ATTACHMENT D
ENVIRONMENTAL IMPACT REPORT
APPENDIX B3
NOTICE OF PREPARATION COMMENTS
“Provide a safe and reliable transportation network that serves all people and respects the environment” DISTRICT 11
4050 TAYLOR STREET, MS -240
SAN DIEGO, CA 92110
(619) 709-5152 | FAX (619) 688-4299 TTY 711
www.dot.ca.gov
May
4, 2023
11-SD-78
PM 10.67
Capalina Apartments
NOP/SCH#2023050006
Mr. Sean del Solar
Senior Planner
City of San Marcos
1 Civic Center Drive
San Marcos, CA 92069
Dear Mr. del Solar:
Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the Notice of Preparation of a Draft EIR for the Capalina Apartments located near State Route 78 (SR-78). The mission of Caltrans is to provide a safe and reliable transportation network that serves all people and respects the environment. The Local Development Review (LDR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities.
Safety is one of Caltrans’ strategic goals. Caltrans strives to make the year 2050 the first year without a single death or serious injury on California’s roads. We are striving for more equitable outcomes for the transportation network’s diverse users. To achieve these ambitious goals, we will pursue meaningful collaboration with our partners. We encourage the implementation of new technologies, innovations, and best practices that will enhance the safety on the transportation network.
These pursuits are both ambitious and urgent, and
their accomplishment involves a focused departure from the status quo as we continue to institutionalize safety in all our work.
Caltrans is committed to prioritizing projects that are equitable and provide meaningful benefits to historically underserved communities, to ultimately improve transportation accessibility and quality of life for people in the communities we serve.
We look forward to working with the City of San Marcos in areas where the City and Caltrans have joint jurisdiction to improve the transportation network and connections between various modes of travel, with the goal of improving the experience of those who use the transportation system.
CALIFORNIA STATE TRANSPORTATION AGENCY GAVIN NEWSOM, GOVERNOR California Department of Transportation
• •
li:t/trans·
Mr. Sean del Solar, Senior Planner
May 4, 2023
“Provide a safe and reliable transportation network that serves all people and respects the environment” Caltrans has the following comments:
Traffic Impact Study
• A Vehicle Miles of Travel (VMT) based Traffic Impact Study (TIS) should be provided for this project. Please use the Governor’s Office of Planning and Research Guidance to identify VMT related impacts.
1 • The TIS may also need to identify the proposed project’s near-term and long-term safety or operational issues, on or adjacent any existing or proposed State facilities.
Complete Streets and Mobility Network
Caltrans views all transportation improvements as opportunities to improve safety, access and mobility for all travelers in California and recognizes bicycle, pedestrian and transit modes as integral elements of the transportation network. Caltrans supports improved transit accommodation through the provision of Park and Ride facilities, improved bicycle and pedestrian access and safety improvements, signal prioritization for transit, bus on shoulders, ramp improvements, or other enhancements that promotes a complete and integrated transportation network. Early coordination with Caltrans, in locations that may affect both Caltrans and the City of San Marcos, is encouraged.
To reduce greenhouse gas emissions and achieve California’s Climate Change target, Caltrans is implementing Complete Streets and Climate Change policies into State Highway Operations and Protection Program (SHOPP) projects to meet multi-modal mobility needs. Caltrans looks forward to working with the City to evaluate potential Complete Streets projects.
Bicycle, pedestrian, and public transit access during construction is important.
Mitigation to maintain bicycle, pedestrian, and public transit access during construction is in accordance with Caltrans’ goals and policies.
Land Use and Smart Growth
Caltrans recognizes there is a strong link between transportation and land use.
Development can have a significant impact on traffic and congestion on State transportation facilities. In particular, the pattern of land use can affect both local vehicle miles traveled and the number of trips. Caltrans supports collaboration with local agencies to work towards a safe, functional, interconnected, multi-modal transportation network integrated through applicable “smart growth” type land use planning and policies.
1 California Governor's Office of Planning and Research (OPR) 2018. "Technical Advisory on Evaluating Transportation Impacts in CEQA." https://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf Mr. Sean del Solar, Senior Planner
May 4, 2023
“Provide a safe and reliable transportation network that serves all people and respects the environment” The City should continue to coordinate with Caltrans to implement necessary improvements at intersections and interchanges where the agencies have joint jurisdiction.
