening criteria for the proposed project is described below:
▪ Screening Threshold for Small Projects – Absent substantial evidence indicating that a project would generate a potentially significant level of VMT, or inconsistency with the City General Plan, projects that generate or attract fewer than 110 trips per day generally may be assumed to cause a less-than-significant transportation impact.
▪ Map-Based Screening for Residential and Office Projects – Residential and office projects located in areas that generate VMT below adopted City threshold can be presumed to have a less-than-significant transportation impact. This determination must be made by SANDAG’s [the San Diego Association o f Governments’] online residential and employment VMT maps for existing year or model baselines year VMT (whichever is available at the time analysis is being conducted), which show census tracts in the city where the VMT is below the regional average.
▪ Presumption of Less Than Significant Impact for Affordable Residential Development – Residential projects with 100 percent deed restricted affordable housing can be presumed to have a less -than-significant transportation impact. Projects can only be screened out if they are located in parts of the city that have been identified by SANDAG and the City as Smart Growth Opportunity Areas. ▪ Presumption of Less Than Significant Impact Near Transit Stations – Projects located within one-half mile walkshed of a high -quality transit area can be presumed to have a less than significant transportation impact. However, this presumption does not apply if the project:
- Has a floor area ratio (FAR) of less than 0.75;
- Includes more parking for use by residents, customers, or employees of the project than required by the City; - Is inconsistent with the City’s current General Plan, as determined by the City; or, - Replaces affordable residential units with a smaller number of moderate- or high-income residential units If a project would result in significant impacts, CEQA requires mitigation measures to be implemented to reduce or mitigate an impact. VMT is reduced by implementing strategies that reduce the number of automobile trips generated by the project, shift more trips from automobile to non-automobile modes, and/or reduce the distances that people drive. Generally, these reductions can be achieved by the implementation of transportation demand management (TDM) strategies. TDM measures focus on understanding how people make their transportation decisions and help ing people use the infrastructure in place for transit, ridesharing, walking, biking, and teleworking. The following are examples of TDM measures:
▪ Transit pass subsidies
▪ Carpool program
▪ Flexible work schedules
▪ Telework
▪ Showers, changing rooms, and secure bike parking to help employees bike to work Projects for which VMT impacts are determined to be significant are required to propose a list of VMT reduction measures and document the associated percent reduction in VMT. Mitigated project VMT is calculated by applying the percent reduction. Project VMT is then compared to the threshold of significance to determine if the project’s VMT impact has been mitigated.

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-4
Study scenarios used for traffic impact analysis are outlined below:
▪ Existing Conditions are utilized to establish the existing baseline of traffic operations within the study area. ▪ Near-Term (Interim Year 2024) Conditions are based on the SANDAG pre-established interim year scenario closest to the project’s anticipated opening year.
▪ Near-Term (Interim Year 2024) Plus Project Conditions include project-generated traffic added to interim year volumes.
▪ Horizon Year Conditions are based on the Regional Transportation Plan year, currently 2050. ▪ Horizon Year Plus Project Conditions include project-generated traffic added to horizon year traffic volumes.

Existing Street Network
Figure 5.1 of Appendix K-1 to this EIR depicts existing conditions within the transportation study area, including signalized intersections and lane configurations. The transportation study area evaluated for the project includes the following intersections and street segments, based on the anticipated distribution traffic to/from the project site:

Intersections:

N Las Posas Road and Project Driveway No. 1/Palm Road (Signal) W Mission Road and Project Driveway No. 2 (Side-Street Stop-Controlled) N Las Posas Road and W Mission Road (Signal)
Segments:

N Las Posas Road, between Palm Road and W Mission Road
N Las Posas Road, between W Mission Road and Armorlite Drive W Mission Road, between Pacific Street and N Las Posas Road W Mission Road, between N Las Posas Road and Palomar College Driveway The principal roadways in the transportation study area are described briefly below. Roadway classification was determined from a review of the General Plan Mobility Element and information gathered from field observations.

N Las Posas Road is currently constructed as a 6 -lane divided roadway betwe en the State Route 78 westbound ramps and Avenida Azul, a 4-lane divided roadway between Avenida Azul and Avenida Arana, and a 3-lane undivided roadway between Avenida Arana and Avenida Leon . The posted speed limit is 45 mph. On -street parking is prohibited. Class II bike lanes are provided. N Las Posas Road is classified as a 6-Lane Arterial between State Route 78 westbound ramps and Avenida Azul.

W Mission Road is constructed as a 4-lane undivided roadway with a two-way left-turn lane between Comet Circle and N Las Posas Road. The posted speed limit is 40 mph. On-street parking is prohibited. Class I (eastbound) and Class II (westbound) bike lanes are provided along the roadway. W Mission Road is classified as a 4 -Lane Arterial between W San Marcos Boulevard and Las Flores Drive.

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-5
Existing Traffic Volumes
Both signalized and unsignalized intersections, in addition to street segments, were analyzed as part of the local transportation analysis. These terms are described below:

Signalized intersections: Signalized intersections were analyzed under AM and PM peak hour conditions. Average vehicle delay was determined utilizing the methodology f ound in Chapter 19 of the Highway Capacity Manual 6th Edition (TRB 2016) , with the assistance of the Synchro Version 11 computer software. The delay values (represented in seconds) were qualified with a corresponding intersection LOS.

Unsignalized intersections: Unsignalized intersections were analyzed under AM and PM peak hour conditions. Average vehicle delay and LOS was determined based upon the procedures found in Chapter 20 and Chapter 21 of the Highway Capacity Manual 6th Edition (TRB 2016) with the assistance of the Synchro Version 11 computer software.

Street Segments: Street segment analysis is based upon the comparison of average daily traffic (ADT) volumes to the City’s Roadway Classification, Level of Service, and ADT Table (City of San Marcos 2012b). This table provides segment capacities for different street classifications based on traffic volumes and roadway characteristics.

Intersections
Table 3.15-2 summarizes the peak hour intersection operations under existing conditions. As seen in Table 3.15-2, all study intersections operate at LOS D or better . As explained above, LOS information is provided as part of the LTA, not in support of the CEQA analysis. LOS and other measures of vehicle capacity or traffic congestion are no longer considered to be a significant impact on the environment. For informational purposes, trip generation rates and distribution information are provided from the TIA. The potential CEQA environmental impact of the project in terms of vehicle trips is analyzed in terms of VMT.

Table 3.15-2. Existing Intersection Operations
Intersection Control Type Peak Hour
Existing
Delay LOS
N Las Posas Road/Project Driveway No. 1/Palm Road Signal AM 17.7 B PM 16.3 B
Project Driveway No. 2 and W Mission Road SSSC AM 10.2 B PM 11.1 B
N Las Posas Road and W Mission Road Signal AM 39.6 D
PM 41.2 D
Source: Appendix K-1.

Notes: LOS = level of service; SSSC =Side-Street Stop Controlled.

For SSSC intersections, the delay shown is the worst delay experienced by any of the movements.

SIGNALIZED UNSIGNALIZED

DELAY/LOS THRESHOLDS DELAY/LOS THRESHOLDS
Delay LOS Delay LOS

0.0 ≤ 10.0 A 0.0 ≤ 10.0 A

10.1 to 20.0 B 10.1 to 15.0 B

20.1 to 35.0 C 15.1 to 25.0 C

35.1 to 55.0 D 25.1 to 35.0 D

55.1 to 80.0 E 35.1 to 50.0 E
≥ 80.1 F ≥ 50.1 F

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-6
Street Segments
Table 3.15-3 summarizes the segment operations under existing conditions and the available ADT volumes from counts conducted on June 15, 2021. Counts at the study intersections, including bicycle and pedestrian counts, were conducted on June 15, 2021, between 7:00 a.m. and 9:00 a.m. and 4:00 p.m. and 6:00 p.m. As described in the LTA prepared for the project (Appendix K-1), current traffic volume counts may remain artificially depressed due to restrictions and limitations on business, school, and other activities associated with the coronavirus (COVID-19) pandemic. Therefore, current counts were compared to traffic data collected prior to 2020. All existing segments outlined below currently operate at LOS B or better under Existing Conditions.

Table 3.15-3. Existing Street Segment Operations
Street Segment Classification ADT
LOS Threshold
(LOS E) LOS V/C
North Las Posas Road
Palm Road to West
Mission Road
6-Lane Major Arterial 17,900 50,000 A 0.358
West Mission Road to
Armorlite Drive
6-Lane Major Arterial 22,000 50,000 B 0.440
West Mission Road
Pacific Street and North
Las Posas Road
4-Lane Major Arterial 17,800 40,000 B 0.445
North Las Posas Road to
Palomar College Driveway
4-Lane Major Arterial 17,800 40,000 B 0.445
Source: Appendix K-1.

Note: ADT = average daily traffic; LOS = level of service; V/C = Volume/Capacity Existing Transit Conditions
NCTD provides public transportation within the City and the County of San Diego for Coaster rail service, SPRINTER light rail service, and Breeze bus se rvice. 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 Station SPRINTER and Breeze transit station located approximately 0.3 miles from the project’s W Mission Road entrance. Transit service is provided to the project area via NCTD bus routes 304, 305, 347, and 445 and the SPRINTER.

Route 304 provides bus service along W Mission Road, with stops within the transportation study area along W Mission Road and Rancho Santa Fe Road . This route connects the Palomar College Transit Center to the Encinitas Train Station. This route provides a direct connection to Palomar College Station with transfers to SPRINTER, Route 305, Route 347, and Route 445 bus service. The route operates in 30-minute intervals between the hours of 4:53 a.m. and 8:23 p.m., Monday through Friday, and in 60-minute intervals between 6:53 a.m. and 9:05 p.m. on Saturday.

Route 305 provides bus service between Vista and Escondido, with stops within the transportation study area along W Mission Road. This route provides a direct connection to Palomar College Station with transfers to SPRINTER, Route 304, Route 347, and Route 445 bus service. The route operates in 30-minute intervals between the hours of 4:37 a.m. and 11:30 p.m., Monday through Friday, and in 60-minute intervals between 5:34 a.m. and 11:31 p.m. on Saturday.

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-7
Route 347 provides bus service between California State University, San Marcos, SPRINTER Station and Palomar College, with stops within the transportation study area along N Las Posas Road. This route provides a direct connection to Palomar College Station with transfers to SPRINTER, Route 304, Route 305, and Route 445 bus service. The route operates in 30-minute intervals between the hours of 5:31 a.m. and 7:21 p.m., Monday through Friday, and in 60-minute intervals between 7:22 a.m. and 7:08 p.m. on Saturday.

Route 445 provides bus service between Palomar College and Carlsbad Poinsettia Station with stops within the transportation study area along N Las Posas Road. This rout e provides a direct connection to Palomar College Station with transfers to SPRINTER, Route 304, Route 305, and Route 347 bus service, and to Poinsettia Station with transfers to Coaster service. The route operates in 30-minute intervals between the hours of 6:34 a.m. and 7:19 p.m., Monday through Friday. This route is not in operation during the weekends.

SPRINTER provides light rail service between Oceanside Transit Center and Escondido Transit Center . This route provides a direct connection to Pal omar College Station with transfers to Route 304, Route 305, Route 347 , and Route 445 bus service. The route operates in 30-minute intervals between the hours of 4:03 a.m. and 9:26 p.m., Monday through Friday, and between 4:46 a.m. and 12:26 a.m. on Saturday.

The project site is located within 0.25-miles (walking distance) of two bus stops serving Route 304, Route 305, Route 347, and Route 445 located along N Las Posas Road and W Mission Road . The closest bus stops to the project site are located near the intersection of N Las Posas Road and W Mission Road and the intersection of W Mission Road and Pacific Street. The project site is also approximately 0.3 miles walking or biking distance from Palomar College Station.

At the intersection of N Las Posas Road and W Mission Road, the bus stop in the westbound direction provides route signage, route designations, seating with shade, and a trash receptacle. In the southbound direction the stop provides route signage only . At intersection of W Mission Road and Pacific Street, the bus stop in the westbound direction provides route signage, route designation, seating with shade, and a trash receptacle . In the eastbound direction it provides route signage only.

Existing Bicy cle Network
Currently, Class II bike lanes are provided on the following study street segments:
▪ N Las Posas Road (both sides)
▪ W Mission Road (north side)
Currently, Class I bike lanes are provided on the following study street segments:
▪ W Mission Road (south side)
No other bicycle facilities are currently constructed within the transportation study area.

Existing Pedestrian Conditions
Pedestrian sidewalks are provided throughout the transportation study area along N Las Posas Road and W Mission Road.

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-8

3.15.2 Regulatory Setting
The following provides a general description of the applicable regulatory requirements and guidelines for the project area.

Federal
There are no federal codes, policies, or regulations regarding transportation that would apply to the proposed project.

State
California Department of Transportation
The California Department of Transportation (Caltrans) is the primary state agency responsible for transportation issues. One of its duties is the construction and maintenance of the state highway system. Caltrans has established standards for roadway traffic flow and has developed procedures to determine if intersections require improvements. For projects that may physically affect facilities under its administration, Caltrans requires encroachment permits before any construction work may be undertaken. For projects that would not physically affect facilities, but may influence traffic flow and levels of services at such facilities, Caltrans may recommend measures to mitigate the traffic impacts of such projects.

Assembly Bil l 1358 – California Complete Streets Act of 2008 The California Complete Streets Act of 2008 (Assembly Bill 1358) requires circulation elements as of January 1, 2011, to accommodate the transportation system from a multimodal perspective, including public transit, walking, and biking.

Senate Bill 743, CEQA Guidelines Update
In December 2018, the California Natural Resources Agency certified and adopted the CEQA Guidelines update package, including Guidelines Section 15063.4, which implements Senate Bill (SB) 743. SB 743 require d new metrics for analyzing transportation impacts under CEQA to provide an alternative to LOS. Measurements of transportation impacts may include VMT ,1 VMT per capita, automobile trip generation r ates, or automobile trips generated. SB 743 further directed that unless otherwise provided, a project’s effect on automobile delay shall no longer be considered a significant environmental impact under CEQA. 2 Under CEQA Guidelines Section 15064.3, VMT was determined to be the most appropriate measure of transportation impacts.

The justification for this paradigm shift is that when significant impacts are identified under a LOS and delay-based analysis, the mitigation is often to provide road improvements, which increase roadway capacity, which inherently accommodates more vehicular traffic resulting in additional greenhouse gas emissions. In contrast, under a VMT - based analysis, mitigation typically takes the form of strategies intended to reduce vehicle t raffic, rather than accommodate such traffic, thereby reducing vehicle traffic and associated emissions.

Lead agencies were tasked to transition to the new guidelines and establish thresholds for transportation impacts no later than July 1, 2020. The City adopted its VMT thresholds for CEQA purposes in November 2020 as part of the City’s Transportation Impact Analysis Guidelines (November 2020), which provides that a significant impact

1 VMT refers to the amount and distance of automobile travel attributable to a project. 2 California Public Resources Code , Section 21099(b). SB 743 also amends congestion management law to allow cities and counties to opt out of LOS standards within certain infill areas (OPR 2023).

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-9
would occur if a project proposing a residential land use would generate VMT per resident exceeding a level of 15% below the existing countywide average. The City’s Transportation Impact Analysis Guidelines also provide VMT thresholds for other land use types including employment projects (office and industrial), retail uses, mixed -use projects, and redevelopment projects.

Local
The San Diego Association of Governments’ San Diego Forward: The Regional Plan The SANDAG’s San Diego Forward: The Regional Plan combines the region’s two most important existing planning documents—the Regional Comprehensive Plan and the Regional Transportation Plan and its Sustainable Communities Strategy (SANDAG 2015). The Regional Comprehensive Plan, adopted in 2004, laid out key principles for managing the region’s growth while preserving natural resources and limiting urban sprawl. The plan covered eight policy areas, including urban form, transportation, housing, healthy environment, economic prosperity, public facilities, our borders, and social equity. These policy areas were addressed in the 2050 Regional Transportation Plan/Sustainable Communities Strategy and are now fully integrated into the regional plan.

The SANDAG Board of Directors adopted the 2021 Regional Plan on December 10, 2021. The 2021 Regional Plan is a 30-year plan that considers growth, movement, and residential location around the region (SANDAG 2021). The 2021 Regional Plan combines the Regional Transportation Plan, Sustainable Communities Strategy, and Regional Comprehensive Plan. As such, the 2021 Regional Plan must comply with specific state and feral mandates. These include a Sustainable Communities Strategy , per California SB 375, that achieves greenhouse gas emissions reduction targets set by the California Air Resources Board, compliance with federal civil rights requirements (Title VI), environmental justice considerations, air quality conformity, and public participation (SANDAG 2021).

Congestion Management Program
The 2008 Congestion Management Program for San Diego County was developed to meet the requirements of Section 65089 of the California Government Code. Since that time, the local agencies within San Diego County elected to opt out of the Congestion Management Program requirements, as allowed within the Government Code.

As such, there are no Congestion Management Program -specific requirements associated with this project.

However, to ensure the region’s continued compliance with the federal congestion management process, SANDAG prepared San Diego Forward: The Regional Plan in compliance with Title 23 Code of Federal Regulations Section 450.320 (SANDAG 2015). The regional plan incorporates performance monitoring and measurement of the regional transportation system, multimodal alternatives to single-occupancy vehicles, land use impact analysis, congestion management tools, and integration with the Regional Transportation Improvement Program process.

City of San Marcos Bikeway Master Plan
The 2016 Bikeway Master Plan is an update to the City’s original master plan adopted in 2001. Goals of the master plan were to obtain State Bicycle Transportation Account grant funds and improve bicycle facilities throughout the City for safer routes to school, connections to adjacent cities and incorporate an environmental inventory analysis.

One of the goals of the master plan was to connect the City’s trails to bicycle facilities to complete a safe and enjoyable trail and bikeway system.

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-10
City of San Marcos General Plan
Land Us e and Community Design Element
The Land Use and Community Design Element of the General Plan identifies specific policies related to congestion management. Those that are applicable to the project are identified below (City of San Marcos 2012a).

Policy LU-3.7: Require new development to prepare traffic demand management programs.

Policy LU-3.8: Require new development and discretionary actions to annex into a Congestion Management Community Facilities District.

Mobility Element
The Mobility Element of the General Plan identifies specific goals and policies related to an efficient circulation system, traffic calming and safety, and alternative modes of travel. Those that are applicable to the project are identified below (City of San Marcos 2012b).

Goal M-1: Provide a comprehensive multimodal circulation system that serves the City land uses and provides for the safe and effective movement of people and goods.

Policy M-1.1: Safely and efficiently accommodate traffic generated by development and redevelopment associated with implementation of the General Plan Land Use Policy Map.

Policy M-1.2: Require new development to finance and construct internal adjacent roadway circulation and City-wide improvements as necessary to mitigate project impacts, including roadway, transit, pedestrian and bicycle facilities.

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.

Policy M -1.4: Utilize multi -modal LOS techniques to evaluate transportation facilities. For identified prioritized modes (based on facility typology), provide the following minimum LOS as shown in Table 3-4 of the Mobility Element:
▪ LOS D or better for Vehicles as a prioritized mode
- Generally, provides facilities that have minimum vehicle congesti on during peak periods. Most motorists are delayed less than 55 seconds at a signal (or less than one signalized cycle).
▪ The City shall allow for flexible LOS where warranted (e.g., accepting a lower LOS than identified above).

Policy M-1.6: Work to improve connectivity within the City by closing gaps in the existing bicycle, pedestrian, trail, transit, and roadway network. Work with new development to provide connectivity and redundancy in the mobility network.

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-11
Policy M-1.7: Strive to ensure that str eets within San Marcos shall be complete streets where feasible; thereby providing accessibility, safety, connectivity, and comfort for all modes and users of the system. Appropriate new local streets and Main Streets will prioritize pedestrian and bicycle users through the corridor.

Goal M-2: Protect neighborhoods by improving safety for all modes of travel and calming traffic where appropriate.