Noise
The applicant must be informed that in accordance with 23 Code of Federal Regulations (CFR) 772, Caltrans is not responsible for existing or future traffic noise impacts associated with the existing configuration of SR-78.
Environmental
Caltrans welcomes the opportunity to be a Responsible Agency under the California Environmental Quality Act (CEQA), as we have some discretionary authority of a portion of the project that is in Caltrans’ Right-of-Way (R/W) through the form of an encroachment permit process. We look forward to the coordination of our efforts to ensure that Caltrans can adopt the alternative and/or mitigation measure for our R/W. We would appreciate meeting with you to discuss the elements of the EIR that Caltrans will use for our subsequent environmental compliance.
An encroachment permit will be required for any work within the Caltrans’ R/W prior to construction. As part of the encroachment permit process, the applicant must provide approved final environmental documents for this project, corresponding technical studies, and necessary regulatory and resource agency permits. Specifically, CEQA determination or exemption. The supporting documents must address all environmental impacts within the Caltrans’ R/W and address any impacts from avoidance and/or mitigation measures.
We recommend that this project specifically identifies and assesses potential impacts caused by the project or impacts from mitigation efforts that occur within Caltrans’ R/W that includes impacts to the natural environment, infrastructure including but not limited to highways, roadways, structures, intelligent transportation systems elements, on-ramps and off-ramps, and appurtenant features including but not limited to fencing, lighting, signage, drainage, guardrail, slopes and landscaping. Caltrans is interested in any additional mitigation measures identified for the project’s draft Environmental Document.
Broadband
Caltrans recognizes that teleworking and remote learning lessen the impacts of traffic on our roadways and surrounding communities. This reduces the amount of VMT and decreases the amount of greenhouse gas (GHG) emissions and other pollutants. The availability of affordable and reliable, high-speed broadband is a key component in supporting travel demand management and reaching the state’s transportation and climate action goals.
Mr. Sean del Solar, Senior Planner
May 4, 2023
“Provide a safe and reliable transportation network that serves all people and respects the environment” Mitigation
Caltrans endeavors that any direct and cumulative impacts to the State Highway network be eliminated or reduced to a level of insignificance pursuant to the California Environmental Quality Act (CEQA) and National Environmental Policy Act (NEPA) standards.
Mitigation measures to State facilities should be included in TIS/TIA. Mitigation identified in the traffic study, subsequent environmental documents, and mitigation monitoring reports, should be coordinated with Caltrans to identify and implement the appropriate mitigation. This includes the actual implementation and collection of any “fair share” monies, as well as the appropriate timing of the mitigation.
Mitigation improvements should be compatible with Caltrans concepts.
Right-of-Way
• Per Business and Profession Code 8771, perpetuation of survey monuments by a licensed land surveyor is required, if they are being destroyed by any construction. • Any work performed within Caltrans’ R/W will require discretionary review and approval by Caltrans and an encroachment permit will be required for any work within the Caltrans’ R/W prior to construction.
Additional information regarding encroachment permits may be obtained by contacting the Caltrans Permits Office at (619) 688-6158 or emailing [email protected]
or by visiting the website at
If you have any questions or concerns, please contact Shannon Aston, LDR Coordinator, at (619) 992-0628 or by e-mail sent to [email protected].
Sincerely,
Kimberly Dodson for
MAURICE A. EATON
Branch Chief
Local Development Review
1 Sean del Solar
From: Troeller, Alexandra@Wildlife <[email protected]> Sent: Monday, May 8, 2023 10:31 AM
To: Sean del Solar
Subject: SCH 2023050006 Capalina Apartments
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Hi Sean,
This email is a follow‐up to my voicemail left on Friday 5/5/2023 and my phone call this morning, which also went to voicemail. I am the CDFW scientist reviewing the Capalina Apartments NOP, and I have a few questions I wanted to clarify/discuss with you. At your earliest convenience, please reach out via ph one at 858‐354‐4299.
Thank you,
Alex Troeller
Environmental Scientist
South Coast Region 5
Habitat Conservation
3883 Ruffin Road
San Diego, CA 92123
Mobile: (858) 354‐4299
CALIFORNIA DEPAIITMENT OF '
FISH and WILDLIFE
wildlife.ca.gov
STATE OF CALIFORNIA • NATURAL RESOURCES AGENCY Gavin Newson, Governor DEPARTMENT OF FISH AND WILDLIFE Charlton H. Bonham, Director South Coast Region
3883 Ruffin Road | San Diego, CA 92123
wildlife.ca.gov
May 30, 2023
Sean del Solar, Senior Planner
City of San Marcos
1 Civic Center Drive
San Marcos, CA 92069
[email protected]
Subject: Notice of Preparation of a Draft Environmental Impact Report for the Capalina Apartments Project, SCH #2023050006, San Diego County
Dear Mr. del Solar:
The California Department of Fish and Wildlife (CDFW) received a Notice of Preparation (NOP) of a draft environmental impact report (DEIR) from the City of San Marcos (City) for the Project pursuant the California Environmental Quality Act (CEQA) and CEQA Guidelines.
Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife. Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.
CDFW ROLE
CDFW is California’s Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State. (Fish & G. Code, §§ 711.7, subd. (a) & 1802; Pub. Resources Code, § 21070; CEQA Guidelines § 15386, subd. (a).) CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species. (Id., § 1802.) Similarly for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review DocuSign Envelope ID: EFFE4755-DE79-4DAC-98ED-A8269E94D8D5 Sean del Solar
City of San Marcos
May 30, 2023
efforts, focusing specifically on projects and related activities that have the potential to adversely affect fish and wildlife resources.
CDFW also administers the Natural Community Conservation Planning (NCCP) program, a California regional habitat conservation planning program. The City was a local jurisdiction participant in the early planning of the Subregional Multiple Habitat Conservation Program (MHCP) in the late 1990’s and early 2000’s. The City had prepared a draft Subarea Plan under the Subregional MHCP, which addressed regional conservation planning across seven incorporated jurisdictions on northern San Diego County. However, the San Marcos Subarea Plan was not finalized, and state and federal permits have not been issued to the City. To date, only the City of Carlsbad has received permits pursuant to the MHCP; however, the conservation principals remain relevant for development projects occurring in other jurisdictions. The City is no longer an active participant in the plan; however, it is the City’s policy to comply with the conservation policies identified in the draft San Marcos Subarea Plan.
PROJECT DESCRIPTION SUMMARY
Proponent: City of San Marcos (City)
Objective: The Project includes the rezoning and development of a 2.54-acre vacant lot into 119 apartment units, 4,000 square feet of commercial use, 147 parking spots, and associated residential amenities including a common open space area and a recreation/fitness center.
Location: The site is located along Capalina Road in the City of San Marcos, California. The Project site is currently an undeveloped, vacant lot located just north of Capalina Road, south of West Mission Road, east of South Rancho Santa Fe Road, and about one block north of CA State Route 78 (SR-78) in the Business/Industrial District. The SPRINTER rail line is also located in the Project vicinity. The Project site is undeveloped and generally flat with elevations ranging from approximately 580 to 600 feet above mean sea level (amsl).
Biological Resources: Though the Project site is mostly surrounded by development, multiple sensitive resources have previously been mapped within the surrounding areas, including thread-leaved brodiaea (Brodiaea filifolia; federally listed-threatened, state listed endangered, CNPS Rare Plant Rank 1B.1, proposed Narrow Endemic under the MHCP), Orcutt’s brodiaea (Brodiaea orcuttii; CNPS Rare Plant Rank 1B.1), and San Diego button celery (Eryngium aristulatum var. parishii; federally listed-endangered, state listed-endangered, DocuSign Envelope ID: EFFE4755-DE79-4DAC-98ED-A8269E94D8D5 Sean del Solar
City of San Marcos
May 30, 2023
California Native Plant Society (CNPS) Rare Plant Rank 1B.1, proposed Narrow Endemic under the MHCP). The site is mainly comprised of disturbed habitat containing non-native forbs and invasive grasses, mainly dominated by Russian thistle (Salsola tragus), Bermuda grass (Cynodon dactylon), tocalote (Centaurea melitensis), short-pod mustard (Hirschfeldia incana), and various species of bromes (Bromus sp.) and erodium (Erodium sp.). There are several non-native trees scattered throughout the site including Mexican fan palms (Washingtonia robusta) and Peruvian pepper tree (Schinus molle).