Policy M-2.1: Work with new development to design roadways that minimize traffic volumes and/or speed, as approp riate within residential neighborhoods; while maintaining the City’s desire to provide connectivity on the roadway network.

Policy M-2.3: Consider roundabouts, as appropriate, as an intersection control device with demonstrated air quality, traffic efficiency, and safety benefits.

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 greenhouse gas emissions; and reinforces the role of the street as a public space that unites the City.

Policy M -3.2: Improve safety conditions, efficiency, and comfort for bicyclists and pedestrians through design, maintenance and law enforcement. Install wider sidewalks and curb extensions at pedestrian crossings (bulb outs) where appropriate.

Policy M-3.3: Provide a pedestrian and bicycle network in existing and new neighborhoods that facilitates convenient and continuous pedestrian and bicycle travel free of major impediments and obstacles.

Policy M-3.5: Ensure that streets in areas with high levels of pedestrian activity (such as employment centers, residential areas, mixed use areas, and schools) support safe pedestrian travel by providing detached sidewalks, bulb-outs, enhanced pedestrian crossings, pedestrian bridges, and medians.

Policy M-3.9: Create a pleasant wa lking environment for roadway typologies where pedestrian travel is prioritized. This includes providing shade trees, landscaping, benches, pedestrian -scale lighting, way finding signage, transit shelters, and other appropriate amenities.

3.15.3 Thresholds of Significance
Appendix G of the CEQA Guidelines provides thresholds for determining significant environmental impacts. A project may be deemed to have a significant impact on transportation/traffic if it would:
▪ Threshold No. 1: Conflict with a program , plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. ▪ Threshold No. 2: Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b). ▪ Threshold No. 3: Substantially increase hazards due to a geometric design feature (e.g., sharp curves, or dangerous intersections) or incompatible uses (e.g., farm equipment). ▪ Threshold No. 4: Result in inadequate emergency access.

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-12

3.15.4 Project Impact Analysis
The following discussion summarizes the findings of the LTA (Appendix K-1) and VMT analysis (Appendix K-2) as it relates to project trip generation, project trip distribution and assignment, Near -Term (Year 2024) scenarios with and without the proposed project, and Horizon Year (Year 2050) scenarios with and without the proposed project.

The discussion herein supports the findings of the project impact analysis.

Project Trip Generation
As described in Chapter 2 , Project Description, of this EIR, the project proposes development of 120 residential dwelling units under the proposed Specific Plan Area designation. To determine the traffic generation of the project, SANDAG’s (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region ( SANDAG 2002) rates were applied to the project. The trip generation rate for Multifamily (6–20 dwelling units/acre) was used based on the project density of approximately 15.8 dwelling units/acre.

SANDAG provides for a 5% daily trip reduction for land uses with transit access or near transit stations accessible within 0.25 miles. The site is located adjacent to transit service with stops located near project driveway no. 2. To provide a conservative analysis, however, no transit trip reduction was applied to the trip generation for this analysis.

Table 3.15-4 tabulates the total project traffic generation. The project is estimated to generate a total of 960 ADT with 77 AM peak hour trips (15 inbound/62 outbound) and 96 PM peak hour trips (67 inbound/29 outbound).

Table 3.15-4. Project Trip Generation
Land Use Size
Daily Trip
Ends (ADTs) AM Peak Hour PM Peak Hour
Rate ADT %
In:

Out
Split
Volume
%
In:

Out
Split
Volume
In Out Total In Out Total
Multi-Family
6–20 du/acre)
120 du 8/du 960 8% 2:8 15 62 77 10% 7:3 67 29 96
Source: Appendix K-1; SANDAG 2002.

Notes: ADT = average daily traffic; DU = Dwelling Unit.

Project Trip Distribution /Assignment
Trip distribution is the process of determining traffic percentage splits on the regional and local roadway network.

Trip distribution is determined based on the characteristics of the project and upon the general location of other land uses at which project trips would originate or terminate, such as employment, housing, schools, recreation , and shopping.

The traffic generated by the project was distributed and assigned based on anticipated traffic patterns to and from the site, as well as the project site’s proximity to state highways and arterials. The project would be served by two driveways, one located on N Las Posas Road and one located on W Mission Road . Full turning movements would be provided at the N Las Posas Road driveway . W Mission Road driveway would include a left -turn in and right - in/right-out traffic movements.

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-13
Figure 3.1 in the LTA (Appendix K-1) shows the traffic distribution, including the project driveway traffic distribution to provide additional clarity on the local distribution of trips on the streets immediately adjacent to the project site, and Figure 6.4 in the LTA shows the Near-Term Plus Project traffic volumes. Additionally, Table 6.5 , Near-Term Intersection Operations and Table 6.4 , Near-Term Street Segment Op erations, in Appendix K-1 show intersection and street segment operations both with and without the project.

Near -Term (Interim Year 2024) Conditions
This section describes Near-Term (Interim Year 2024) roadway network and traffic volume conditions. Year 2 024 was selected based on SANDAG’s pre-established interim year scenarios as the closest to the opening year of the project. The existing street system as illustrated in Figure 5.1 of the LTA (Appendix K-1) is assumed for Near-Term Conditions with no notable improvements within the transportation study area. To forecast future traffic volumes for Near -Term (Interim Year 2024) Conditions, the SANDAG Series 14 Model was utilized. The forecasted ADT volumes were then used to calculate peak hour volumes based p artially on the existing relationship between ADT and peak hour volumes. As outlined in Section 6.42 of the LTA (Appendix K-1), all transportation study area roadway segments are projected to operate at acceptable LOS B under Near-Term Conditions. Additionally, all transportation study area intersections are projected to operate at acceptable LOS D or better under Near-Term Conditions.

Near -Term (Interim Year 2024) Plus Project Conditions
Intersection geometrics under the Near -Term Plus Project Conditions were assumed to be identical to the Near - Term Conditions. As outlined in Section 6.6 of the LTA (Appendix K -1), all transportation study area roadway segments are projected to operate at acceptable LOS B under Near -Term Plus Project Conditions. Ther efore, no transportation study area roadway segments are anticipated to degrade in LOS to unacceptable levels with implementation of the project and no improvements would be required.

Peak hour intersection volumes for the Near-Term Plus Project Conditions were derived by combining the proposed project trips with the Near -Term base traffic volumes. As outlined in Appendix K -1, all transportation study area intersections are projected to operate at acceptable LOS D or better under Near -Term Plus Project Conditions. No study intersections are anticipated to degrade in LOS to unacceptable levels with implementation of the proposed project and no improvements would be required.

Horizon Year 2050 Conditions
Intersection geometrics under Horizon Year 2050 Conditions were assumed to be identical to the Existing Conditions. Horizon Year 2050 ADT forecasts were obtained from the SANDAG Series 14 ABM2+/2021 RP forecast year 2050 model (scenario ID no. 459). Any transportation study area roadway with Near -Term ADT found to be greater than forecasted Transportation Forecast Information Center ADT were adjusted using growth rates observed between existing and forecasted Transportation Forecast Information Center ADT for adjacent segments.

Intersection turning movement volumes were developed utilizing the roadway volumes analyzed for the roadway segment analysis. Growth was applied per approach based on existing and forecasted Horizon Year 20 50 ADT, distributed based on existing travel patterns, and balanced utilizing engineering judgement.

As outlined in Appendix K-1, all transportation study area roadway segments are projected to operate at acceptable LOS C or better under Horizon Year 2050 conditions. Similarly, all transportation study area intersecti ons are projected to operate at acceptable LOS D or better under Horizon Year 2050 Conditions.

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-14
Horizon Year 2050 Plus Project Conditions
Intersection geometrics under the Horizon Year 2050 Plus Project Conditions were assumed to be identical to the Horizon Year 2050 Conditions geometrics. Peak hour intersection volumes for the Horizon Year 2050 Plus Project Conditions were derived by combining the proposed project trips with the Horizon Year 2050 traffic volumes. As outlined in Appendix K -1, all transportation study area roadway segments are projected to operate at acceptable LOS C or better under Horizon Year 2050 Plus Project Conditions. Therefore, no transportation study area roadway segments are anticipated to degrade in LOS to unacceptable levels with implementation of the proposed project and no improvements would be required. Similarly, all transportation study area intersections are projected to operate at acceptable LOS D or better under Hori zon Year 2050 with Project Conditions. Therefore, no study intersections are anticipated to degrade in LOS to unacceptable levels with implementation of the proposed project and no improvements would be required.

Threshold No. 1. Conflict with a program plan, ordinance or policy addressing the circulation system , including transit, roadway, bicycle, and pedestrian facilities.

The proposed project seeks to construct 120 multifamily dwelling units on a vacant property approximately 250 feet northwest of the W Mission Road and N Las Posas Road intersection in the City of San Marcos. The property is bordered by N Las Posas Road on the northeast side, W Mission Road on the southwest side, single-family dwelling units on the northwest side, and a CVS pharmacy to the south. Per the City’s General Plan, the site is designated as a Commercial (C) land use.

The proposed project would share two existing driveways with the adjacent CVS Pharmacy, with one located off N Las Posas Road and the other off W Mission Road. The access off N Las Posas Road is via a signalized intersection at N Las Posas Road and Palm Road (driveway no. 1), and the access off W Mission Road is via a side -street (the CVS driveway) stop-controlled intersection that does not allow left-turn out movements (driveway no. 2).

The project site is located in an area surrounded by development with numerous bicycle, pedestrian, and transit facilities, as discussed in Section 3.15.1, Existing Conditions. Class II bike lanes are provided on N Las Posas Road and W Mission Road . Additionally, a Class I multi -use path exists along the south side of W 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. As described previously, 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, a public community college consisting of a 200 -acre campus, is located east of the project site . Palomar College Transit Center, a n NCTD hub, is located less than

0.25 miles from the project site . Palomar College Transit Center consis ts of a bus depot on the north side of W Mission Road, near the main entrance to Palomar College, and a train station on the south side of W Mission Road that serves the SPRINTER hybrid rail train. Rail service and bus transit service offered at the Transi t 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 Mission Road in front of CVS.

As concluded in the TIA, the proposed project would not conflict with any existing or planned transit 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.

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-15
Sidewalks are proposed along the project frontage along N Las Posas Road and W 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 recommendations, the overall pedestrian environment would be enhanced for both walkability and safety and would not result in any impacts to pedestrian facilities.

The project would be req uired to provide adequate on -site circulation for passenger vehicles, heavy vehicles, bicyclists , and pedestrians. Internal circulation within the project site is shown in site plans subject to City review and would be designed to comply with the following recommendations of the TIA, as required by conditions of approval :

Driveways would be constructed in accordance with City standards Stop sign (R1-1) would be installed at project driveway no. 2 High visibility pedestrian crossings where crossing is allowed would be installed at project driveway no. 1 Existing traffic detection camera would be modified at traffic signal serving driveway no. 1 to accommodate queuing vehicles exiting through this driveway
Appropriate signage would be posted to warn drivers of pedestrian foot traffic Installation of speed cushions/bumps along internal roadways would be considered to calm traffic The adjacent CVS parcel includes 99 existing 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 existing parking spaces on the project site 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 be electric vehicle charging stations . The project also includes 240 garage spaces , which would provide two garage spaces per unit and therefore would comply with the City’s Parking Ordinance. 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 desi gnation 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 .

Therefore, impacts would be less than significant.

Threshold No. 2: Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)? As discussed above, CEQA Guidelines Section 15064.3 replaces LOS with VMT as the appropriate metric to be used in assessing a project’s transportation related impacts. Under CEQA Guidelines Section 15063.4(b)(1), VMT exceeding an applicable threshold of significance may indicate a significant impact. However, development projects within 0.5 miles of a major transit stop are presumed to cause a less-than-significant transportation impact (under California Public Resource Code , Section 21064.3, a "Major transit stop means a site containing an existing rail station"). Despite the project b eing located within 0.5 miles of a major transit stop (Palomar Station ), the project would not be screened out to be less than significant because the project is inconsistent with the current General Plan. Because the project site is inconsistent with the current General Plan, a quantitative VMT analysis has been prepared for the project.

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-16
Vehicle Miles Traveled Analysis
As described under Section 3.15.1, for new land use development that does not meet any of the screening criteria, the VMT metrics and thresholds outlined in the City ’s Transportation Impact Analysis Guidelines , VMT Impact Thresholds by Land Use Type, are used to determine a significant transportation impact (City of San Marcos 2020).

The project does not meet any of the screening criteri a. Therefore, a detailed VMT analysis is required. Since the project proposes residential land uses, this EIR evaluates whether the project VMT per resident would exceed a significance threshold of 15% below the existing countywide average. The project is estimated to generate 960 ADT.

The SANDAG Series 14 model (also known as ABM 2+) is the latest available model and was used to determine the regional average VMT. VMT data should only be compared with regional averages within the same model version.

Table 3.15-5 shows the project VMT analysis. Based on the model outputs, the project VMT per resident is 17.10, above the significance threshold of 15% below the regionwide average, or 14.9 VMT per resident.

Because the project’s VMT per resident is more than 15% above the regionwide average , impacts would be potentially significant and mitigation is required (Impact TRA-1).

Table 3.15-5. VMT Impact Analysis
Metric
Regional
Average 1
Significance Threshold
(15% below Average) 2 Project 1
Transportation Impact?
(Over Threshold)
VMT per Resident 18.90 16.07 17.10 Yes
Source: Appendix K-2
Notes:
1 SANDAG Series 14 ABM2+/2021 RP Year 2016 Base Model
2 Regional Average x 85%
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.

The proposed project would have a significant VMT impact and mitigation measures are required to reduce the VMT per resident. The proposed project’s total VMT per resident is 17.1 miles. To mitigate the proposed project’s VMT to less-than-significant levels, mitigation measures would need to reduce the total VMT per resident by 6.02% from

17.1 miles to 16.07 miles.

To reduce the average VMT per resident, it is recommended that the proposed project implement a TDM Program.

A 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 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 (CAPCOA 2022).

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-17
Mitigation Measure (MM) TRA-1 through MM-TRA-3 are proposed for the project, as outlined in Section 3.15.6. As described in Appendix K-2, based on the VMT reduction results, implementation of the TDM program is anticipated to reduce the VMT per capita generated by 0.10 %. Thus, with implementation of the TDM program, the proposed project is anticipated to generate 17.08 VMT per resident (17.1 VMT p er resident × (1−0.001)). The resulting

17.08 miles per resident exceeds the 16.07 miles threshold. Therefore, since the mitigation measures would not reduce the VMT per resident to less-than-significant levels, the impact is only partially mitigated, and the proposed project would have a significant and partially mitigated impact. Therefore, despite the implementation of MM-TRA-1 through MM-TRA-3, impacts would be significant and unavoidable.

Threshold No. 3: Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves, or dangerous intersections) or incompatible uses (e.g., farm equipment)? The project site is located in an area surrounded by development and is bounded by N Las Posas Road and W Mission Road. The project would be served by two driveways located on N Las Posas Road and W Mission Road.

Internal roadways on the project site allow for two -way flow of vehicle traf fic. Dead-end aisles between buildings would provide direct access to garages for each dwelling unit. The internal circulation network for the project would not include any hazardous design features or incompatible uses. The project would include connections to existing roadways within the vicinity of the project site and access to regional arterial and highway networks and SPRINTER/Breeze transit services. All final project plans and the LTA prepared for the project (Appendix K-1) are subject to review and approval by the City and the San Marcos Fire Department. Proposed circulation improvements per the LTA would be designed in accordance with the City’s roadway design standards to ensure proper safety requirements are met (Appendix K-1). All uses on site, including vehicle, pedestrian, and bicycle circulation, would be typical of a residential land use, and no incompatible uses or equipment is proposed. Furthermore, the project is designed to comply with the recommendations of the TIA, outlined under response to Threshold No. 1, which are required conditions of approval for the project. As such, impacts would be less than significant.

Threshold No. 4: Would the project result in inadequate emergency access? The project would be served by two driveways located on N Las Posas Road and W Mission Road . Driveway no. 1 would provide for full turning movements while driveway no. 2 would be limited to right -out only. Both would be designed to meet the design requirements codified in the California Fire Code.

According to the General Plan Safety Element, the San Marcos Emergency Operations Plan governs the operations of the City during a disaster. This plan addresses response to moderate evacuation scenarios, including the identification of evacuation points and general routes (City of San Marcos 2012c). The project would be required to abide by standards as set forth in the San Marcos Emergency Operations Plan. Implementation of the project would not impact any roadway or staging areas that are identified in any emergency planning documents and would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. Additionally, as described in Chapter 3.13, Public Services, of this EIR, the Preliminary Fire Emergency Response Analysis prepared for the project (Appendix J to this EIR) determined that San Marcos Fire Department could provide emergency response to the project site within its internal 7 -minute response time from San Marcos Fire Department Station 1 to the project site.

Furthermore, the California Fire Code, along with the San Marcos Fire Department, administers the rules and regulations on fire access design. Final site plans will be required to show fire and emergency responders suitable fire access roads dimensions an d surfaces ( Chapter 5, Sections 503.1–503.4, of the California Fire Code) and an adequate number of emergency rated entrances to the community (Appendix D, Section D106, of the California Fire

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-18
Code). All final project plans and the LTA prepared for the project (Appendix K-1) are subject to review and approval by the City and the San Marcos Fire Department. Proposed circulation improvements would be designed in accordance with the City’s roadway design standards to ensure proper safety requirements are met (City of San Marcos 2022).

Therefore, for the reasons outlined above, impacts related to emergency access would be less than significant.

3.15.5 Cumulative Impact Analysis
The project, in addition to cumulative projects in the transportation study area, could result in cumulative impacts related to transportation and circulation. Table 6.1 in the LTA (Appendix K-1) displays the projected trip generation for the cumulative projects considered for the traffic analysis. Cumulative project traffic was assign ed to the transportation study area as identified within their respective traffic studies provided by the City. Cumulative project traffic without completed traffic studies were assigned to the transportation study area utilizing the same methodology used for the proposed project, consistent with the City’s Transportation Impact Analysis Guidelines .

As shown in Table 6.1 in Appendix K -1, the cumulative projects are anticipated to generate 6,756 daily trips, including 536 trips during AM peak hour and 623 trips during the PM peak hour, that would be dispersed throughout the City and beyond the transportation study area.

It is expected that TIAs would be prepared for cumulative projects , consistent with City guidelines, to fully analyze project-specific impact s on site and in the transportation study area and provide 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. As analyzed in Section 3.15.4, implementation of the project would result in a significant VMT impact in the transportation study area. For this reason, it is deter mined that cumulative impacts to transportation as a result of project implementation would similarly be significant and unavoidable.

3.15.6 Mitigation Measures
MM-TRA-1 through MM-TRA-3 outlined below would reduce impacts related to the VMT per resident. However, even with implementation of these mitigation measures, project VMT would remain significant.

MM-TRA-1 Provide subsidized transit passes (10%) for 100% of all residents (CAPCOA T -9: Implement Subsidized or Discounted Transit Program = 0.10% VMT reduction) MM-TRA-2 Creation and distribution of a “new resident” information packet addressing alternative modes of transportation (CAPCOA T-7: Implement Commute Trip Reduction Marketing).

MM-TRA-3 Provide on-site bike parking (CAPCOA T-10: Provide End-of-Trip Bicycle Facilities).

In addition to MM -TRA-1 through MM -TRA-3, the following improvement recommendation proposed by the LTA (Appendix K-1) would be incorporated as a condition of approval , which has the potential to further reduce VMT; however, it is not considered a mitigation measure as it does not meet CAPCOA’s minimum requirements:
▪ Install electric vehicle charging stations at each electric vehicle guest parking space (CAPCOA T-14: Provide Electric Vehicle Charging Infrastructure).

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-19

3.15.7 Conclusion
The project would provide for residential land uses in an infill area, taking advantage of the site’s location near transit, retail, employment, schools, parks, and other uses. The project would be consistent with programs, plans, ordinances, and poli cies addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. Implementation of the project would not conflict with any applicable plans or policies addressing circulation, would not increase hazards, and would not result in inadequate emergency access. Impacts related to Threshold Nos. 1, 3, and 4 were determined to be less than significant.

As described in response to Threshold No. 2, based on the VMT reduction results, implementation of the TDM program is anticipated to reduce the VMT per capita generated by 0.10%. Thus, with implementation of the TDM program, the proposed project is anticipated to generate 17.08 VMT per resident (17.1 VMT per resident × (1−0.001)). The resulting

17.08 miles per resident exceeds the 16.07 miles threshold. Therefore, since the mitigation measures would not reduce the VMT per resident to less-than-significant levels, the impact is only partially mitigated, and the proposed project would have a significant and partially mitigated impact. Therefore, even with implementation of MM-TRA-1 through MM-TRA-3, impacts related to VMT would be significant and unavoidable. As such, cumulative impacts related to traffic would similarly be considered significant and unavoidable.

3.15 – TRANSPORTATION
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.15-20

INTENTIONALLY LEFT BLANK

3.16 – TRIBAL CULTURAL RESOURCES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.16-1

3.16 Tribal Cultural Resources
This section describes the existing tribal cultural resources (TCRs) of the proposed Gran Vista Specific Plan Project (project), identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the project. As defined by California Public Resources Code (PRC), Section 21074, a TCR is a site, feature, place, or cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe. A TCR is either on or eligible for the California Register of Historic Resources (CRHR) or a local historic register or determined by the City of San Marcos (City) at its discretion to treat the resources as a TCR (PRC Section 5024.1).

Cultural resources are further analyzed in Section 3.4, Cultural Resources, of this environmental impact report (EIR).

The analysis in this section relies on the Archaeological Resource Inventory – Negative Findings Report for the Gran Vista Project prepared by Dudek in February 2023 (Appendix D to this EIR). The cultural resources report included a record search, literature review, correspondence with Native American contacts, and a field survey. The analysis also considers the California Environmental Quality Act (CEQA) Guidelines Appendix G and applicable state and local regulations, including the City of San Marcos General Plan (General Plan). Table 3.16-1 summarizes the TCRs project- and cumulative-level impacts by threshold.

Table 3.16-1. Tribal Cultural Resources Summary of Impacts Threshold of Significance
Project -Level
Impact
Cumulative -
Level Impact
Significance
Determination
No. 1: Cause a substantial adverse change in the
significance of a tribal cultural resource, defined in
Public Resources Code section 21074 as either a site,
feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of
historical resources as defined in Public Resources
Code section 5020.1(k), or
b) A resource determined by the lead agency, in its
discretion and supported by substantial evidence,
to be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code
Section 5024.1. In applying the criteria set forth in
subdivision (c) of Public Resource Code
Section 5024.1, the lead agency shall consider the
significance of the resource to a California
Native American tribe.

Potentially
Significant
Less than
Significant
Less than
Significant with
MM-CR-1 through
MM-CR-4

3.16.1 Existing Conditions
The project site is undeveloped and reflects a history of disturbance. Vegetation is disturbed by an abundance of invasive and weedy plant species (Appendix C, Biological Resources Technical Report).

3.16 – TRIBAL CULTURAL RESOURCES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.16-2
The project area of potential effect (APE), as analyzed in the cultural resources report, includes the entire 7.6-acre project site. The project APE is located at the northwest corner of N Las Posas Road and W Mis sion Road and is surrounded by commercial, residential, and light industrial uses.

The information herein describes the existing archeological context of the project site. It also provides information on the outreach and consultation efforts with local tribes, as required by existing regulations.

Methodology
South Coastal Information Center Records Search
Dudek previously completed a cultural resources constraints analysis for the project (DeCarlo et al . 2021). The purpose of the records search is to identify any previously recorded cultural resources that may be located within the property. In addition to a review of previously prepared EIRs, permit application packages, site records, and reports, the records se arch also review ed historical maps of the project APE and vicinity, ethnographies, the National Register of Historic Places (NRHP), CRHR, Built Environment Resources Directory, and the lists of California State Historical Landmarks, California Points of Historical Interest, and Archaeological Determinations of Eligibility.

Dudek received the results of the records search on June 17, 2021 (Appendix D).

Dudek review ed the Built Environment Resources Directory on June 16, 2021. No previously recorded built environment resources are located on the project APE or along the blocks of N Las Posas Road and W Mission Road that border the project APE.

The South Coastal Information Center records search results identified 40 cultural resources within 1 mile of the project APE, none of which intersect the current project APE. One resource, P -37-005584/CA-SDI-5584, was identified immediately adjacent to the project APE and is discussed below. Table 1 in Appendix D summarizes the cultural resources within 1 mile of the project APE.

P-37-005584 /CA -SDI -5584
This site was originally recorded by Randy Franklin in 1977 as a single grinding slick in a boulder outcrop on a small knoll. Franklin (1977) stated that there was no midden but lithic flakes, core fragments, and a hammerstone were present near the adjacent road, and suggested that they may have been intrusive. This resource was located immediately east of the project APE within the current path of N Las Posas Road. This resource was destroyed during the road’s construction in 1986 and its expansion by 1990.

The records search also identified 55 previous studies that have been performed within 1 mile of the project APE. Four of these studies have addressed at least a portion of the project APE, one of which (SD-18210) addressed the entire project APE. SD-18210, however, was a constraints study and did not include a full pedestrian survey. The findings of SD-18210 are similar to the findings of this inventory; therefore, they will not be summarized here. These previous 55 studies were conducted between 1974 and 2020. No survey of the project APE has been conducted within the past 6 years. A complete list of the previous studies conducted within 1 mile of the project APE is included in Appendix D.

Archival Research
The previous constraints analysis included a review of historic to pographic maps and aerial photographs of the project APE and the general vicinity, to help determine the possible development and land use of the project APE in the past. The historic aerial imagery available from Nationwide Environmental Title Research LLC includes historic

3.16 – TRIBAL CULTURAL RESOURCES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.16-3
photographs available since 1953 (NETR 2021). The 1953 aerial photograph shows that the property was undeveloped but still bordered W Mission Road to the south. The knoll and rock outcrop on which archaeological resource P-37-005584 was located is vaguely visible on the 1953 aerial photograph. By 1964, a natural drainage that was located west of the project APE was channelized and demarcates the western boundary of the current project APE. The project APE itself was still undisturbed but a residential development was constructed to the northeast. By 1978, the project APE and the adjacent P -37-005584 knoll were undisturbed, though a new residential development was constructed west of the project boundary. The 1984 aerial photograph shows that the southeastern corner of the project APE was graded but the rest of the project APE and the adjacent P-37-005584 knoll was undisturbed. The 1986 aerial photograph shows the grading of the current N Las Posas Road alignment.

This grading disturbed the eastern border of the project APE and destroyed part of the adjacent P-37-005584 knoll.

By 1989, the grading of the eastern project APE boundary was expanded and substantial earth movement was required to support the current alignment of the six -lane N Las Posas Road. This expansion destroyed the P-37-005584 knoll adjacent to the project APE. By 1991, the entire project APE had been graded. By 2009, the entire project APE was graded again leaving the property with a northern terrace that overlooked the southern 75% of the project APE. The current commercial building and parking lot that bou nd the southern portion of the project APE were also constructed by 2009. The historic aerial photographs show that the project APE has been undeveloped but completely disturbed.

Intensive Pedestrian Survey
A Dudek archaeologist conducted a survey of the proposed project APE on April 22, 2022. Native American Monitor Logovii Sialoi from Saving Sacred Sites Inc., a Luiseño owned company, participated in the pedestrian survey. The project consists of a vacant lot bordering existing residential and commercial developments. The project APE has been previously disturbed , as evidenced by graded terraces. There was an elevation difference of approximately 10 feet between the northern and the southern half of the parcel , showing complete disturbance of the natural landscape. Ground visibility was low throughout the project APE due to heavy vegetation with some modern trash and debris scattered throughout the area. Though currently undeveloped, the project APE is immediately adjacent to residential and commercial development and has been subjected to illicit dumping activities. Pedestrian survey was conducted utilizing formal transects at 15-meter intervals. Deviations from transects also occurred to inspect animal burrows and other locations of exposed sediments and boulders. No remnants of adjacent resource P-37-005584 or other cultural resources were identified within the project APE (Appendix D).

Native American Heritage Commission and Native American outreach letters Dudek requested a Native American Heritage Commission (NAHC) search of the Sacred Lands File on April 15, 2022, for the project APE and a 1 -mile buffer. The Sacred Lands File consists of a database of known Native American resources. These resources may not be included in South Coastal Information Center database. The NAHC replied on May 19, 2022, and reported that the Sacred Lands File did not identify any known Native American cultural resources within the project APE or the surrounding 1-mile buffer (Appendix D). The NAHC additionally provided a list of Native American tribes and individuals/organizations with traditional geographic associations that might have knowledge of cultural resources in this area.

Outreach letters were mailed on May 27, 2022, to all Native American group representatives included on the NAHC contact list (Appendix D). These letters attempted to solicit additional information relating to Native American resources that may be impacted by the project. Native American representatives were requested to define a general area where known resources intersect the project APE. To date, Dudek has received responses to these outreach letters from three tribal representatives. On June 17, 2022, San Pasqual Band of Mission Indians responded to the

3.16 – TRIBAL CULTURAL RESOURCES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.16-4
letter stating that the project APE is within the boundary of the tribe’s Traditional Use Area. San Pasqual stated that they would like to engage in “formal government to government consultation.” On June 21, 2022, Pechanga Band of Luiseño Mission Indians stated that the project APE is within their Ancestral Territory and that they are interested in participating in the project area. Pechanga added that the project APE is within 1.75 miles of two Ancestral Placenames and nine other previously recorded sites within 0.5 miles, one of which is within the project APE.

Unfortunately, no other information about the intersecting resource was included but Pechanga is likely referring to the destroyed adjacent P-37-005584 knoll. On June 28, 2022 , Rincon Band of Luiseño Indians responded to the outreach letter and stated that the project APE was within the band’s specific Area of Historic Interest. Rincon added that they were concerned that the project may impact Tribal Cultural Resources, Traditional Cultural Landscapes, or potential Traditional Cultural Properties. Rincon recommended an archaeological/cultural resources inventory and that a tribal monitor from the Rinco n Band should accompany the survey staff. On July 12, 2022, Dudek archaeologist Matthew DeCarlo met Cheryl Madrigal, the tribal historic preservation officer for Rincon Band, at the project APE for a site visit. They discussed the previous disturbance of t he area and visited the location of former prehistoric bedrock milling site P -37-005584. Ms. Madrigal stated that she would contact the City about her concerns after she had some time to research the project area. On September 8, 2022, Rincon sent a letter to the City critiquing an earlier version of this report. Rincon requested an ethno-historic research and further analysis of adjacent sites P-37-005584 and P-37-005633.

In compliance with Assembly Bill 52 and Senate Bill 18 , the City, as lead agency, is responsible for conducting government to government consultation with pertinent tribal entities. Rincon Band responded to City outreach for Senate Bill 18 and Assembly Bill 52 on February 16 and April 13 requesting consultation on the Project. The City had a consultation meeting with representatives of Rincon Band on August 16, 2022.

3.16.2 Regulatory Setting
Federal
National Historic Preservation Act
The National Historic Preservation Act established the NRHP program under the Secretary of the Interior. The act authorized funding for state programs with provision for pass -through funding and participation by local governments, created an Advisory Council on Historic Preservation, and established the Section 106 review process for protecting historic resources. The goal of the Section 106 review process is to offer protection to sites that are determined eligible for listing in the NRHP. The National Historic Preservation Act provides the legal framework for most state and local preservation laws.

Tradition al Cultural Properties (Native American Heritage Values) Federal and state laws mandate that consideration be given to the concerns of contemporary Native Americans with regard to potentially ancestral human remains, associated funerary objects, and items of cultural patrimony.

Consequently, an important element in assessing the significance of the study site has been to evaluate the likelihood that these classes of items are present in areas that would be affected by the proposed project. Also, potentially relevant to prehistoric archaeological sites is the category termed Traditional Cultural Properties in discussions of cultural resource management performed under federal auspices. According to Parker and King (1998), “Traditional” in this context refers to those beliefs, customs, and practices of a living community of people that have been passed down through the generations, usually orally or through practice. The traditional cultural significance of a historic property, then, is significance derived fro m the role the property plays in a community’s historically rooted beliefs, customs, and practices.

3.16 – TRIBAL CULTURAL RESOURCES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.16-5
State
California Register of Historical Resources (California Public Resources Code Section 5020 et. seq.) In California, the term “historical resource” includes but is not limited to “any object, building, structure, site, area, place, record, or manuscript which is historically or archaeologically significant, or is significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California” (PRC Section 5020.1[j]). In 1992, the California legislature established the CRHR “to be used by state and local agencies, private groups, and citizens to identify the state’s historical resources and to indicate what properties are to be protected, to the extent prudent and feasible, from substantial adverse change” ( PRC Section 5024.1[a]). A resource is eligible for listing in the CRHR if the State Historical Resources Commiss ion determines that it is a significant resource and that it meets any of the following NRHP criteria (PRC Section 5024.1[c]):

Associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage.

Associated with the lives of persons important in our past.

Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values.

Has yielded, or may be likely to yield, information important in prehistory or history.

Resources less than 50 years old are not considered for listing in the CRHR, but may be considered if it can be demonstrated that sufficient time has passed to underst and the historical importance of the resource (14 CCR Section 4852[d][2]).

The CRHR protects cultural resources by requiring evaluations of the significance of prehistoric and historic resources. The criteria for the CRHR are nearly identical to those for the NRHP, and properties listed or formally designated as eligible for listing on the NRHP are automatically listed on the CRHR, as are the state landmarks and points of interest. The CRHR also includes properties designated under local ordinances or identified through local historical resource surveys. The State Historic Preservation Officer maintains the CRHR.

Native American Historical Cultural Sites ( California Public Resources Code Section 5097 et. seq.) State law addresses the following:
▪ The disposition of Native American burials in archaeological sites and the protection of such remains from disturbance, vandalism, or inadvertent destruction.
▪ The procedures to be implemented if Native American skeletal remains are discovered during construction of a project.
▪ The establishment of the NAHC to resolve disputes regarding the disposition of such remains.

In addition, the Native American Historic Resource Protection Act states that defacing or destroying Native American historic or cultural sites that are listed (or may be eligible for listing) in the CRHR is a misdemeanor punishable by up to 1 year in jail.

3.16 – TRIBAL CULTURAL RESOURCES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.16-6
California Environmental Quality Act
As described further below, the following CEQA statutes and CEQA Guidelines are of relevance to the analysis of archaeological and historic resources:

PRC Section 21083.2(g): Defines “unique archaeological resource.” PRC Section 21084.1 and CEQA Guidelines Section 15064.5(a): Define historical resources. In addition, CEQA Guidelines Section 15064.5(b) defines the phrase “substantial adverse change in the significance of an historical resource;” it also defines the circumstances when a project would materially impair the significance of a historical resource.

PRC Section 5097.98 and CEQA Guidelines Section 15064.5(e): Set forth standards and steps to be employed following the accidental discovery of human remains in any location other than a dedicated ceremony.

PRC Sections 21083.2(b) –(c) and CEQA Guidelines Section 15126.4: Provide information regarding the mitigation framework for archaeological and historic resources, including options of preservation-in-place mitigation measures; preservation-in-place is the preferred manner of mitigating impacts to significant archaeological sites because it maintai ns the relationship between artifacts and the archaeological context, and may also help avoid conflict with religious or cultural values of groups associated with the archaeological site(s).

Under CEQA, a project may have a significant effect on the envir onment if it may cause “a substantial adverse change in the significance of an historical resource” (PRC Section 21084.1; 14 CCR 15064.5[b]). If a site is either listed or eligible for listing in the CRHR, if it is included in a local register of historic resources, or is identified as significant in a historical resources survey (meeting the requirements of PRC Section 5024.1[q]), it is a “historical resource” and is presumed to be historically or culturally significant for purposes of CEQA ( PRC Section 21084.1; 14 CCR 15064.5[a]). The lead agency is not precluded from determining that a resource is a historical resource even if it does not fall within this presumption (PRC Section 21084.1; 14 CCR 15064.5[a]).

A “substantial adverse change in the significance of an historical resource” reflecting a significant effect under CEQA means “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired” (14 CCR 15064.5[b][1]; PRC Section 5020.1[q]).

In turn, the significance of a historical resource is materially impaired when a project does the following:

Demolishes or materially alters in an adverse manner those physical character istics of an historical resource that convey its historical significance and that justify its inclusion in, or eligibility for, inclusion in the CRHR
Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to section 5020.1(k) of the PRC or its identification in an historical resources survey meeting the requirements of Section 5024.1(g) of the PRC, unless the public agency reviewing the effects of the project establishes by a preponderance of evidence that the resource is not historically or culturally significant
Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its histo rical significance and that justify its eligibility for inclusion in the CRHR as determined by a lead agency for purposes of CEQA

3.16 – TRIBAL CULTURAL RESOURCES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.16-7
California Health and Safety Code , Section 7050.5
California law protects Native American burials, skeletal remains, and assoc iated grave goods, regardless of their antiquity, and provides for the sensitive treatment and disposition of those remains. California Health and Safety Code, Section 7050.5, requires that if human remains are discovered in any place other than a dedicated cemetery, no further disturbance or excavation of the site or nearby area reasonably suspected to contain human remains shall occur until the County coroner has examined the remains (Section 7050.5b). If the coroner determines or has reason to believe the remains are those of a Native American, the coroner must contact the NAHC within 24 hours (Section 7050.5c). The NAHC will notify the most likely descendant. With the permission of the landowner, the most likely descendant may inspect the site of discove ry. The inspection must be completed within 24 hours of notification of the most likely descendant by the NAHC. The most likely descendant may recommend means of treating or disposing of, with appropriate dignity, the human remains and items associated with Native Americans.

Senate Bill 18
Senate Bill 18 amended Section 65351 of the Government Code and dictates the following:

During the preparation or amendment of the general plan, the planning agency shall provide opportunities for the involvement of citizens California Native American Indian tribes, public agencies, public utility companies, and civic, education, and other co mmunity groups, through public hearings and any other means the city or county deems appropriate.

Assembly Bill 52
California AB 52, which took effect July 1, 2015, establishes a consultation process between California Native American tribes and lead agencies in order to address tribal concerns regarding project impacts and mitigation to TCRs. PRC Section 21074(a) defines TCRs and states that a project that has the potential to cause a substantial adverse change to a TCR is a project that may have an adverse effect on the environment. A TCR is defined as a site, feature, place, cultural landscape, sacred place, and object with cultural value to a California Native American tribe that is either:

Listed or eligible for listing in the CRHR or a local register of historical resources Determined by a lead agency to be a TCR
Traditional Cultural Properties /Native American Heritage Values Federal and state laws mandate that consideration be given to the concerns of contemporary Native Americans with regard to poten tially ancestral human remains associated funerary objects and items of cultural patrimony.

Consequently, an important element in assessing the significance of the project site has been to evaluate the likelihood that these classes of items are present in areas that would be affected by the proposed project.