Comments and Recommendations
CDFW offers the comments and recommendations below to assist the City in adequately identifying, avoiding, and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources. The DEIR should provide adequate and complete disclosure of the Project’s potential impacts on biological resources [Pub. Resources Code, § 21061; CEQA Guidelines, §§ 15003(i), 15151]. CDFW looks forward to commenting on the DEIR when it is available.
General Comments
1. Biological Resource Inventory: The DEIR document should contain a complete description of the Project, including purpose and need, that describes all habitats within or adjacent to the Project area, all staging areas and access routes to the construction and staging areas. The Project area is described as the area in which potential effects may occur.
The document should also provide a complete assessment of the flora and fauna within and adjacent to the Project area, with particular emphasis upon identifying endangered, threatened, sensitive, and locally unique species and sensitive habitats. This should include a complete floral and faunal species compendium of the Project site, undertaken at the appropriate time of year. Species to be further addressed should include all those which meet the CEQA definition (see CEQA Guidelines, § 15380). This should include sensitive fish and wildlife species. Seasonal variations in use of the Project area by wildlife should also be addressed.
Focused species-specific surveys, conducted at the appropriate time of year and time of day when the sensitive species are active or otherwise identifiable, are required. Acceptable species-specific survey procedures DocuSign Envelope ID: EFFE4755-DE79-4DAC-98ED-A8269E94D8D5 Sean del Solar
City of San Marcos
May 30, 2023
should be developed in consultation with CDFW and the U.S. Fish and Wildlife Service.
2. Mitigation for Project-related Biological Impacts: The DEIR should include mitigation measures for adverse Project-related impacts to sensitive plants, animals, and habitats. Mitigation measures should emphasize avoidance and reduction of Project impacts. For unavoidable impacts, on-site habitat restoration or enhancement should be discussed in detail.
If on-site mitigation is not feasible or would not be biologically viable and therefore not adequately mitigate the loss of biological functions and values, off-site mitigation through habitat creation and/or acquisition and preservation in perpetuity should be discussed.
3. MHCP Alignment: While the City is not an active participant in the draft Subarea Plan, CDFW encourages consistency with draft Subarea Plan and appreciates the City’s efforts to adhere to policies in that plan.
Additionally, early, pre-Project coordination between the City and CDFW regarding regional conservation goals and objectives is also encouraged.
4. Cumulative Effects Analysis: A cumulative effects analysis should be developed as described under CEQA Guidelines, section 15130. General and specific plans, as well as past, present, and anticipated future projects, should be analyzed relative to their impacts on similar plant communities and wildlife habitats. The DEIR should evaluate the full scope of potential actions as part of the cumulative impact analysis and discussion of related actions.
Specific Comments
5. Brodiaea Surveys: To avoid potential impacts to rare plants, CDFW recommends conducting an additional focused survey for brodiaea during the appropriate blooming period of March-May to compare with previous focused survey data from 2021. Additionally, seasonally appropriate brodiaea pre-construction checks should occur prior to the start of construction.
6. Mitigation for Project-related Biological Impacts to Nonnative Grassland:
According to the Biological Resources letter provided by Dudek in April of 2023, the Project site is “extraordinarily disturbed with European grasses DocuSign Envelope ID: EFFE4755-DE79-4DAC-98ED-A8269E94D8D5 Sean del Solar
City of San Marcos
May 30, 2023
and broadleaf mustards” (Dudek 2023). Despite the site characteristics being classified as disturbed, grasses are pictured on page C-1 of Attachment C of the Biological Resources Letter. Additionally, CDFW points out that the vegetation delineation methods from the MHCP include non-native forb associations in the non-native grassland category, and thus these conditions should be defined as such and mitigated accordingly rather than delineated as “disturbed” with no associated mitigation requirement. This non-native grassland recognition ensures that habitat value for many species, including for raptor foraging, will be appropriately off-set when permanently lost to development. Thus, CDFW encourages the applicant to reassess the site and map land cover/vegetation consistent with the MHCP classifications, and mitigate accordingly.
7. Nesting Bird Surveys and Avoidance: CDFW appreciates the mitigation measures described in Mitigation Measure 1 (MM-BIO-1) of the Biological Resources Letter (Dudek, 2023). CDFW recommends the following changes (in bold and strikethrough).