The category termed “Traditional Cultural Properties” in discussions of cultural resource management performed under federal auspices is also potentially relevant to prehistoric archaeological sites. According to Patricia L. Parker and Thomas F. King (1998), “Traditional” in this context refers to those beliefs, customs, and practices of a living community of people that have been passed down through the generations, usually orally or through practice. T he traditional cultural significance of a historic property, then, is significance derived from the role the property plays in a community’s historically rooted beliefs, customs, and practices. Examples of properties possessing such significance include the following:

A location associated with the traditional beliefs of a Native American group about its origins, its cultural history, or the nature of the world
A rural community whose organization, buildings and structures, or patterns of land use reflect the cultural traditions valued by its long-term residents

3.16 – TRIBAL CULTURAL RESOURCES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.16-8
An urban neighborhood that is the traditional home of a particular cultural group, and that reflects its beliefs and practices
A location where Native American religious practitioners have historically gone, and are known or thought to go today, to perform ceremonial activities in accordance with traditional cultural rules of practice A location where a community has traditionally carried out economic, artistic, or other cultural practices important in maintaining its historic identity
Native American Historic Resource Protection Act
State law addresses the disposition of Native American burials in archaeological sites and protects such remains from disturbance, vandalism, or inadvertent dest ruction; establishes procedures to be implemented if Native American skeletal remains are discovered during construction of a project; and establishes the NAHC to resolve disputes regarding the disposition of such remains. In addition, the Native American Historic Resource Protection Act (PRC Section 5097 et seq.) makes it a misdemeanor punishable by up to 1 year in jail to deface or destroy a Native American historic or cultural site that is listed or may be eligible for listing in the CRHR.

California Nat ive American Graves Protection and Repatriation Act The California Native American Graves Protection and Repatriation Act (California Repatriation Act) (25 USC Chapter 32), enacted in 2001, requires all state agencies and museums that receive state funding and that have possession or control over collections of human remains or cultural items, as defined, to complete an inventory and summary of these remains and items on or before January 1, 2003, with certain exceptions. The California Repatriation Act also provides a process for the identification and repatriation of these items to the appropriate tribes.

Local
City of San Marcos General Plan
The Conservation and Open Space Element of the City’s General Plan contains several policies pertaining to the protection of archaeological and historic resources. The following goals and policies apply to the project (City of San Marcos 2012):

Policy COS -2.5: Continue to review future development proposals to ensure that cultural resources (including prehistoric, historic, paleontological, and SB 18 Tribal resources) are analyzed and conserved in compliance with CEQA requirements.

Goal COS-11: Continue to identify and evaluate cultural, historic, archaeological, paleontological and architectural resources for protection from demolition and inappropriate actions.

Policy COS -11.1: Identify and protect historic and cultural resources including individual properties, districts and sites (e.g., archaeological sites) in compliance with CEQA.

Policy COS-11.2: Prohibit the demolition or removal of a historic structure without evaluation of the condition of the structure, the cost of rehabilitation, and the feasibility of alternatives to preservation in place including but not limited to relocation, or reconstruction off-site, and/or photo-preservation.

The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10 , Land Use and Planning, of this EIR.

3.16 – TRIBAL CULTURAL RESOURCES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.16-9

3.16.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to TCRs are based on Appendix G of the CEQA Guidelines.

According to Appendix G of the CEQA Guidelines, a significant impact related to TCRs would occur if the project would:
▪ Threshold No. 1: Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or b. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1.

In applying the criteria set forth in subdivisio n (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

3.16.4 Project Impact Analysis
Impacts to TCRs that may result from ground disturbing activities associated with the project are analyzed below.

Threshold No. 1: Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a) Listed or eligible for listing in the California Register of Historical Resou rces, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or b) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set fo rth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Under California’s AB 52, TCRs are defined as archaeological resources that are eligible for or listed in the CRHR or resources that the lead agency determines to be a TCR with a substantial burden of evidence.

Based on information on TCRs received by the City to date, no TCRs have been identified that would be impacted by project implementation.

As described above, outreach letters were mailed on May 27, 2022, to all Native American group representatives included on the NAHC contact list (Appendix D). These letters attempted to solicit additional information relating to Native American resources that may be impacted by the project. Native American representatives were requested to define a general area where known resources intersect the project APE. To date, Dudek has received responses to these outreach letters from three tribal representatives. On June 17, 2022, San Pasqual Band of Mission Indians responded to the letter stating that the project APE is within the boundary of the tribe’s Traditional Use Area. San Pasqual stated that they would like to engage in “formal government to government consultation.” On June 21, 2022, Pechanga Band of Luiseño Mission Indians stated that the project APE is within their Ancestral Territory and that they are interested in participating in the project area. Pechanga added that the project APE is

3.16 – TRIBAL CULTURAL RESOURCES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.16-10
within 1.75 miles of two Ancestral Placenames and nine other previously recorded sites within 0.5 miles, one of which is within the project APE. Unfortunately, no other information about the intersecting resource was included but Pechanga is likely referring to the destroyed adjacent P-37-005584 knoll. On June 28, 2022, Rincon Band of Luiseño Indians responded to the outreach letter and stated that the project APE was within the band’s specific Area of Historic Interest. Rincon added that they were concerned that the project may impact Tribal Cultural Resources, Traditional Cultural Landscapes, or potential Traditional Cultural Properties. Rincon recommended an archaeological/cultural resources inventory and that a tribal monitor from the Rincon Band should accompany the survey staff. On July 12, 2022, Dudek archaeologist Matthew DeCarlo met Cheryl Madrigal, the tribal historic preservation officer for rincon band, at the project APE for a site visit. They discussed the previous disturbance of the area and visited the location of former prehistoric bedrock milling site P-37-005584. Ms. Madrigal stated that she would contact the City about her conc erns after she had some time to research the project area. On September 8, 2022, Rincon sent a letter to the City critiquing an earlier version of this report. Rincon requested an ethno-historic research and further analysis of adjacent sites P-37-005584 and P-37-005633.

In compliance with Assembly Bill 52 and Senate Bill 18, the City, as lead agency, is responsible for conducting government to government consultation with pertinent tribal entities. Rincon Band responded to City outreach for Senate Bill 18 and Assembly Bill 52 on February 16 and April 13 requesting consultation on the project.

The City had a consultation meeting with representatives of Rincon Band on August 16, 2022.

While considered unlikely based on the South Coastal Information Center records search, the current disturbed state of the project site, and other information received by the City to date ; there remains the potential for the project to encounter previously unknown and unanticipated TCRs during construction of the project (Impact TCR-1).

Implementation of previously identified mitigation in Section 3.4 of this EIR (Mitigation Measure [MM] CR-1 through MM-CR-4) would ensure potential impacts to TCRs as a result of ground-disturbing activities on the project site would remain less than significant with mitigation incorporated.

3.16.5 Cumulative Impact Analysis
Each cumulative project subject to AB 52 would require tribal consultation on a case -by-case basis to identify any potential TCRs affected by each cumulative project. It is anticipated that each cumulative project would require mitigation similar to that required of the project to reduce potentially significant impacts to TCRs to a level belo w significance. With implementation of project-specific mitigation and compliance with applicable regulations related to TCRs, cumulative impacts would be less than significant.

3.16.6 Mitigation Measures
Implementation of MM-CR-1 through MM-CR-4 outlined in EIR Section 3.4 would be required to ensure any potential impacts to unknown and unanticipated TCRs would remain less than significant.

3.16.7 Conclusion
Implementation of MM-CR-1 through MM-CR-4 outlined in Section 3.4 of this EIR would ensure any potentially significant impacts to TCRs (Impact TCR-1) remain less than significant.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-1

3.17 Utilities and Service Systems
This section describes the existing utilities setting of proposed Gran Vista Specific Plan Project (project), identifies associated regulatory requirements, and evaluates potential impacts related to water supply, water infrastructure, wastewater treatment capacity, wastewater infrastructure, and solid waste. Stormwater drainage and facilities are also analyzed in Section 3.9, Hydrology and Water Quality, of this environmental impact report (EIR). Energy consumption and conservation are addressed in Section 3.5, Energy, of this EIR.

The analysis herein relies on the following technical studies and supporting documentation:
▪ Preliminary Drainage Study for Gran Vista, prepared by Hunsaker & Associates, May 20, 2022 (included as Appendix G)
▪ Las Posas Meritage Homes Water and Sewer Study Final Technical Memorandum, prepared by Vallecitos Water District, March 23, 2022 (included as Appendix L) Table 3.17-1 summarizes the utilities and service system analysis by threshold.

Table 3.17-1. Utilities and Service Systems Summary of Impacts Threshold of Significance
Project -Level
Impact
Cumulative -
Level Impact
Significance
Determination
No. 1: Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm
water drainage, electric power, natural gas, or
telecommunications facilities, the construction or relocation of which could cause significant environmental effects.

Less than
Significant
Less than
Significant
Less than
Significant
No. 2: Have sufficient water supplies available to serve the project and reasonably foreseeable future development
during normal, dry and multiple dry years.

Less than
Significant
Less than
Significant
Less than
Significant
No. 3: Result in a determination by the wastewater
treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s
projected demand in addition to the provider’s
existing commitments.

Less than
Significant
Less than
Significant
Less than
Significant
No. 4: Generate solid waste in excess of State or local standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of solid waste reduction goals.

Less than
Significant
Less than
Significant
Less than
Significant
No. 5: Comply with federal, state, or local management and reduction statutes and regulations related to solid waste.

Less than
Significant
Less than
Significant
Less than
Significant

3.17.1 Existing Conditions
This section provides background information about the water, wastewater, and solid waste service providers that currently serve the project area and that would serve the project.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-2
Water
The project site is located within the Vallecitos Water District (VWD) for water services (Appendix L). According to the City of San Marcos General Plan (General Plan) , the VWD receives its water from the Metropolitan Water District of Southern California (MWD), which imports water from the Colorado River and Northern California (City of San Marcos 2012a).

MWD was formed in 1928 to develop, stor e, and distribute supplemental water to Southern California for domestic and municipal purposes. MWD consists of 26 member agencies and has a service area covering six counties, 5,200 square miles, and approximately 19 million people. MWD obtains water fro m local sources , as well as the Colorado River, via the Colorado River Aqueduct, and the Sacramento –San Joaquin Delta, via the State Water Project. MWD’s Urban Water Management Plan (UWMP) documents the availability of these supplies to meet future demands. With a projected annual water demand of 4,925,000 acre-feet per year for 202 5, the MWD UWMP concludes that, with implementation of required conservation measures, MWD has supply capabilities sufficient to meet expected demands through 204 5 under normal, single dry, and multiple dry water years (MWD 2021).

The MWD water demands through normal, single dry year, and multiple dry years are shown below in Table 3.17-2.

Table 3.17-2. MWD Total Water Demands (AFY)
Year 2025 2030 203 5 2040 204 5
Average Year 4,925,000 5,032,000 5,156,000 5,261,000 5,374,000 Single Dry Year 4,929,000 5,037,000 5,160,000 5,265,000 5,378,000 Multiple Dry Years 4,877,000 5,064,000 5,182,000 5,299,000 5,410,000 Source: MWD 2021.

Note: MWD = Metropolitan Water District of Southern California; AFY = acre-feet per year.

San Diego County Water Authority ( SDCWA) is the largest member agency of MWD. SDCWA ’s 2020 UWMP was approved on May 27, 2021. SDCWA’s mission is to provide a safe and reliable supply of water to its 24 member agencies serving the San Diego region, which includes VWD. SDCWA is San Diego County’s predominant source of water, supplying from 75% to 95% of the region’s water needs (SDCWA 2021). The population within the SDCWA’s service area was approximately 3.3 million people in 2020 and is projected to increase to roughly 3.8 million people by 2045. The County of San Diego is expected to develop an addit ional 130,000 acres between 2020 and 2050, with the majority (125,000 acres) of development dedicated to residential land uses. These regional growth projections are based on the San Diego Association of Governments Series 14 Regional Growth Forecast, developed for its 2019 Federal Regional Transportation Plan adopted by San Diego Association of Governments ’ Board of Directors on October 25, 2019. In fiscal year 2020, total water demand in the SDCWA’s service area was 463,128 acre-feet, of which 92% was for municipal and industrial use and 8% was for agricultural water use. By 2045, the SDCWA’s annual water demands are projected to reach 630,771 acre -feet. This projection accounts for planned future water conservation savings (SDCWA 2021).

The project site is entirely within the 855 zone. Water storage within this zone is located within the 920 zone and 1028 Twin Oaks pressure zones.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-3
Wastewater
The project site is located within the VWD for sewer services (Appendix L). The VWD currently has a wastewater system that has a total liquids treatment capacity of 12. 67 million gallons per day (MGD ) and has an estimated daily flow of approximately 7.5 MGD (Appendix L). VWD’s award-winning Meadowlark Water Reclamation Facility (MRF) is capable of recycling up to 74% of the wastewater generated in VWD’s service area. Built in 1961, MRF is located within the southwestern portion of VWD’s service area in Carlsbad. The MRF treats wastewater to meet the stringent standards of California Code of Regulations Title 22 and Waste Discharge Permit R9 -2007-0018 issued by the Regional Water Quality Control Board Region 9. The MRF has a capacity of 5 MGD , with a wet weather treatment capacity of 8 MGD. Recycled water from MRF travels through a 24-inch pipeline and is sold to the Carlsbad Municipal Water District and Olivenhain Municipal Water District. The Carlsbad Municipal Water District is contra cted to annually purchase 3 MGD, while Olivenhain Municipal Water District is contracted to annually purchase up to 1.5 MGD (VWD 2018).

Surplus water from the MRF is stored in the 54-million-gallon Mahr Reservoir. Of the total 54 million gallons within the reservoir, 32 million gallons are allocated to Carlsbad Municipal Water District, and 16 million gallons are allocated to Olivenhain Municipal Water District, leaving 6 million gallons for VWD to use in wastewater flow management. From here, water can be transported to the Encina Water Pollution Control Facility for disposal via a 3 MGD capacity failsafe pipeline. Under dry weather conditions, up to 1 MGD is conveyed for disposal. Under wet weather conditions, VWD would manage flow via the Mahr Reservoir to ensure flows to the Encina Water Pollution Control Facility would not exceed 2.5 MGD .1 According to VWD’s Master Plan, when the pipeline is at capacity, Carlsbad Municipal Water District has agreed to permit VWD to dispose of additional flow into their recycled water distribution system, subject to availability . In January 2010 through June 2014, VWD conveyed approximately

3.65 MGD of wastewater flow to the MRF for treatment and disposal (VWD 2018).

There are existing gravity sewer lines on the southwestern and northeastern sides of the project site. There is a 15-inch sewer line in N Las Posas Road and an 8 -inch line in W Mission Road . These gravity sewers all convey flow to N Las Posas Road where they are conveyed south to San Marcos Boulevard and eventually to District Lift Station No. 1.

Solid Waste
Solid waste disposal in the City of San Marcos (City) is provided by a private franchise hauler, EDCO Waste and Recycling (EDCO), a private waste collection and recycling company that handles all residential, commercial, and industrial collections within the City (City of San Marcos 2012a). Waste collected by EDCO is hauled to the Escondido Resource Recovery Transfer Station. Waste is then transported to the Sycamo re Sanitary Landfill in Santee, while r ecyclable materials are processed at the Escondido Resource Recovery Transfer Station (City of San Marcos 2012a). The project site would be serviced by EDCO.

The Escondido Resource Recovery Transfer Station has a permitted daily maximum capacity of 2,500 tons . Solid waste is consolidated here and trucked to a landfill for disposal. The transfer station is permitted to operate 7 days per week, 24 hours per day (County of San Diego 2008). The Sycamore Sanitary Landfill has a daily permitted throughput of 5,000 tons of solid waste, a remaining capacity of approximately 113,972,637 cubic yards, and an anticipated closure date of 2042 (CalRecycle 2019a).

1 Despite a total capacity of 3 MGD in the failsafe pipeline, permitted wastewater flows are determined by acceptable depth -to- diameter ratios to ensure infrastructure longevity and functioning systems. This means that maximum flows to the Encina Water Pollution Control Facility will be less than 3 MGD.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-4
Electrical and Gas
Electricity and natural gas would be provided by San Diego Gas & Electric (SDG&E) (City of San Marcos 2012a).

SDG&E provides energy service to an estimated 3.3 million consumers through 1.3 million electric meters and approximately 800,000 natural gas meters in San Diego Coun ty and southern Orange County (City of San Marcos 2012a). Electrical facilities throughout the City include a combination of aboveground and belowground electrical distribution lines and utilities structures. The City ’s fiber-optic network is facilitated b y a 72 -strand fiber-optic line that runs on various streets throughout the City. All major arterials in the City have implemented fiber optics. Proposed development on site would require constructing private utility lines to connect to existing electrical lines within N Posas Road and natural gas lines within N Las Posas Road and W Mission Road.

Telecommunications
Telecommunications services to the project site may be provided by various distributors . Existing AT&T and Cox telecommunication lines surround the project site.

3.17.2 Regulatory Setting
Existing federal, state, and local regulations related to water supply, wastewater, and solid waste that are applicable to the project are summarized below.

Federal
Clean Water Act
The federal Clean Water Act establishes regulatory requirements for potable water supplies including raw and treated water quality criteria. The City is required to monitor water quality and conform to regulatory requirements of the Clean Water Act.

Resource Recovery and Conservation Act
The Resource Recovery and Conservation Act , Subtitle D, focuses on state and local governments as the primary planning, regulating, and implementing entities for the management of non -hazardous solid waste, such as household solid waste and nonhazardous industrial solid waste. Subtitle D provides regulations for the generation, transportation, and treatment, storage, or disposal of hazardous wastes.

State
Urban Water Management Plans
Urban water purveyors are required to prepare and update a UWMP every 5 years. The UWMPs address water supply, treatment, reclamation, and water conservation and contain a water shortage contingency plan. Local UWMPs and those of other water districts are supplemental to the regional plans pr epared by MWD. The Water Conservation Bill of 2009 ( Senate Bill [S] X7-7) requires each urban retail water supplier to develop an urban water use target and an interim urban water use target. Notably, SB X7-7 authorizes urban retail water suppliers to determine and report progress toward achieving these targets on an individual agency basis or pursuant to a regional alliance as provided in California Water Code Section 10608.28(a). As described above, water service to

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-5
the site is provided by MWD. In accordance with this regulation, MWD prepared and their Board of Directors adopted its 20 20 UWMP in 20 21. MWD’s UWMP includes estimated future water demands until 2040, using updated population projections and a conservative assumption that, in the ab sence of mandatory water conservation measures, per -capita consumption could rebound to its 2020 target value (MWD 2021). Demands provided in MWD UWMP have been coordinated with SDWCA, MWD’s wholesale supplier.

California Green Building Standards Code
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 of the California Code of Regulations ) is commonly referred to as CALGreen and establ ishes minimum mandatory standards and voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and interi or air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground-up, new construction of commercial, low -rise residential and state -owned buildings and schools and hospitals. The CALGreen 20 22 building standards code became effective on January 1, 2023. The mandatory standards require the following measures that relate to utilities and service systems (24 CCR Part 11):
▪ Mandatory reduction in indoor water use through compl iance with specified flow rates for plumbing fixtures and fittings
▪ Mandatory reduction in outdoor water use through compliance with a local water efficient landscaping ordinance or the California Department of Water Resources’ Model Water Efficient Landscape Ordinance ▪ 65% of construction and demolition waste must be diverted from landfills ▪ Mandatory inspections of energy systems to ensure optimal working efficiency ▪ Inclusion of electric vehicle charging stations or designated spaces capable of supporting fu ture charging stations
The CALGreen standards also include voluntary efficiency measures that are provided at two separate tiers and implemented at the discretion of local agencies and applicants. CALGreen’s Tier 1 standards call for a 15% improvement in e nergy requirements, stricter water conservation, 65% diversion of construction and demolition waste, 10% recycled content in building materials, 20% permeable paving, 20% cement reduction, and cool/solar-reflective roofs. CALGreen’s more rigorous Tier 2 st andards call for a 30% improvement in energy requirements, stricter water conservation, 75% diversion of construction and demolition waste, 15% recycled content in building materials, 30% permeable paving, 25% cement reduction, and cool/solar-reflective roofs.

Senate Bill 221
Signed into law on October 8, 2001, SB 221 established a process whereby sufficient water supply must be identified and available for new development for any residential development of 500 homes or more or, in the case wherein a water supplier has fewer than 5,000 service connections or the pr oposed development would increase the number of connections by at least 10 %, unless there is proof of adequate water over at least the next 20 years, including long periods of drought. Because the project is fewer than 500 homes , a water supply assessment and verification report pursuant to SB 221 and SB 610, described below, are not required.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-6
Senate Bill 610
Signed into law October 9, 2001, SB 610 resulted in amendments to the California Public Resources Code and the California Water Code. Revising provis ions established by SB 901, SB 610 requires that the planning agency determine whether a project subject to the California Environmental Quality Act ( CEQA) meets any of the thresholds for requiring preparation of a water supply assessment. Specifically, if a project proposes development of more than 500 dwelling units, the planning agency must then request that the urban water supplier prepare a water supply assessment. The assessment would include the identification of existing water entitlements, water rights, or water service contracts relevant to the water supply identified for the project, as well as the amount of water received pursuant to such entitlements, rights, or contracts. Because the project is fewer than 500 homes , a water supply assessment pursuant to SB 610 is not required.

Assembly Bill s 939 and 341
In 1989, Assembly Bill ( AB) 939, known as the Integrated Waste Management Act (California Public Resources Code, Section 40000 et seq.), was passed because of the increase in waste stream and the 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 where jurisdictions were required to meet diversion go als of all solid waste through source reduction, recycling, and composting activities of 25% by 1995 and 50% by 2000.

AB 341 (2011) amended the California Integrated Waste Management Act of 1989 to include a provision declaring that it is the policy goal o f the state that not less than 75% of solid waste generated be source -reduced, recycled, or composted by the year 2020 and annually thereafter. In addition, AB 341 required the California Department of Resources Recycling and Recovery (CalRecycle) to devel op strategies to achieve the state’s policy goal. CalRecycle has conducted multiple workshops and published documents that identify priority strategies that CalRecycle believes would assist the state in reaching the 75% goal by 2020.

Local
San Diego Count y Integrated Waste Management Plan
Pursuant to the Integrated Waste Management Act , the Countywide Integrated Waste Management Plan for San Diego County describes the goals, policies, and objectives of the county for coordinating efforts to divert, market, and dispose of solid waste during the planning period through the year 2022 (County of San Diego 2005).

Countywide policies for reducing waste and implementing the programs are identified in the individual jurisdiction Source Reduction and Recycling Elements and Household Hazardous Waste Elements and are intended to reduce costs, streamline administration of programs, and encourage a coordinated and planned approach to integrated waste management.

To avoid duplication of effort, all of the jurisdict ions in the county participate in the San Diego County Integrated Waste Management Local Task Force. The Local Task Force coordinates mandated planning, oversees implementation of new or countywide integrated waste management programs, and carries out an active legislative program. Regulatory reform, changes to state diversion requirements, and reduction of the costs of compliance are considered by the Local Task Force, as well as other solid waste issues of regional or countywide concerns.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-7
City of San Marc os Municipal Code
Title 8, Health and Sanitation
San Marcos Municipal Code (SMMC) Title 8 contains regulations and provisions on sewers and sewage disposal plants, sewer connections, septic tanks, waste matter, garbage and refuse collection, and other mat ters concerning sanitation.

Title 14, Streets, Sidewalks, and Underground Utility Facilities SMMC Title 14, Chapter 14.15, contains regulations concerning stormwater management and discharge control.

Chapter 14.24 contains regulations concerning underground utility facilities.

Title 19, Subdivisions
SMMC Title 19 regulates subdivision requirements, including the installation of utility facilities and connections and payment or fees for such installations.

Title 20, Chapter 20.330 Water Efficient Landsca ping Ordinance The provisions of Title 20 of the SMMC are referred to as the Zoning Ordinance. SMMC Title 20, Section 20.330, details the City’s Water Efficient Landscap ing Ordinance. In accordance with state law, SMMC Chapter 20.330 establishes specific s tandards for landscape and irrigation design and installation to ensure beneficial, efficient , and responsible use of water resources within the City.

City of San Marcos General Plan
The General Plan Conservation and Open Space Element includes two goals and one policy that are applicable to the project (City of San Marcos 2012b):

Goal COS -5: Reduce water consumption and ensure reliable water supply through water efficiency, conservation, capture, and reuse.

Goal COS-10: Establish and maintain an innovative, sustainable solid waste collection, recycling, and disposal delivery system for present and future generations.

Policy COS-10.1: Promote the curbside recycling program to divert residential refuse from the landfills.

The General Plan Land Use and Community Design Element identifies the following goals and policies regarding utilities and services systems that are applicable to the project (City of San Marcos 2012a):

Goal LU-8: Ensure that existing and future development is adequately serviced by infrastructure and public services.

Policy LU -8.1: New development shall pay its fair share of required improvements to public facilities and services.

Policy LU -8.2: Promote development timing that is guided by the adequacy of existing and/or expandable infrastructure, services, and facilities.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-8
Goal LU-13: Water Service and Supply: Manage and conserve domestic water resources by reducing water usage and waste on a per capita basis, to ensure an adequate water supply for existing and future residents.

Policy LU-13.1: Work closely with local and regional water providers to ensure high quality water supplies are available for the community.

Policy LU-13.2: Actively promote water conservation programs aimed at reducing demand.

Policy LU-13.3: Encourage exploration and use of deep underground wells to reduce reliance on treatable water.

Goal LU-14: Wastewater: Ensure a wastewater system for existing and future development.

Policy LU-14.1: Work closely with local service providers to en sure an adequate wastewater system for existing and future development is in place.

Policy LU -14.2: Ensure development approval is directly tied to commitments for the construction or improvement of primary water, wastewater, and circulation systems.

Goal LU-16: Solid Waste: R educe the amount of waste material entering regional landfills with an efficient and innovative waste management program.

Policy LU -16.1: Work closely with local service providers to ensure adequate solid waste disposal, collection, and recycling services.

Policy LU-16.2: Increase recycling, composting, source reduction, and education efforts throughout the city to reduce the amount of solid waste requiring disposal at landfills.

Goal LU -17: Utilities and Communications: Encourage provision of power and communication systems that provide reliable, effective and efficient service for San Marcos.

Policy LU-17.2: Require all new development and redevelopment to provide the technology to support multiple telecommunications facilities and providers such as multi -media products, wireless technologies, and satellite communications.

Policy LU -17.3: The City shall prohibit above ground utility equipm ent within any of the pedestrian pathway and street frontage areas. All above ground utilities shall be placed either within; “wet closets” within the buildings, underground vaults, or behind buildings where they are not visible.

The developer shall be res ponsible to contact the applicable utility agencies in advance to coordinate utilities prior to approval of the final street improvement plans for both public and private street frontages and prior to submittal of building permits.

Policy LU -17.4: Require utility location to be shown on all site development plans at the time of development/ project application.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-9

3.17.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to utilities and service systems are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to utilities and service systems would occur if the project would:
▪ Threshold No. 1: Require or result in the relocation or construction of new or ex panded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunication s facilities, the construction or relocation of which could cause significant environmental effects. ▪ Threshold No. 2: Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years. ▪ Threshold No. 3: Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.
▪ Threshold No. 4: Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. ▪ Threshold No. 5: Comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

3.17.4 Project Impact Analysis
Threshold No. 1: Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunication s facilities, the construction or relocation of which could cause significant environmental effects.

Water
The project development would be served by VWD. Townhome residential sites in the VWD are typically served by on-site private water systems, which consist of separate fire and domestic systems on site. Private fire systems typically supply on -site fire hydrants and building fire sprinkler systems and require a backflow preventer at the connection to the public water system.

The distribution of potable water to each home would be provided by a series of 8 -inch public pipes and related infrastructure. The proposed water system would connect to an existing 8 -inch pipe in N Las Posas Road. Pipes would be located within private drives and private drive aisles to create a loop system that serves the entire project site. Individual services to homes would be provided by a lateral from the main pipe to the water meter for each home.

A dedicated fire main would provide fire service to a series of new and existing fire hydrants , as well as to the individual units, for firefighting purposes. There are two existin g fire hydrants on the project site that are already in service and would remain in place.

In accordance with current California Building Code, all buildings would be equipped with fire sprinklers and water conservation features such as water efficient fau cets and shower heads and high -performance toilets. Homes would be Water Sense Certified to meet U.S. Environmental Protection Agency standards.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-10
Irrigation for the site will tie into the proposed loop system. Irrigation of landscaping throughout the project site would be required to comply with the City’s Water Efficient Landscaping Ordinance and the City’s Landscape Manual.

The domestic system for the project would consist of a single connection to the public water system with an on - site loop ing system. A water meter and backflow preventer would be required at the connection to the public water system. The project would connect to the existing 855 Zone water facilities within N Las Posas Road .

Landscaped areas associated with the project would require a separate irrigation service and meter. A water and sewer study was prepared by VWD for the project and is included as Appendix L to this EIR . Prior to project construction, VWD will confirm capacity fees to be paid by the project applicant. Therefore, due to the location of the project site in an urbanized area that is currently served by existing facilities, the project is not expected to require or result in the relocation or construction of new water facilities and impacts to water services would be less than significant.

Wastewater
As described above, the project would develop 120 townhomes, which would increase the intensity of uses on the project site and result in increased wastewater generation. The Water and Sewer Memorandum prepared for the project estimated that buildout of the project would generate approximately 24,882 gallons of wastewater per day (Appendix L).

There are existing gravity sewer lines on the southwestern and northeastern sides of the project site, including an 8-inch sewer lines in W Mission Road and a 15-inch line in N Las Posas Road . These gravity sewers all convey flow to N Las Posas Road where they are conveyed south to San Marcos Boulevard and eventually to District Lift Station N o. 1. Sewer service to the project site would consist of constructing private on -site sewer lines and connecting to the public system. A wastewater system would be incorporated into the project site design, which would include an 8 -inch PVC sewer main to adequately service individual homes and community areas discharging wastewater. Pipes would be located underneath internal private drives and private drive aisles. The on-site system would collect wastewater and direct flows into an existing 15-inch pipe in N Las Posas Road.

Wastewater generated by the project would be treated by the MRF. MRF has a capacity of 5 MGD, with a wet weather treatment capacity of 8 MGD , and treats wastewater at 0.25 MGD . It is expected that the MRF would be able to ad equately treat wastewater flows from the project, and therefore new wastewater treatment facilities would not be needed.

The City requires that VWD provide a letter of Sewer Availability for proposed developments within VWD. VWD conducted a sewer study for the proposed development to determine whether the current infrastructure is sufficient to accommodate the development project and/or to provide recommendations for capital improvements to provide service. As discussed in the Water and Sewer Memorandum (Ap pendix L), the applicant would be required to pay all applicable Wastewater Capital Facility fees in effect at the time service is committed in accordance with VWD rules and regulations . A cceptance by VWD of all wastewater facilities required to be constructed to service the project would also be required. With implementation of City and VWD requirements for sewer service, and considering the scope of existing and proposed infrastructure, the project is not anticipated to exceed current capacities or significantly impact existing wastewater treatment systems. Further, to the extent the project will require or result in the relocation or construction of sewer facilities, the construction of such infrastructure has been considered throughout this EIR (e.g., within the project description and construction assumptions) and would not cause significant environmental effects. Therefore, impacts to wastewater services would be less than significant.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-11
Storm water Drainage
Development of the project would increase the impervious area on site and increase stormwater runoff in comparison to existing conditions. However, as described in Section 3.9 of this EIR, storm drainage components recommended by the Preliminary Drainage Study (Appendix G) would properly handle runoff to meet regulatory requirements and to ensure that post -development runoff quantifies rates would be similar to or less than pre - development conditions.

Stormwater arrives on site via natural rainfall only. Rainfall runoff f rom the site typically only occurs during a significant wet weather event. Stormwater that does accumulate on site generally drains in a southwester n direction to an existing 12-inch corrugated metal pipe riser to a 12-inch corrugated metal pipe to meet up with the commercial site to the south of the project site and is then conveyed west through a storm channel and eventually downstream to the Las Posas Creek south. Per municipal separate storm sewer system requirements, stormwater flows on site would be c onveyed to biofiltration systems through storm drains throughout the project site, where water would be treated prior to being discharged. Storm drainage components would properly handle runoff to meet regulatory requirements and to ensure that post -development runoff quantifies rates are similar to or less than pre -development conditions. The project would incorporate appropriate design of on - and off -site drainage facilities and would prepare and implement a stormwater pollution prevention plan , stormwater quality management plan, and best management practices.

Implementation of all recommendations from the Preliminary Drainage Study and development -specific drainage plans would ensure the project would not substantially exceed stormwater drainage capacity or result in substantial polluted runoff. The construction of such improvements has been considered throughout this EIR (e.g., within the project description and construction assumptions) and has not been identified to cause significant environmental effe cts. Therefore, impacts would be less than significant . Please refer to Section 3.9 for additional discussion related to drainage.

Electric Power
As discussed in Section 3.5 of this EIR, implementation of the project would not result in inefficient, wasteful, or unnecessary electricity use. Temporary electric power for as-necessary lighting and electronic equipment (such as computers inside temporary construction trailers and heating, ventilation, and air conditioning ) would be provided by SDG&E. The amount of electricity used during construction of the project would be minimal because typical demand stems from the use of electronic equipment in addition to electrically powered hand tools. The majority of the energy us ed during construction would be from petroleum. The electricity used for construction activities would be considered temporary and minimal.

Project operation would require electricity for multiple purposes, including cooling, lighting, appliances, and various equipment. Additionally, the supply, conveyance, treatment, and distribution of water would indirectly result in electricity usage. The project is estimated to have a total electrical demand of approximately 0.7 million kilowatt-hours of electricity pe r year. Additionally, the project would be required to implement, as applicable, the City’s Climate Action Plan Consistency Checklist measures that would reduce operational electricity consumption.

The project would be required to include various on -site features and measures to reduce the project’s energy consumption, which includes electric vehicle charging stations, electric or solar water heaters, solar panels, a transportation demand management plan, reduced landscaping water use, and trees . The project would be built under the 2019 Title 24 standards or newer standards. 2019 Title 24 homes would use about 53% less energy than those under the 2016 Title 24 standards.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-12
Electricity and natural gas would be prov ided by SDG&E. Electrical facilities throughout the City include a combination of aboveground and belowground electrical distribution lines and utilities structures. The City fiber - optic network is facilitated by a 72-strand fiber-optic line that runs on various streets throughout the City. All major arterials in the City have implemented fiber optics. The project would require constructing private utility lines to connect to existing electrical lines within N Las Posas Road.

In summary, although electricity consumption would increase at the project site over current, vacant conditions , project would be required to comply with the Title 24 and the City’s Climate Action Plan Consistency Checklist by implementing energy-efficiency measures that would further reduce electricity usage. Residential development on site is not expected to exceed existing capacity of servicing infrastructure. Therefore, implementation of the project would not require or result in the relocation or construction of expanded electric power facilities and impacts would be less than significant.

Natural Gas
As discussed in Section 3.5, natural gas is not anticipated to be required during construction of the project. The proposed residential land use/ zoning change is estimated to use approximately 247 million kBTU of natural gas per year, equivalent to 24,672 therms of natural gas per year. Further, the project would be required to implement project design features and comply with green building standards to reduce energy consumption.

As described above, natural gas would be provided by SDG&E. The project would require constructi on of private utility lines to connect to an existing natural gas pipeline within N Las Posas Road and W Mission Road . SDG&E maintains a 4 -inch gas distribution system within N Las Posas Road and a 3 -inch distribution system within W Mission Road. The gas li nes would be extended to and t hrough the project site through the same joint trench alignment as electric and telecommunication facilities. Use of gas for the project would be limited to gas cooktops and gas dryers.

Due to existing SDG&E infrastructure in the project area, the project is expected to be adequately served by SDG&E. However, a will -serve letter from SDG&E would be required to ensure service needs are met. For these reasons, implementation of the project would not require or result in the relocation or construction of new or expanded natural gas facilities, and impacts would be less than significant.

Telecommunications
Communications systems for telephones, computers, and cable television are serviced by utility providers such as AT&T, Cox, and othe r independent cable companies. No specific systems upgrades are proposed or anticipated for the project. Due to the existing infrastructure served in the surrounding project area , the project would not result in impacts associated with the construction or expansion of telecommunications, and impacts would be less than significant.

Threshold No. 2: Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years? As discussed in response to Threshold No. 1, the project would be served by VWD. Per the Water and Sewer Memorandum (Appendix L), the project is anticipated to use a n estimated 37,700 gallons per day. This equates to approximately 42.26 acre-feet per year.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-13
As discussed above, MWD’s 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 202 5, 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 projected by the MWD’s UWMP.

Further, 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. VWD requires a development -specific evaluation of water use to determine its ab ility to service any development and capacity fees to be paid. A Water Availability letter will be required for processing the project (VWD 2021). Compliance with these regulations and conservation measures will ensure sufficient water supplies are available to service the project. Impacts to water services would be less than significant.

Threshold No. 3: Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to s erve the project’s projected demand in addition to the provider’s existing commitments?
As discussed under Threshold No. 1, wastewater generated by the project would be treated by the MRF. MRF has a capacity of 5 MGD, with a wet weather treatment capacity of 8 MGD , and treats wastewater at 0.25 MGD .

The project is estimated to generate 24,882 gallons per day , or approximately 0.49% of the facility’s 5 MDG capacity. It is expected that the MRF would be able to adequately treat wastewater flows from the project.

As described above, sewer facilities to serve the project would require the construction of private on -site sewer lines connecting to the public system within N Las Posas Road. As discussed in the Water and Sewer Memorandum (Appendix L), the applicant of the project would be required to pay all applicable Wastewater Capital Facility fees in effect at the time service is committed in accordance with VWD rules and regulations.

Acceptance by VWD of all wastewater facilities required to be constructed to service the project would also be required. With implementation of City and VWD requirements for sewer service, and considering the scope of existing and proposed infrastructure, the project is not anticipated to exceed current capacities or significantly impact existing wastewater treatme nt systems. Further, to the extent the project will require or result in the relocation or construction of sewer facilities, the construction of such infrastructure has been considered throughout this EIR (e.g., within the project description and construction assumptions) and would not cause significant environmental effects. Therefore, impacts to wastewater services would be less than significant.

Threshold No. 4: Generate solid waste in excess of State or local standards, or in excess of the capacity of l ocal infrastructure, or otherwise impair the attainment of solid waste reduction goals? Construction of the project would result in the generation of solid waste such as scrap lumber, concrete, residual wastes, packing materials, and plastics. Operation of the project would represent an increase in intensity of uses and generation of solid waste on the project site compared to existing conditions. Solid waste generated by the project would be serviced by EDCO, and solid waste would then be transferred to S ycamore Landfill. According to CalRecycle, the facility has a daily permitted capacity of 5,000 tons per day for solid waste. As of December 2016, the remaining capacity of Sycamore Sanitary Landfill is 1 13,972,673 cubic yards, with an anticipated closure date of 2042. Further, three other landfills in the County of San Diego accept municipal solid waste, including Borrego Landfill, Miramar Landfill, and Otay Landfill.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-14
The anticipated operational solid waste generation from the project was estimated using CalRecycle’s Estimated Solid Waste Generation Rates (CalRecycle 2019 b). It is estimated that the project ( 120 units) would generate approximately 1,467.6 pounds of solid waste per day (12.23 pounds per household). This does not consider any waste diversion through recycling. According to CalRecycle, the City has a disposal rate target of 8.9 pounds per person per day. If the City meets this target, the City is considered in compliance with the 50 % diversion requirement of AB 939. The most recent data from CalRecycle identif y the annual per capital disposal rate as

4.9 pounds per person per day (CalRecycle 2020). Thus, the City is exceeding their target for diversion.

The project would be required to comply with applicable state and local regulations related to solid waste, waste diversion, and recycling at the time of development. Implementation of the project is not expected to generate solid waste in excess of state or local standards or in excess of the capacity of local infrastructure, or to otherwise impair the attainment of solid waste reduction goals. Impacts related to solid waste would be less than significant.