MM-BIO-1: Construction-related ground-disturbing activities (e.g., clearing/grubbing, grading, and other intensive activities) that occur during the breeding season (typically February 1 through September 15) shall require a one-time biological survey for nesting bird species to be conducted within the limits of grading within 72 hours prior to construction. This survey is necessary to ensure avoidance of impacts to nesting raptors and/or birds protected by the federal Migratory Bird Treaty Act and California Fish and Game Code, Sections 3503 and 3513. If any active nests are detected, the area shall be flagged and mapped on the construction plans or a biological resources figure, and the information provided to the construction supervisor and any personnel working near the nest buffer. Active nests will have buffers established around them (e.g., 250 feet for passerines, 300 feet for listed bird species, and 500 feet for raptors) by the Project biologist in the field with brightly colored flagging tape, conspicuous fencing, or other appropriate barriers or signage. The Project biologist shall serve as a construction monitor during those periods when construction activities occur near active nest areas to avoid inadvertent impacts to these nests, providing daily “sweeps” at the start of each workday.
After conferring with CDFW and gaining approval, the Project biologist may adjust the 250-foot to 500-foot setback at his or her discretion depending on the DocuSign Envelope ID: EFFE4755-DE79-4DAC-98ED-A8269E94D8D5 Sean del Solar
City of San Marcos
May 30, 2023
species and the location of the nest (e.g., if the nest is well protected in an area buffered by dense vegetation). However, if needed, additional qualified monitor(s) shall be provided in order to monitor active nest(s) or other Project activities in order to ensure all of the Project biologist’s duties are completed.
Once the nest is no longer occupied for the season, construction may proceed in the setback areas.
If construction activities, particularly clearing/grubbing, grading, and other intensive activities, stop for more than 3 days, an additional nesting bird survey shall be conducted within the proposed impact area before construction proceeds.
ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub.
Resources Code, § 21003, subd. (e).) Accordingly, please report any special status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB). The CNNDB field survey form can be filled out and submitted online at the following link:
https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported to CNDDB can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.
ENVIRONMENTAL DOCUMENT FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is required in order for the underlying Project approval to be operative, vested, and final. (Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089.)
Conclusion
We appreciate the opportunity to comment on the NOP for the Capalina Apartments Project to assist the City in identifying and mitigating Project impacts on biological resources. If you have any questions or comments regarding this letter, please contact Alex Troeller, Environmental Scientist, at [email protected] or (858) 354-4299.
DocuSign Envelope ID: EFFE4755-DE79-4DAC-98ED-A8269E94D8D5 Sean del Solar
City of San Marcos
May 30, 2023
Sincerely,
David Mayer
Environmental Program Manager
South Coast Region
ec: CDFW
David Mayer, San Diego – [email protected]
Jennifer Turner, San Diego – [email protected] Cindy Hailey, San Diego – [email protected]
OPR
State Clearinghouse, Sacramento – [email protected]
City of San Marcos
Sean del Solar – [email protected]
REFERENCES
California Department of Fish and Wildlife. 2023. California Natural Diversity Database (CNDDB) – Plants and Animals. Available from:
https://wildlife.ca.gov/Data/CNDDB
Dudek, 2023. Biological Resources Letter Report for the Capalina Apartments Project, City of San Marcos, California (GPA22-0003, R22-0003, SDP22-000)
DocuSign Envelope ID: EFFE4755-DE79-4DAC-98ED-A8269E94D8D5 jnDocuSigned by:
~:it52~tY
“Environmental and public health through leadership, partnership and science”
May 16, 2023
Sean del Solar, Senior Planner for Chris Garcia
City of San Marcos Planning Division
1 Civic Center Drive
San Marcos, CA 92069
Via e-mail: [email protected]
COMMENTS ON THE ENVIRONMENTAL IMPACT REPORT FOR THE CAPALINA
APARTMENTS PROJECT
Dear Mr. Del Solar:
Thank you for the opportunity to comment on the Environmental Impact Report for the above referenced project. The County of San Diego Vector Control Program (VCP) is responsible for the protection of public health through the surveillance and control of mosquitoes that are vectors for human disease including West Nile virus (WNV). The VCP has completed their review and has the following comments regarding the proposed project.
1. The VCP respectfully requests that the Environmental Impact Report address potential impacts from possible mosquito breeding sources created by the project and that the project be designed and constructed in a manner to minimize those impacts. Specifically, ensure construction-related depressions created by grading activities, vehicle tires, and excavation do not result in depressions that will hold standing water. In addition, ensure drains, BMPs, stormwater capture systems, and other structures do not create a potential mosquito breeding source. Any area that is capable of accumulating and holding at least ½ inch of water for more than 96 hours can support mosquito breeding and development. Finally, if habitat remediation is required for the project, the design should be consistent with guidelines for preventing mosquito habitat creation.