Threshold No. 5: Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
As described in response to Threshold No. 4, the project would be required to comply with all federal, state, and local statutes and regulations related to solid waste, diversion of waste, and recycling . All solid waste facilities, including landfills, require solid waste facility permits to operate. In San Diego County, California Public Resources Code, Sections 44001–44018, and California Code of Regulations Title 27, Division 2, Subdivision 1, Chapter 4 , Section 21440 et seq. , authorize the County Department of Environmental Health, Local Enforcement Agency to issue solid waste facility permits. Sycamore Sanitary Landfill is a permitted facility and EDCO is a licensed hauler.

For these reasons, and the reasons stated above, impacts related to solid waste as a result of project implementation would be less than significant.

3.17.5 Cumulative Impact Analysis
Water
Some of the cumulative projects are within VWD service area for potable water service and would contribute to the cumulative demand for water supply. However, MWD anticipates the demand of future development through their master planning process. According to MWD’s UWMP, no water shortages are anticipated within MWD service area in single o r multiple dry years through 2045. Not all cumulative projects fall into the VWD’s service area; those that do not would be served by neighboring districts.

As described in Section 3.17.4, the project would result in less-than-significant impacts to water supply services.

As discussed in Section 3.17.1, MWD has determined that with supplies provided by SDCWA and compliance with the Water Conservation Bill of 2009, no water shortages would occur in a normal year through 204 5 (MWD 2021). Other c umulative projects that are consistent with the land use assumptions made in MWD’s UWMP would have already been accounted for in demand projections. Projects that are inconsistent with the land use assumptions made in MWD’s UWMP would also be subject to CEQA and required to include water supply assessments to demonstrate adequate supply for d evelopment. Further, related projects would be required to show that adequate infrastructure exists to serve the related projects and mitigate any potential impacts to water infrastructure caused by the project. All projects would be required to pay applicable Capital Facility fees to the SDCWA and VWD , which are required to go towards infrastructure improvements. Thus, cumulative impacts to water services would be less than significant.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-15
Wastewater
Some of the cumulative projects are within VWD’s service area for wastewater service and would contribute to the cumulative demand for wastewater treatment. VWD anticipates the demand for future development through their master planning process. Cumulative projects that are consistent with the land use assumption s made in VWD’s Master Plan would have already had their demand accounted for. Lastly, not all cumulative projects fall into the VWD’s service area; those that do not would be served by neighboring districts.

As discussed in Section 3.17.4, VWD has sufficient capacity to account for the project’s estimated wastewater generation rate. Thus, with payment of all applicable Wastewater Capital Facility fees to VWD, impacts to wastewater treatment facilities would be less than significant. Cumulative projects that result in an increase in density or development over what was accounted for in VWD’s Master Plan would further exacerbate wastewater deficiencies. However, these projects would also be subject to CEQA and re quired to mitigate any potential impacts to water supply services caused by the project. As such, cumulative impacts to wastewater facilities would be less than significant.

Electrical Power
Potential cumulative impacts on energy would result if the project, in combination with past, present, and future projects, would result in the wasteful or inefficient use of energy. This could result from development that would not incorporate sufficient building energy efficiency features, would not achieve building energy efficiency standards, or would result in the unnecessary use of energy during construction and/or operation. The cumulative projects within the areas serviced by the energy service providers would be applicable to this analysis; this includes existing aging structures that are energy inefficient. Projects that include development of large buildings or other structures that would have the potential to consume energy in an inefficient manner would have the potential to contribute to a cumulative impact . Projects that would mostly include construction, such as transportation infrastructure, could also contribute to a cumulative impact; however, the impact of these projects would be limited because they would typically not involve substantial ongoing energy use.

As described previously in Section 3.5 , the project would not result in significant environmental impacts due to wasteful, inefficient, or unnecessary use of energy due to various design features, including installing electric vehicle charging sta tions, installing electric or solar water heaters, implementing a Transportation Demand Management plan, reducing landscaping water use, and planting trees, that would be required of the project. Like the project, cumulative projects would be subject to CA LGreen, which provides energy efficiency standards for commercial and residential buildings. Over time, CALGreen would implement increasingly stringent energy efficiency standards that would require the project and the cumulative projects to minimize the w asteful and inefficient use of energy. In addition, cumulative projects would be required to meet or exceed the Title 24 building standards, further reducing the inefficient use of energy.

Cumulative projects are also required to comply with the state’s energy efficiency standards and local regulations.

Cumulative projects are therefore unlikely to result in significant effects related to requiring or resulting in the relocation or construction of new or expanded electric power facilities. As such, cumulative impacts related to electrical power would be less than significant.

3.17 – UTILITIES AND SERVICE SYSTEMS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 3.17-16
Solid Waste
Cumulative development projects would generate solid waste to be disposed of at the Sycamore Sanitary Landfill.

According to CalRecycle, the facility has a daily permitted capacity of 5,000 tons per day for solid waste. As of February 2021 , the remaining capacity of Sycamore Sanitary Landfill is 113,972,673 cubic yards, or approximately 40 million tons, with an anticipated closure date of 2042. Further, three other landfills in the County of San Diego accept municipal solid waste (County of San Diego 20 22). This includes Borrego Landfill, with a remaining cap acity of 88,750 cubic yards in January 2020 ; Otay Landfill, with a remaining capacity of

11.1 million cubic yards in February 2021; and Miramar Landfill, with a remaining capacity of 11.0 million cubic yards in January 2020 (County of San Diego 2022) . Therefore, it is determined there is adequate capacity throughout the County of San Diego to serve future development projects, including those identified on the cumulative project list. Cumulative impacts related to solid waste would be less than significant.

3.17.6 Mitigation Measures
Impacts to utilities and service systems would be less than significant, and no mitigation is required.

3.17.7 Conclusion
Project implementation would result in an increase in the need for water, wastewater, stormwater, electrical power, and solid waste services. However, as outlined in the project impact a nalysis in Section 3.17.4, there would be adequate existing facilities to service the project ; impacts to /from such utilities and service systems would be less than significant.

GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-1
4 Alternatives

4.1 Introduction
Section 15126.6 of the California Environmental Quality Act (CEQA) Guidelines states that the environmental impact report (EIR) shall “describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of th e project and evaluate the comparative merits of the alternatives.” The comparative merits of the alternatives evaluated, including the No Project Alternative, shall also be discussed.

The range of alternatives evaluated in an EIR is governed by the “rule of reason,” which requires the EIR set forth alternatives adequate to permit a reasoned choice by decisionmakers and limited to alternatives that “would avoid or substantially lessen any of the significant effects of the project.” An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose implementation is remote and speculative (14 CCR 15126.6[a]).

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.

Factors that may influence feasibility of an alternative also include “site suitability, economic viability, availabili ty of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control, or otherwise have access to the alternative site (or the site is already owned by t he proponent)” ( 14 CCR 15126.6[f][1]). The ultimate determination as to whether an alternative is feasible or infeasible is made by the lead agency’s decision ‐making body, the San Marcos City Council (California Public Resources Code, Section 21081[a][3]).

This section presents several alternatives to the proposed Gran Vista Specific Plan Project (project) that were considered pursuant to CEQA and evaluated for their ability to meet the basic objectives of the project, while reducing or avoidin g the environmental impacts of the project identified throughout Chapter 3, Environmental Analysis, of the EIR. The alternatives proposed herein include the No Project Alternative ( Section 4.4.3), the Existing Land Use Designation Alternative ( Section 4.4.4), and the Reduced Density Alternative (Section 4.4.5).

Other alternatives were considered but rejected, as summarized in Section 4.3.

4.2 Project Objectives
The following objectives of the proposed project describe the underlying purpose of the project and provide a basis for identification of a range of reasonable alternatives evaluated in this EIR:

1. Maximize residential densities, to the extent feasible, within proximity to major transit, education facilities, commercial uses, and trail s to reduce reliance on automobiles and potentially minimize greenhouse gas (GHG) emissions.

2. Create a highly connected and efficient system of sidewalks and pathways supported by pedestrian friendly architecture and landscaping to promote walkability and connect people to surrounding transit and destinations.
4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-2

3. Design a vehicular circulation system that adequately accommodates traffic and minimizes traffic impacts in and around the project site.

4. Support the housing needs of the City of San Marcos (City) and the region by developing high -quality workforce housing that balances density with price -points and long -term maintenance costs, such that new homes remain financially attainable to entry-level home buyers.

5. Establish development standards and design guidelines that ensure distinctive architecture, landscaping, and recreational amenities that complement and enhance the existing surrounding neighborhood while providing a desirable living environment.

6. Identify a program for the long -term maintenance of the community to ensure all facilities are adequately maintained to City standards.

7. Finance or contribute a fair share of funding to all community services and infrastructure needed to support development proposed by the project to promote economic stability.

4.3 Alternatives Considered But Rejected
The CEQA Guidelines state that an EIR should identify any alternatives that were considered by the lead agency but were rejected during the planning or scoping process, and should briefly explain the reasons unde rlying the lead agency’s determination. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: failure to meet most of the basic project objectives, infeasibility, or inability to avoid significant environmental impacts. Factors that may be taken into account when evaluating an alternative’s feasibility include, among other things, site suitability, economic viability, availability of infrastructure, general plan consistency, consistency with other plans, reg ulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control, or otherwise have access to the alternative site (or the site is already owned by the proponent). The following describes concepts that were considered as alternatives to the proposed project by the City but were rejected from further evaluation in this EIR, and a brief description of the reasons for their rejection.

4.3.1 Alternative Location
Pursuant to Section 15126.6(f)(2) of the CEQA Guidelines, t he City considered the potential for alternative locations to develop the proposed project. There are sites within the City that are already zoned for residential use under the City of San Marcos General Plan (General Plan) that could be developed or redeveloped with a residential project. However, the project applicant does not control another site within the City of comparable land area that is surrounded by existing infrastructure and near existing transit. One of the factors for feasibility of 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 not con sidered feasible. The project site is surrounded on all sides by development and considered an infill site in an urban area . As such, an alternative location was ultimately rejected from further analysis in the EIR.
4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-3

4.4 Project Alternatives Considered in this EIR

4.4.1 Description of Alternatives
The following alternatives are under consideration for this project:
▪ No Project Alternative (Section 4.4.3)
▪ Existing Land Use Designation Alternative (Section 4.4.4) ▪ Reduced Density Alternative (Section 4.4.5)
Alternatives considered and removed from further consideration are summarized in Section 4.3.

4.4.2 Summary of Project Impacts
Project- and cumulative -level impacts associated with implementation of the proposed project are evaluated throughout Chapter 3 of this EIR. As identified in Table 1‐1, in Chapter 1, Executive Summary, construction and/or operation of the proposed project would cause the following significant but mitigable environmental impacts:
▪ Impact BIO-1: There is potential for project activities to cause disturbances that would result in impacts to adjacent habitat.
▪ Impact BIO-2: There is potential for construction activities could result in indirect impacts to nesting birds. ▪ Impact CR-1: Unknown archaeological resources may occur on the project site, and the proposed project has the potential to disturb such unidentified resources during project grading. ▪ Impact CR-2: There is a potential for project construction activities to disturb previously unidentified human remains on the project site.
▪ Impact TCR-1: There is potential for project construction to adversely affect previously unidentified tribal cultural resources.

The following impacts are significant and unavoidable:
▪ Impact TRA -1: The project vehicle miles traveled ( VMT) per resident would exceed 16.07 VMT per resident, which exceeds the 15% below regional average threshold.

4.4.3 No Project Alternative
Under the No Project Alternative, the proposed project would not be implemented and the project site would remain undeveloped in its existing condition. This alternative would eliminate all the significant impacts identified for the proposed project. Since the No Project Alternative would not provide any development, overall impacts would be reduced compared to the proposed project. However, certain benefits would not be realized under this alternative, including the provision of housing units as identified in the General Plan in an infill and transit area. 4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-4

4.4.3.1 Comparison of the Effects of the No Project Alternative to the Proposed Project
Aesthetics
Under the No Project Alternative, the site would remain in its current condition and the visual character of the site would not change. Existing vegetation would remain on site, and no grading or landform modificati on would occur under this alternative. This alternative would result in no impacts related to scenic vistas, scenic highways, visual character or quality, or lighting and glare. No new sources of light, glare, or shading would be introduced.

However, as di scussed in Section 3.1, Aesthetics, of this EIR, the proposed project would similarly not result in significant impacts to aesthetics and no mitigation would be required. Further, leaving the site condition unchanged in an infill area would be inconsistent with, and not enhance, the character of the surrounding area.

However, when compared to the proposed project, this alternative would reduce impacts, as no new development or construction would occur.

Air Quality
Under the No Project Alternative, air poll utant emissions associated with construction, including emissions associated with grading, site preparation, site finishing and building finishing, would not occur. This alternative would avoid any potential impacts related to construction volatile organic compound emissions, because no construction air pollutant emissions would occur. Implementation of this alternative would not introduce any uses that would generate operational air pollutant emissions. Although the proposed project would result in less -than- significant impacts related to air quality , the No Project Alternative would reduce air quality impacts overall, because no development would occur.

Biological Resources
The No Project Alternative would not require any ground -disturbing activities. As such, this alternative would not result in direct impacts to biological resources. Because impacts to biological resources would be avoided under the No Project Alternative, Mitigation Measure ( MM) BIO-1 and MM-BIO-2 proposed for the project would not be implemented or required for this alternative. Thus, compared to the proposed project, this alternative would result in a reduced level of direct impacts to biological resources.

Cultural Resources
The No Project Alternative would not require any ground -disturbing activities. Therefore, there would be no potential to impact unknown archae ological resources potentially located within the project site. Further, there would be no potential to disturb previously unidentified human remains that may be present on the project site.

As such, MM-CR-1 through MM-CR-4 proposed for the project would not be implemented or required for this alternative. Although there may be a reduced level of direct impact to cultural resources, any previously undiscovered on -site resources could be subject to continued degradation due to lack of preservation of the undeveloped site. Nonetheless, compared to the proposed project, this alternative would result in a reduced level of impact to cultural resources as no ground disturbance would occur. 4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-5
Energy
Under the No Project Alternative, en ergy use associated with construction or operation of the proposed development, including from electricity use and natural gas use, would not occur. No construction would occur; therefore, no construction -related energy impacts associated with the construc tion equipment and worker and vendor vehicles would occur as they would with the proposed project. This alternative would not introduce any people or uses that would generate energy use, and, in comparison to the proposed project, this alternative would reduce energy use. As described in Section 3.5, Energy, of this EIR, the proposed project’s impacts related to energy emissions would be less than significant. Therefore, compared to the proposed project’s less -than- significant impact to energy, the No Project Alternative would have reduced impacts.

Geology and Soils
Under the No Project Alternative, the project site would remain in its current state. Existing topography and on -site soils would not be disturbed by any development. Although the project site wo uld still be subject to potential seismic hazards such as seismic ground shaking, under this alternative, no structures would be present on site.

Additionally, paleontological resources would be avoided as no grading or construction would occur. Thus, the risk of loss, injury, or death involving seismic hazards or other geologic conditions would be reduced compared to development of the proposed project.

Greenhouse Gas Emissions
Under the No Project Alternative, GHG emissions associated with construction or operation of future residences at the site, including from electricity use, natural gas use, water use, and solid waste handling , would not occur. No construction would occur; therefore, no construction related GHG impacts associated with t he operation of construction equipment and worker and vendor vehicles would occur like they would under the proposed project.

This alternative would not introduce any people or uses that would generate GHG emissions. GHG emissions associated with vehicular trips would not occur. In comparison to the proposed project, this alternative would reduce GHG emissions. As described in Section 3.7, Greenhouse Gas Emissions, of this EIR, the proposed project’s impacts related to GHG emissions would be less than signi ficant. Therefore, compared to the proposed project’s less-than-significant impact to GHGs, the No Project Alternative would have reduced impacts.

Hazards and Hazardous Materials
Under the No Project Alternative, no land uses would be introduced that could result in the use or generation of hazardous materials. In comparison to the proposed project, this alternative would not have the potential for transport, accidental release, or spill of hazardous materials during construction and would not expose people or structures to the potential of wildland fires, as the site would remain undeveloped. As described in Section 3.8, Hazards and Hazardous Materials, of this EIR, the proposed project’s impacts related to hazards and hazardous materials would be less than significant. Therefore, compared to the proposed project’s less -than-significant impact to hazards/hazardous materials, this alternative would have reduced impacts.

Hydrology and Water Quality
Under No Project Alternative, no development would occur and no impervious surfaces would be created. The existing on-site hydrologic conditions, drainage patterns, and drainage volumes would remain unaltered. Water quality would also remain unchanged. However, no best management prac tices would be implemented and 4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-6
stormwater runoff would continue to leave the project site untreated. Additionally, as described in Section 3.9, Hydrology and Water Quality, of this EIR, the proposed project’s impacts to hydrology and water quality would be less than significant. Therefore, compared to the proposed project’s less-than-significant impacts to hydrology and water quality, this alternative would have reduced impacts.

Land Use and Planning
Under this alternative, the project site would remain undeveloped and none of the discretionary approvals identified for the project would be required. The proposed General Plan Amendment (GPA) and Rezone of the site from Commercial (C) to Specific Plan Area (SPA) would not be required. However, this alternative would not meet many of the overall goals of the City’s General Plan, including accommodating growth in areas that can sustain a concentration of a variety of uses and constructing residential uses in areas suitable for multimodal transportation.

Nonetheless, because discretionary approvals would not be required to change the existing land use and zoning designations under this alternative to allow for intended development (i.e., potential conflict regarding consistency with applicable regulations), impacts to land use and planning would be reduced compared to the proposed project.

Noise
The project site is currently vacant and does not generate any noise. Under the No Project Alternative, the project site would remain undeveloped and would not create any new sources of construction or operational noise.

Additionally, this alternative would no t generate any groundborne vibration. As described in Section 3.11, Noise, of this EIR, the proposed project’s impacts related to noise would be less than significant. Therefore, compared to the proposed project’s less-than-significant impact to noise, this alternative would have reduced impacts.

Population and Housing
The project site is currently undeveloped. The No Project Alternative would not induce population growth in the area, as no development would occur. However, this alternative would also not contribute to meeting regional housing demands. Similar to the propose d project, this alternative would not displace any housing or people. As described in Section 3.12, Population and Housing, of this EIR, the proposed project’s impacts related to population and housing would be less than significant. However, because this alternative would not induce unplanned population growth, overall impacts would be reduced.

Public Services
The No Project Alternative would not result in an increase in demand for public services since no development would occur. Specifically, the No Proj ect Alternative would not increase the demand for police and fire protection services, nor would this alternative increase the demand on parks, schools, and library services. As stated in Section 3.13, Public Services, of this EIR, the proposed project wou ld result in less -than-significant impacts to public services. Therefore, compared to the proposed project’s less -than-significant impact to public services, this alternative would have reduced impacts.

Recreation
Under the No Project Alternative, there w ould not be an increased demand for park and recreational facilities. As such, payment of the City’s Public Facility Fees by the applicant would not be required. However, under this alternative, recreation and open space amenities proposed as part of the p roject would also not be developed. As 4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-7
stated in Section 3.14, Recreation, of this EIR, the proposed project would result in less -than-significant impacts to recreation. Because this alternative would not result in increased demands to parks and recreation , impacts would be reduced compared to the proposed project.

Transportation
Under the No Project Alternative, no development would occur. Therefore, this alternative would have no direct impact on VMT, would not result in hazards due to design features, an d would not alter emergency access ; no impact would occur. However, compared to the proposed project, this alternative would not promote sustainability by focusing housing development in an infill area identified as having low VMT due to proximity to existing employment, entertainment, scho ols, markets, parks, transit, and shopping centers. Additionally, other improvements, such as circulation and pedestrian improvements, would not occur under this alternative. As outlined in Section 3.15, Transportation, of this EIR, because the project’s V MT per resident is more than 15% above the regionwide average , impacts would be significant ; despite the implementation of MM-TRA-1 through MM-TRA-3, impacts would remain significant and unavoidable. Under the No Project Alternative, no mitigation would be required as no development would occur. Therefore, c ompared to the proposed project, the No Project Alternative would result in reduced impacts related to transportation.

Tribal Cultural Resources
The No Project Alternative would not require any ground -disturbing or other construction/development activities.

Therefore, there would be no potential to impact unknown tribal cultural resources potentially located within the project site. However, although there may be a reduced level of direct impact to triba l cultural resources, any previously undiscovered on-site resources could be subject to continued degradation due to lack of preservation with the undeveloped site.

Nevertheless, because the site would not be disturbed under this alternative, MM-CR-1 through MM-CR-4 proposed for the project would not be implemented or required under this alternative. Compared to the proposed project, this alternative would result in a reduced level of impact to tribal cultural resources.

Utilities and Service Systems
No development would occur under the No Project Alternative. As such, the increase in demand for water service, wastewater service, and solid waste handling services would not occur. As discussed in Section 3.17 of this EIR, impacts to utilities and service syst ems were determined to be less than significant under the proposed project.

Nonetheless, because no development would occur under this alternative, the demand for utilities would be eliminated. Therefore, impacts to utilities and service systems would be r educed under this alternative compared to the proposed project and no impacts on utilities and service systems would occur.

Summary and Relation to Project Objectives
Since the No Project Alternative would not provide any development, overall impacts woul d be reduced compared to the proposed project. However, certain benefits would not be realized under this alternative, including the provision of housing units in an infill area identified in the General Plan and enhanced uses and connectivity in the surrounding area.

As the No Project Alternative would not develop the site or allow for housing, this alternative would not fulfill any of the project objectives.
4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-8

4.4.4 Existing Land Use Designation Alternative
Under the Existing Land Use Designation Alt ernative, the project site would be developed per the City’s General Plan as a Commercial (C) land use. The project site would be developed as previously processed with the existing CVS Conditional Use Permit. The Existing Land Use Designation Alternative would include 69,000 square feet (sf) of grocery store and gas station uses and 23,000 sf of office space. This alternative would include 276 parking spaces. This alternative could be processed with a Conditional Use Permit and Site Development Plan and would not require a GPA or Rezone of the site.

Other improvements, such as circulation , landscaping, and utility connections would occur as required. Off-site improvements beyond those required by mitigation measures would not occur under this alternative. No open space uses would occur on site.

4.4.4.1 Comparison of the Effects of the Existing Land Use Designation Alternative to the Proposed Project
Aesthetics
The Existing Land Use Designation Alternative would develop commercial uses on the currently undeveloped site. This alternative would consist of 69,000 sf of grocery store and gas station uses , 23,000 sf of office space, and 276 parking spaces. This alternative would result in similar less-than-significant impacts or no impacts related to scenic vistas, scenic highways, visual character or quality, or lighting and glare compared to the proposed project. The visual character of the site would change from vacant to commercial, which is consistent with the existing land use designation and immediately adjacent uses to the south/southeast. New sources of lighting would be introduced, but, similar to the project, they would be required to comply with the City’s Light and Glare Standards. Therefore, aesthetic impacts of the Existing Land Use Designation Alternative would be comparable to those of the proposed project.

Air Quality
Under the Existing Land Use Designation Alternative, air pollutant emissions associated with project construction , including emissions associated with grading, site prep aration, site finishing and building finishing , would occur, which would be similar to the proposed project.

Under the Existing Land Use Designation Alternative, mobile source operational emissions from vehicle trips are expected to be greater than those of the proposed project, based on the alternative land use of a grocery store, gas station, and office space. Commercial development would likely result in greater stationary source operational air pollutant emissions compared to the proposed project’s residential use of the site. Commercial uses generally use more energy than residential land uses, which translate s to increased air pollutant emissions related to energy generation and energy transmission. Diesel particulate matter emissions from heavy-duty equipment operations and heavy-duty truck trips associated with the gas station and grocery store may also generate significant operational emissions, which could potentially result in associated health impacts to nearby sensitive receptors. Unlike operation of a residential development, development of the Existing Land Use Designation Alternative could result in significant long-term toxic air contaminant emissions, including diesel particulate matter. Commercial development of the site may also result in adverse impacts from odors associated with the gas station. As such, this alternative would likely result in greater impacts to air quality compared to the proposed project. 4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-9
Biological Resources
The development footprint of the Existing Land Use Designation Alternative would result in a similar or greater ground disturbance area on the project site. Development of this alternative would result in a similar potential to impact existing biological resources on site, including loss of vegetation communities and potential impacts to special-status species, sensitive natural communities, and nesting birds. Under this alternative, designated open space areas would not be required and the site would be developed with mor e impervious area than the proposed project. Like the project, this alternative would likely require mitigation measures similar to MM-BIO-1 and MM-BIO-2 in order to reduce impacts to biological resources. With implementation of mitigation measures similar to those proposed for the project, this alternative would result in similar impacts to biological resources compared to the project.

Cultural Resources
The development footprint of the Existing Land Use Designation Alternative would be slightly greater than the proposed project since no open space area would be required . Development could result in similar or greater ground-disturbance compared to the proposed project. Therefore, the potential to impact unknown archaeological resources located within the p roject site, as well as unidentified human remains , would still occur. As with the proposed project, implementation of MM-CR-1 through MM-CR-4 would be required to reduce potential impacts to unknown/unidentified cultural resources. Compared to the proposed project, thi s alternative would result in a similar level of impact to cultural resources.

Energy
Development of the Existing Land Use Designation Alternative would result in construction and operational energy use. Energy use during construction would be similar to the proposed project and primarily be associated with construction equipment, as -necessary lighting, and electronic equipment such as computers ins ide temporary construction trailers and heating, ventilation, and air conditioning. The operation of this alternative would require electricity for multiple purposes, including proposed daily uses associated with the industrial land use, cooling, lighting, and various equipment. Additionally, the supply, conveyance, treatment, and distribution of water would indirectly result in electricity usage.

As described above, c ommercial uses generally use more energy than residential land uses, which translate s to increased air pollutant emissions related to energy generation and energy transmission. As such, demand for energy would be greater under the Existing Land Use Designation Alternative than under the proposed project.

Similar to the proposed project, this alternative would be required to comply with building requirements (including Title 24 California Code of Regulations standards) designed to ensure efficient energy use, reduce energy demand, and comply with state and local renewable energy and energy efficiency requirements. Petroleum use during operation of the Existing Land Use Designation Alternative is expected to b e increased compared to the proposed project as a result of grocery store and gas station land use activities and vehicles. As such, demand for energy would be greater under this alternative than under the proposed project.

Geology and Soils
Under the Existing Land Use Designation Alternative, although the project site would be developed with different land uses, ground-disturbance areas would be similar. Development under this alternative would be subject to the same potential seismic hazards such as seism ic ground shaking. This alternative would also require abiding by geological recommendations, such as the ones identified in the geotechnical evaluation for the proposed project. 4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-10
Similar to the proposed project, paleontological resources would be avoided b ecause the potential for paleontological resources to be located on the project site is considered low. Compared to the proposed project, this alternative would result in similar level of impacts to geology and soils.

Greenhouse Gas Emissions
Construction and operation of the Existing Land Use Designation Alternative would result in construction GHG emissions that are primarily associated with use of off -road construction equipment, on -road vehicles, vendor trucks, daily operations, and worker vehicles. The GHG emissions associated with this alternative are expected to be greater due to typical daily operations associated with the commercial land uses, specifically transportation trucks associated with the gas station and grocery store . Additionally, the City’s zoning does not have an open space requirement for commercial uses, as it does for the project’s residential land use.

Although this alternative is not expected to conflict with an applicable GHG related plan, policy, or regulation due to consistency with the existing General Plan land use and zoning designation, the Existing Land Use Designation Alternative is expected to result in greater emissions compared to the project due to operational uses typical of such commercial projects. As such, impacts to GHG emissions under the Existing Land Use Designation Alternative would be greater in comparison to the proposed project.

Hazards and Hazardous Materials
Similar to the proposed project, there is the potential for the Existing Land Use Designation Alternative to generate hazardous materials during construction; however, existing federal and state standards are in place for the handling, storage, and transport of these materials. Because the Existing Land Use Designation Alternative would result in development of commercial uses on site, including a gas station, operation of this alternative would likely result in increased use of hazardous materials on site compared to the household products that would be utilized under the project’s proposed residential uses. Therefore, compared to the proposed project, this alternative would result in greater impacts related to hazards and hazardous materials.

Hydrology and Water Quality
As described above, the Existing Land Use Designation Alternative would result in a similar or greater disturbance area on the project site. Due to uses associated with commercial development and associated parking, it is assumed that this alternative would introduce more impervious surfaces to the site compared to the p roposed project, as the proposed project would be required to incorporate open space and landscaped areas for residents under the San Marcos Municipal Code. Development of both the proposed project and this alternative would alter the existing on- site hydrologic conditions, drainage patterns, and drainage volumes in comparison to existing vacant conditions. It is expected that this alternative, like the proposed project, would also incorporate all required and applicable best management practices to avoid any violations of water quality standards and to avoid otherwise modifying or adversely affecting surface and groundwater quality or increasing runoff rate or volume from the site. Therefore, as compared to the proposed project, this alternative would result in similar, less-than-significant impacts.

Land Use and Planning
Because development of this alternative would be consistent with land uses identified in the City’s General Plan, a GPA and Rezone would not be required. Development of commercial uses on the project site would also be consistent with adjacent land uses to the south/southeast . By contrast, the proposed project would introduce population growth in an area of the City that has not been accounted for in the City’s General Plan. Therefore, 4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-11
because this alternative would avoid a GPA/Rezone, which would be required for the proposed project, no impacts would occur under this alternative, and impacts would be reduced compared to the proposed project.

Noise
The Existing Land Use Designation Alternative would result in similar ground -disturbance on site in comparison to the proposed project. As analyzed in Section 3.11 of this EIR, proposed project noise impacts were determined to be less than significant. Construction noise of thi s alternative is expected to be similar to that of the proposed project. Operationally, this alternative may result in greater noise generation during commercial operating hours, particularly with components such as the grocery store and gas station . While it is likely that such commercial uses would generate more noise than a residential development, it would be expected that the uses would comply with the City’s noise ordinance regarding generation of noise at the property line, and that appropriate mitigation would be implemented as needed to reduce potential impacts to less than significant. Therefore, compared to the proposed project, this alternative would result in similar impacts.

Population and Housing
The Existing Land Use Designation Alternative w ould not induce substantial unplanned population growth in the area, either directly or indirectly. This alternative would propose new business es consistent with the General Plan and provide for infrastructure only as needed to serve the alternative. The p roposed project seeks to change the land use designation of the project site to allow for development of residential land uses that have not been accounted for in the City’s General Plan; however, the proposed new homes and associated estimate of 370 residents is not expected to substantially induce unplanned population growth in this infill area. Like the proposed project , the Existing Land Use Designation Alternative would have no impact related to displacing substantial numbers of people or housing. Overall, impacts related to population and housing for this alternative would be reduced compared to the proposed project’s less-than-significant impact.

Public Services
Similar to the proposed project, the Existing Land Use Designation Alternative would result in an increase in demand for public services due to the development of a currently vacant site. However, commercial development under this alternative would likely result in less of a demand on public services (especially parks, schools, and libraries) compared to the residential development proposed by the project. Therefore, impacts to public services under this alternative would be reduced compared to the proposed project, but would remain less than significant.

Recreation
Unlike the proposed project, the Existing Land Use Designation Alternative would not result in an increase in demand for parks and recreation services over existing conditions, as no residents or substant ial population generation would be associated with development of commercial uses on site. Additionally, this alternative would not require usable open space on site. This alternative would result in reduced impacts to recreational facilities compared to the proposed project’s less-than-significant impacts.

Transportation
The Existing Land Use Designation Alternative is assumed to be served by a larger volume of large trucks and machinery during both construction and o peration. However, traffic signals and entries to the site were designed 4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-12
and built to accommodate anticipated heavy commercial traffic during processing of the CVS development. It is anticipated that this alternative would be required to provide adequate emergency access, similar to the project.

VMT for the Existing Land Use Designation Alternative is 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 vo lume of large trucks. 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. Further, this alternative would not promote sustainability by focusing housing development in an infill area identified as a High Quality Transit Area due to proximity to existing employment, entertainment, schools, markets, parks, transit, and shopping centers.

This alternative would likely result in a larger v olume of large trucks during operation. However, such uses would be compatible with surrounding commercial uses to the south/southwest and are unlikely to result in hazards due to design features or incompatible uses. Compared to the proposed project, the Existing Land Use Designation Alternative is expected to result in similar or greater impacts related to transportation.

Tribal Cultural Resources
This alternative would result in new commercial development within a slightly greater footprint than the proposed project on a currently vacant site. As such, this alternative would have similar potential to affect unknown tribal cultural resources compared to the proposed project. It is expected that this alternative would require implementation of mitigation measures similar to MM-CR-1 through MM-CR-4 proposed for the project.

Thus, with the implementation of mitigation, impacts to tribal cultural resources ar e expected to be similar to the proposed project.

Utilities and Service Systems
The Existing Land Use Designation Alternative demand for water service, energy , and solid waste is expected to be greater than that required to serve a 120-unit residential project (approximately 370 residents). As described under the air quality analysis above, commercial uses including the grocery store and gas station proposed under this alternative generally use more energy and water than residential land uses. As such, the Existing Land Use Designation Alternative’s demand for utilities and service systems is likely to be greater than the demand under the proposed project.

Summary and Relation to Project Objectives
Under the Existing Land Use Designation Alternative, the pr oject site would be developed per the City’s General Plan land use designation with Commercial (C) land use s. As described above, this alternative would develop 69,000 sf of grocery store and gas station uses, 23,000 sf of office space, and 276 parking spaces. This alternative could be processed with a Site Development Plan and would not require a GPA or Rezone of the site.

Because development of the Existing Land Use Designation Alternative would include grading and development of the same site, construct ion-related impacts would be similar to the proposed project and would require similar mitigation for impacts to biological resources, cultural resources , geology and soils, tribal cultural resources, and traffic. However, t he commercial use of the site wo uld be expected to result in greater 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. 4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-13
This alternative would promote infill development on site; however, it would not fulfill any of the basic project objectives a nd would also not aid the City in achiev ing its Regional Housing Needs Assessment allocation.

Furthermore, the project site has been designated for commercial development under the existing and previous General Plans but has remained vacant, evidencing that it is not marketable or feasible for commercial uses.

Although this alternative would be consistent with the existing designated land use and zoning for the site and adjacent land uses to the south, this alternative would not reduce or avoid significant environmental impacts and would not meet any project objectives.

4.4.5 Reduced Density Alternative
The Reduced Density Alternative would reduce the density on site in comparison to the project by changing the General Plan land use designation to Low Densi ty Residential (LDR) and changing the zoning to Residential 1 (R-1-7.5), which “provides for low -density, single family detached homes that are suitable in massing and character or inclusion in single -family detached neighborhoods ,” as outlined in the Municipal Code. Under this alternative, the site would accommodate approximately 33 single-family homes for a total residential density of

4.34 dwelling units per acre . The Reduced Density Alternative would not incorporate private useable open space area within the residential community since each single -family home would have a backyard. The access points and internal streets would be configured to fit the 33 single -family home layout. This alternative would utilize the entire 7.6-acre site.

4.4.5.1 Comparison of the Effects of the Reduced Density Alternative to the Proposed Project
Aesthetics
The Reduced Density Alternative would reduce the density on site with the development of 33 single-family homes instead of 120 townhomes. The visual character of the site would change from vacant to residential in an urbanized and developed area. Compared to the proposed project, the Reduced Density Alternative would decrease impacts related to visual character and consistency for the land u ses to the north and west of the project due to the more similar single-family housing. New sources of lighting would be introduced but, similar to the project, they would be required to comply with the City’s Light and Glare Standards. Therefore, aestheti c impacts of the Reduced Density Alternative would be comparable to the proposed project, resulting in less-than-significant impacts.

Air Quality
Under the Reduced Density Alternative, air pollutant emissions associated with project construction, including emissions associated with grading, site preparation, site finishing , and building finishing, would be similar compared to the proposed project.

Under the Reduced Density Alternative, mobile source operational emissions from light vehicle trips would be reduced compared to the proposed project , since the unit count would decrease to 33 single -family homes. As such, this alternative would likely result in overall reduced impacts to ope rational air quality compared to the proposed project.
4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-14
Biological Resources
The Reduced Density Alternative would result in similar ground disturbance area on the project site and would result in similar impacts as the proposed project to existing biological resources on site. Similar to the proposed project, this alternative would require mitigation similar to MM-BIO-1 and MM-BIO-2, proposed for the project.

With implementation of mitigation measures similar to those proposed for the project, this alterna tive would result in similar less-than-significant impacts to biological resources compared to the project.

Cultural Resources
The Reduced Density Alternative would result in similar ground-disturbance compared to the proposed project and would result in similar impacts to unknown archaeological resources located within the project site, as well as unidentified human remains. As with the proposed project, implementation of mitigation measures similar to MM-CR-1 through MM-CR-4 would be required to reduce potential impacts to unknown/unidentified cultural resources. With implementation of mitigation measures similar to those proposed within the project, this alternative is expected to result in similar less-than-significant impacts to cultural resources compared to the project.

Energy
Under the Reduced Density Alternative, development would result in construction and operational e nergy use.

Energy use during construction would primarily be associated with construction equipment, as -necessary lighting, and electronic equipment, such as computers inside temporary construction trailers and heating, ventilation, and air conditioning, similar to the proposed project. Natural gas is not anticipated to be used during construction, similar to the proposed project, and would be temporary and negligible if used. Petroleum would be used throughout construction of the alternative and would be s imilar to the proposed project. Ultimately, like the proposed project, the petroleum consumed related to construction would be typical of construction projects of similar types and sizes and would not be wasteful or inefficient.

The operation of this alternative would also require electricity for multiple purposes, similar to the proposed project.

The Reduced Density Alternative demand for energy use is expected to be similar or slightly reduced to that required to serve the proposed project. Similar to the proposed project, this alternative would be required to comply with building requirements (including Title 24 California Code of Regulations standards) designed to ensure efficient energy use, reduce energy demand, and comply with state and local renewabl e energy and energy efficiency requirements. Like the proposed project, the operation of residential units would require natural gas for space heating and to power appliances, but compliance with Title 24 would ensure its efficient use. As such, demand for energy under this alternative would be comparable to demand under the proposed project , or would be slightly reduced. Similar, less-than-significant impacts to energy would occur under this alternative.

Geology and Soils
Under the Reduced Density Alternative, ground -disturbance areas would be similar. Development under this alternative would be subject to the same potential seismic hazards, such as seismic ground shaking. This alternative would also require abiding by geological recommendations, such as th e ones identified in the geotechnical evaluation for the proposed project. Similar to the proposed project, paleontological resources would be avoided because the potential for paleontological resources to be located on the project site is considered low. Compared to the proposed project, this alternative would result in similar less-than-significant impacts to geology and soils. 4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-15
Greenhouse Gas Emissions
Construction of the Reduced Density Alternative would result in construction GHG emissions that are primarily associated with use of off -road construction equipment, on -road vehicles, vendor trucks, and worker vehicles, similar to the proposed project. Construction GHG emissions under this alternative may be slightly reduced as a result of the decreased unit count.

Estimated annual operational GHG emissions from this alternative would be similar or slightly reduced compared to the proposed project as the unit count would be reduced to 33 si ngle-family homes . Thus, this alternative would result in overall similar GHG emissions compared to the proposed project and impacts would remain less than significant.

Hazards and Hazardous Materials
Similar to the proposed project, there is the potential for the Reduced Density Alternative to generate hazardous materials during construction; however, existing federal and state standards are in place for the handling, storage, and transport of these materials. Because the Reduced Density Alternative would result in similar development of residential units on site, operation of this alternative would result in similar use of hazardous materials on site, such as household products, that would be utilized under the proposed project. Therefore, compared to the proposed project, this alternative would result in similar impacts related to hazards and hazardous materials.

Hydrology and Water Quality
As described above, the Reduced Density Alternative would result in similar ground disturbance area on the project site. Due to the similar development footprint under this alternative, impervious surfaces would be similar to those of the proposed project or would slightly increase since no communal useable open space area would be incorporated on site. Development of b oth the proposed project and this alternative would alter the existing on - site hydrologic conditions, drainage patterns, and drainage volumes in comparison to existing vacant conditions.

It is expected that this alternative, like the proposed project, woul d also incorporate all required and applicable best management practices to avoid any violations of water quality standards and to avoid otherwise modifying or adversely affecting surface and groundwater quality or increasing runoff rate or volume from the site. Therefore, as compared to the proposed project, this alternative would result in similar, less -than-significant impacts to hydrology and water quality.

Land Use and Planning
Similar to the proposed project, t he Reduced Density Alternative would introduce housing on site and a GPA and Rezone would be required. Similar to the proposed project, this alternative would introduce population growth in an area of the City that has not been accounted for in the City’s General Plan. Ther efore, because this alternative would also require a GPA/Rezone but would not conflict with applicable plans, policies, and regulations, impacts under this alternative would result in similar impacts to land use to those of the proposed project.

Noise
The Reduced Density Alternative could potentially result in reduced noise levels as a result of the reduction in unit count from 120 townhomes to 33 single -family homes. As analyzed in Section 3.11 of this EIR, noise impacts 4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-16
associated with the proposed proje ct were determined to be less than significant. Construction noise of this alternative is expected to be similar to that of the proposed project. Operationally, this alternative would result in similar or slightly reduced noise generation to that of the pr oposed project due to the layout. Development of this alternative would be expected to comply with the City’s noise ordinance regarding generation of noise at the property line. Therefore, as compared to the proposed project, this alternative may result in slightly reduced noise, but would still result in similar, less-than-significant impacts.

Population and Housing
The Reduced Density Alternative would similarly introduce unplanned population growth in the area with the development of 33 single-family housing units on the currently vacant site. As of 2021, the City has a person per household ratio of 3.08 (DOF 2021). Using this househo ld ratio of 3.08, development of 33 single-family residential dwelling units at the project site would generate approximately 102 people, in comparison to the proposed project’s estimated generation of 370 people . The proposed project seeks to change the l and use designation of the project site to allow for development of residential land uses that have not been accounted for in the City’s General Plan. Development of this alternative would also require a GPA/Rezone. However, similar to the project, the new homes under this alternative would not be considered to substantially induce unplanned population growth as the project site is an infill site surrounding by existing roadways, utilities , and development.

Like the proposed project, this alternative would have no impact related to displacing substantial numbers of people or housing. Therefore, impacts related to population and housing for this alternative would be similar to the proposed project’s less-than-significant impacts.

Public Services
Similar to the proposed project, the Reduced Density Alternative would result in an increase in demand for public services due to the development of a currently vacant site. Because the unit count would be reduced under this alternative, impacts to public services would be slightly less than the proposed project, but still result in similar less-than-significant impacts.

Recreation
Similar to the proposed project, the Reduced Density Alternative would result in an increased demand on existing park and recr eational facilities within the City with the introduction of 33 single-family housing units. However, similar to the proposed project, this alternative would be required to incorporate private open space on site and would be required to pay into applicable developer and park impact fees. Therefore, impacts related to recreation for this alternative would be similar to the proposed project’s less-than-significant impacts.

Transportation
The Reduced Density Alternative would be served by similar vehicle traf fic during construction compared to the proposed project. Construction traffic impacts under this alternative are expected to be less than significant, as with the proposed project.

During operation, project access points for this alternative would be des igned to fit the 33 single -family unit layout. It is anticipated that this alternative would be required to provide adequate emergency access, similar to the project.
4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-17
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. Therefore, compared to the proposed project, this alternative would result in similar significant and unavoidable impacts related to transportation.

Tribal Cultural Resources
This alternative would result in development within the same footprint as the proposed project on the project site.

As such, this alternative would result in a similar potential to affect unknown tribal cultural resources compared to the proposed project. It is expected that this alternative would require implementation of mitigation measures similar to MM-CR-1 through MM-CR-4 proposed for the project. Thus, with the implementation of mitigation, impacts to tribal cultural resources would be similar to the proposed project and would be less than significant.

Utilities and Service Systems
The Reduced Density Alternative demand for water service, energy, and solid waste is expected to be similar to that required to serve the proposed project. Therefore, the demand for utilities and service systems is determined to be similar to that of the proposed project under this alternative, and result in a less-than-significant impact.

Summary and Relation to Project Objectives
The Reduced Density Alternative would reduce the total unit and population density on site, but retain the same development footprint as the proposed project. The Re duced Density Alternative would develop 33 single -family homes on the 7.6 -acre site. Development of single -family homes would be more consistent with the adjacent single-family homes to the west. However, the 33 single -family homes under this alternative w ould 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.

While this alternative would develop infill housing on an urbanized site and rezone the site to residential to assist the City to implement its housing goals, it would less efficiently promote infill development and would not enhance connectivity . Due to the site configuration and single -family units , communal recreational ameniti es would not be incorporated into this alternative . Furthermore, 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.

However, the Reduced Density Alternative would potentially provide a slightly reduced level of impact in some environmental analysis areas including aesthetics, air quality, energy, GHG, and noise. As described above, mitigation measures would still be required to mitigate impacts to biological resources, cultural resources, geology and soils, and tribal cultural resources. This alternative would not meet most of the project objectives.

4.5 Environmentally Superior Alternative
Table 4-1 provides a qualitative comparison of the impacts for each Alternative compared to the proposed project.

As shown in Table 4 -1, the No Project Alternative would eliminate all of the significant impacts identified for the project. However, the No Project Alternative would not meet any of the project objectives. CEQA Guidelines Section 15126.6(e)(2) state s that if the No Project Alternative is identified as the environmentally superior alternative, then an environmentally superior alternative should be identified among the other alternatives. 4 – ALTERNATIVES
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 4-18
Among the other alternatives, not including the proposed projec t, the Reduced Density Alternative would be considered the environmentally superior alternative because it would potentially provide a reduced level of impact in some environmental analysis areas including air quality, GHG, and noise. However, such impacts under this alternative would still remain as less than significant , similar to the proposed project. The Reduced Density Alternative would cover the same development footprint as the proposed project but would result in decreased unit count and population count on site. Because the Reduced Density Alternative would cover the same development footprint as the project, impacts to biological resources, cultural resources, geology and soils, and tribal cultural resources would remain the same as the proposed p roject and mitigation measures would still be required to mitigate impacts to these environmental resources. The Reduced Density Alternative would not meet project objectives 1, 2 , and 4 . Furthermore, d ue 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.

For the Existing Land Use Designatio n Alternative, although this alternative would be consistent with the existing land use and zoning designation for the site and would promote infill development on site, it would not fulfill any of the project objectives, would not reduce or avoid signific ant environmental impacts, would not aid the City in achieving its Regional Housing Needs Assessment allocation . Additionally, it may result in new or more severe impacts related to air quality, GHG emissions, and hazards.

Table 4-1. Comparison of Impacts of Proposed Project and Alternatives Environmental Topic
Proposed
Project
No Project
Alternative
Existing Land Use
Designation
Alternative
Reduced Density
Alternative
Aesthetics LTS No Impact (Reduced) LTS (Same) LTS (Same/Reduced) Air Quality LTS No Impact (Reduced) LTS (Greater) LTS (Same/Reduced) Biological Resources LTSM No Impact (Reduced) LTSM (Same/Greater) LTSM (Same) Cultural Resources LTSM No Impact (Reduced) LTSM (Same/Greater) LTSM (Same) Energy LTS No Impact (Reduced) LTS (Same/Greater) LTS (Same/Reduced) Geology and Soils LTS No Impact (Reduced) LTS (Same) LTS (Same) Greenhouse Gas
Emissions
LTS No Impact (Reduced) LTS (Same/Greater) LTS (Same/Reduced) Hazards and Hazardous
Materials
LTS No Impact (Reduced) LTS (Same/Greater) LTS (Same)
Hydrology and
Water Quality
LTS No Impact (Reduced) LTS (Same) LTS (Same)
Land Use LTS No Impact (Reduced) LTS (Reduced) LTS (Same) Noise LTSM No Impact (Reduced) LTS (Same/Greater) LTS (Same/Reduced) Population and Housing LTS No Impact (Reduced) LTS (Reduced) LTS (Same/Reduced) Public Services LTS No Impact (Reduced) LTS (Reduced) LTS (Same/Reduced) Recreation LTS No Impact (Reduced) LTS (Reduced) LTS (Same) Transportation LTS No Impact (Reduced) LTSM (Same/Greater) LTSM (Same) Tribal Cultural Resources LTSM No Impact (Reduced) LTSM (Same/Greater) LTSM (Same) Utilities and Service
Systems
LTS No Impact (Reduced) LTS (Same/Greater) LTS (Same)
Note: LTS = Less Than Significant Impact; LTSM = Less Than Significant with Mitigation; SU = Significant and Unavoidable.

GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 5-1
5 Environmental Effects Found Not To
Be Significant
As required by Section 15128 of the California Environmental Quality Act Guidelines, the following is a discussion of the environmental effects that were considered as part of this environmental impact report (EIR) but were determined to have no impact and therefore are not discussed in detail in Chapter 3, Environmental Analysis, of this EIR. Agriculture and forestry resources, mineral resources, and wildfire were the only environmental issue areas eliminated from Chapter 3 and are briefly discussed below.

As discussed in Chapter 2 , Project Description, of this EIR, the proposed Gran Vista Specific Plan Project ( project) proposes development of 120 townhomes and associated amenities on a 7.6-acre project site. The project proposes a General Plan Amendment and Rezone from Commercial (C) to Specific Plan Area (SPA).

5.1 Agriculture and Forestry Resources
The project site is designated as Urban and Built -Up Land by the California Department of Conservation Farmland Mapping and Monitoring Program (DOC 2016). As a result, the proposed project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural uses.

Furthermore, the project site is not zoned for agricultural use or designated as land under the Williamson Act, nor is the project site zoned for forest land or timberland production (DOC 2014). Therefore, implementation of the proposed project would not result in the loss or conversion of forest land. No impact would occur regarding conflicts with existing zoning for agricultural use or forest land.

Designated farmland does not exist within the vicinity of the project site. The proposed project would not result in substantial changes that could result in the conversion of farmland to non -agricultural use. The project site is surrounded entirely by dev eloped land, with the exception of two small vacant lots adjacent to the east and west portion of the site. This vacant lots are designated Commercial by the City of San Marcos (City). Other existing development adjacent to the project site include Commercial, Specific Plan Amendment, and Low Density Residential (City of San Marcos 2022). Given the extent of development surrounding the project site, the proposed project would not result in the conversion of any existing farmland, and no impact would occur.

5.2 Mineral Resources
According to the City of San Marcos General Plan Conservation and Open Space Element, the City has land classified in all four Mineral Resource Zones (MRZs) (City of San Marcos 2012). The different MRZs are defined as follows:
▪ MRZ-1: Areas where adequate information indicates that no significant mineral deposits are present or where it is judged that little likelihood exists for their presence. ▪ MRZ-2: Areas where adequate information indicates that significant mineral deposits are present or where it is judged that a high likelihood for their presence exists. ▪ MRZ-3: Areas containing mineral deposits the significance of which cannot be evaluated from available data. ▪ MRZ-4: Areas where available information is inadequate for assignment to any other MRZ zone. 5 – ENVIRONMENTAL EFFECTS FOUND NOT TO BE SIGNIFICANT
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 5-2
California does not require that local governments protect land designated as MRZ -1, MRZ-3, or MRZ-4. However, the City is responsible for recognizing lands designated as MRZ -2 and protecting these areas from premature development incompatible with mining. City lands designated as MRZ -2 include small portions between Double Peak, Mt. Whitney, and Franks Peak and small portions in the northern Sphere of Influence within Twin Oaks Valley Neighborhood (City of San Marcos 2012) . These locations do not overlap w ith the proposed project site and the project site is located in MRZ-4 (DOC 2017); therefore, no loss of known mineral resources would occur.

Furthermore, the project site is not designated as a locally important mineral resource recovery site on any local general plan, specific plan, or other land use p lan (City of San Marcos 201 2). Therefore, due to the location and nature of the proposed project, there would be no impact to mineral resources.

5.3 Wildfire
The project site is not located in any fire hazard severity zones (CAL FIRE 2022). Nor is the project site located near any local responsibility areas, state responsibility areas, or lands classified as very high fire hazards severity zones (CAL FIRE 2022). The existing project site is a vacant lot. Implementation of the proposed project would likely reduce the potential for wildfire hazards on site. Proposed development would not include infrastructure that would exacerbate fire risk . Additionally, the proposed project would be required to comply with all applicable state and local fire codes. Furthermore, as determined in the Fire Response Summary Letter prepared for the project (Appendix J to this EIR), the San Marcos Fire Department’s existing Station 1 would adequately serve future development at the project site while maintaining their response goals. For these reasons, the proposed project is not expected to result in significant impacts related to wildfire. No impact would occur.

GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY 2023 6-1
6 Other CEQA Considerations

6.1 Significant Unavoidable Impacts
California Environmental Quality Act (CEQA) Guidelines Section 15126.2(b) requires that an environmental impact report ( EIR) describe any significant impacts that cannot be avoided, including those impacts that can be mitigated but not reduced to a less-than-significant level. Chapter 3, Environmental Analysis, of this EIR describes the potential environmental impacts of the proposed Gran Vista Specific Plan Project ( project) and recommends mitigation measures to reduce impacts, where feasible.

As discussed in this EIR, all potentially significant impacts would be reduced to a less -than-significant level with mitigation incorpo rated, with the exception of traffic impacts, which would remain significant and unavoidable after incorporation of proposed mitigation.

6.2 Growth Inducement
Section 15126.2(d) of the CEQA Guidelines mandates that the growth -inducing nature of a proposed project be discussed. Th e CEQA Guideline state the growth -inducing analysis is intended to address the potential for the proposed project to “foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment.” Further, the CEQA Appendix G Checklist (Population and Housing) also mandates that a CEQA document speak to the proposed project’s likelihood to induce substantial population growth in an area, either directly (e.g., by propo sing new homes or businesses) or indirectly (e.g., through extension of roads or other infrastructure).

A project may be distinguished as either facilitating planned growth or inducing unplanned growth. Facilitating growth is relat ed to the establishment of direct employment, population, or housing growth that would occur within a project site. Inducing growth is related to lowering or removing barriers to growth or creating an amenity or facility that attracts new population/economic activity. For purpose s of this EIR analysis, a significant growth inducement impact would occur if the proposed project, as well as associated infrastructure improvements, directly or indirectly removes obstacles to growth such that the induced growth would significantly burde n existing community services or the environment or cause a demand for General Plan Amendments. This section contains a discussion of the growth inducing factors related to the proposed project as defined under CEQA Guidelines Section 15126.2(d). A project is defined as growth inducing when it directly or indirectly:

1. Fosters population growth

2. Includes the construction of additional housing in the surrounding environment

3. Removes obstacles to population growth

4. Taxes existing community service facilities, requ iring construction of new facilities that could cause significant environmental effects

5. Encourages or facilitates other activities that could significantly affect the environments, either individually or cumulatively
It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.
6 – OTHER CEQA CONSIDERATIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY2023 6-2
The project proposes development of 120 multifamily residential dwelling units on 7.6 acres for an approximate total densi ty of 15.8 dwelling units per acre. The project would include a total of 260 new parking spaces in addition to 37 existing spaces on site , approximately 92,645 square feet of common recreation area , and an average of 130 square 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 N Las Posas Road frontage. The proposed project also includes landscapi ng, bio -retention areas, and circulation improvements. The project would include two points of entry, the first entry point is located off N Las Posas Road and the second entry point is located off W Mission Road.

The project proposes a General Plan Amendm ent, Rezone, Specific Plan, Tentative Map, and Site Development Plan. The General Plan Amendment and Rezone would change the General Plan designation and Zoning from Commercial (C) to Specific Plan Area (SPA). The Specific Plan serves as both a policy docu ment and a regulatory document for the systematic implementation of the policies and goals of the City of San Marcos General Plan (General Plan) (the Specific Plan is included as Appendix M to this EIR). The Tentative Map presents specific lot configurations for the site. The Site Development Plan will configure the site for townhome dwelling units, street configuration, infrastructure, recreational open space, and private open space.

As described in Section 3.12, Population and Housing, it is anticipated that the proposed residential development at the project site could generate a population increase of up to approximately 370 people. Although the proposed project would accommodate some planned growth within the City of San Marcos (City) and not all potential future residents of the project are expected to be new to the City, the project could still result in unplanned growth for the City because residential land use s for the project site w ere not accounted for in the City’s General Plan.

As described in Section 3.12 of this EIR , the City is forecast to grow from 96,302 persons in 2020 to 109,095 persons in 2035, which is a population increase of 12,793 (SANDAG 2013). Additionally, San Diego Association of Governments allocated 3,116 housing units to the San Marcos area for the 2021 –2029 Housing Element Cycle (SANDAG 2020). Approval of the proposed project to residential land use could help the City accommodate this substantial population growth and its need for housing. The proposed project would be subject to compliance with the City’s General Plan Housing Element goals and policies, compliance with housing -related ordinances in the San Marcos Municipal Code, and applicable development fees as outlined in Section 3.12 of this EIR. Compliance with these policies, ordinances, and fee provisions would ensure any growth at the site is adequately planned for in terms of ensuring the provision of community service facilities, including utilities, public services, recreation, emergency access, and roadways.

There is no hardline number or percentage available to determine whether or not th e estimated introduction of approximately 370 people would be considered a substantial increase in population. However, the San Diego Association of Governments 2050 Regional Growth Forecast is intended to be used as a starting point for regional planning, as opposed to a prescribed growth pattern. While the City has determined that there are adequate sites available with appropriate designations/zoning to accommodate the remaining Regional Housing Needs Assessment allocation for the current General Plan Housing Element planning period (2013 to 2021) , and has tentatively determined the same for the 2021–2029 Draft Housing Element Update (City of San Marcos 2021) , the City has the discretion to adjust allocated housing units/sites as necessary to balance proposed plans for residential development with a pproved/constructed residential development. It is likely the site w ould act to accommodate some of the planned population growth in the City. 6 – OTHER CEQA CONSIDERATIONS
GRAN VISTA SPECIFIC PLAN PROJECT ENVIRONMENTAL IMPACT REPORT CITY OF SAN MARCOS 13528 MAY2023 6-3
Potential indirect growth inducing impacts are unlikely to result from the proposed project. No extension of infrastructure is anticipated to be needed for the proposed project, as the site is located in an urbanized, infill area. In addition, the proposed project would be required to evaluate project-specific requirements, which would ensure the development does not overtax existing infrastructure or community service facilities, consistent with the guidelines, standards, design features, and mitigation measures provided in this EIR.

Therefore, while the proposed project would induce growth beyond current estimates and forecasts, it would not remove obstacles to further growth, expand infrastructure, or overtax existing community facilities. The proposed project would therefore not be considered substantially growth inducing.

6.3 Significant Irreversible Environmental Changes
CEQA Guidelines Section 15126.2(c) requires that an EIR identify any significant irreversible environmental changes associated with the proposed project. Such changes include, for example, the intensification of land use or irreversible damage from environmental accidents associated with the proposed project.

The project proposes development of 120 multifamily residential dwelling units on 7.6 acres for an approximate total density of 15.8 dwelling units per acre. The project would include a total of 26 0 new parking spaces in addition to 37 existing spaces on site , approximately 92,645 square feet of common recreation area , and an average of 146 square feet of private open per unit. The project proposes a General Plan Amendment, Rezone, Specific Plan, Tenta tive Map, and Site Development Plan. The General Plan Amendment and Rezone would change the General Plan designation and Zoning from Commercial (C) to Specific Plan Area (SPA).