2. Please note, the VCP has the authority pursuant to state law and County Code to order the abatement of any mosquito breeding that does occur either during construction or after the project is completed that is determined to be a vector breeding public nuisance. The VCP will exert that authority as necessary to protect public health if the project is not designed and constructed to prevent such breeding.
DEPARTMENT OF ENVIRONMENTAL HEALTH AND QUALITY
VECTOR CONTROL PROGRAM
5570 OVERLAND AVENUE, SUITE 102, SAN DIEGO, CA 92123
Phone: (858) 694-2888 Fax: (858) 505-6786
www.SDVector.com
HEATHER BUONOMO, REHS
DIRECTOR OF ENVIRONMENTAL HEALTH
AMY HARBERT
DIRECTOR
Oiountu of ~an JE}irgo
Mr. Del Solar
May 16, 2023
City of San Marcos
3. For your information, the County of San Diego Guidelines for Determining Significance for Vectors can be accessed at
http://www.sandiegocounty.gov/content/dam/sdc/pds/docs/vector_guidelines.pdf and the California Department of Public Health Best Management Practices for Mosquito Control in California is available at
https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/MosquitoesandMosquitoBorneDiseas es.aspx#
The VCP appreciates the opportunity to participate in the environmental review process for this project. If you have any questions regarding t hese comments, please contact Dan iel Valdez at 858- 688-3722 or by e-mail at [email protected].
Sincerely,
DANIEL VALDEZ, Registered Environmental Health Specialist Vector Control Program
CHAIRPERSON Laura
Miranda
luiseno VICE
CHAIRPERSON
Reginald
Pagallng
Chumash SECRETARY Sara
Dutschke
Miwok COMMISSIONER Isaac
Bojorquez
Ohlone-Costanoan COMMISSIONER Buffy
McQuillen
Yokayo
Pomo
, Yuki,
Nomlaki COMMI
SS
IONER
Wayne
Nelson
luiseno COMMI
SS
IONER
Stanley
Rodriguez
Kumeyaay COMMISSIONER [Vacant) COMMI
SS
IONER
[Vacant) EXECUTIVE
SECR
ET
ARY
Raymond
C.
Hitchcock Miwok,
Nisenan
NAHC
HEADQUARTERS
1550
Harbor
Boulevard
Suite
100
West
Sacramento,
California
95691
(916)
373-3710
nahc
@
nahc.ca.qov
NAHC.ca.gov
STATE
OF
CALIFORNIA
Gavin
Newsom
Governor
NATIVE
AMERICAN
HERITAGE
COMMISSION
May
2,
2023
Sean
Del
Solar
City
of
San
Marcos
l Civic
Center
Dr.
San
Marcos
, CA
92069
Re:
2023050006,
Capalina
Apartments,
San
Diego
County
Dear
Mr.
Del
Solar:
The
Native
American
Heritage
Commission
(NAHC)
has
received
the
Notice
of
Preparation
(NOP)
, Draft
Environmental
Impact
Report
(DEIR)
or
Early
Consultation
for
the
project
referenced
above
. The
California
Environmental
Quality
Act
(CEQA)
(Pub
. Resources
Code
§21000
et
seq.),
specifically
Public
Resources
Code
§21084.1,
states
that
a
project
that
may
cause
a
substantial
adverse
change
in
the
significance
of
a
historical
resource,
is
a
project
that
may
have
a
significant
effect
on
the
environment.
( Pub.
Resources
Code
§
21084.1;
Cal.
Code
Regs.,
tit.14
, § 15064.5
(b)
(CEQA
Guidelines
§ 15064
.5
(b)).
If there
is
substantial
evidence,
in
light
of
the
whole
record
before
a
lead
agency,
that
a
project
may
have
a
significant
effect
on
the
environment,
an
Environmental
Impact
Report
(EIR)
shall
be
prepared.
(Pub
. Resources
Code
§21080
(d);
Cal.
Code
Regs.,
tit.
14,
§
5064
subd.(a)(l)
(CEQA
Guidelines§
15064
(a)(l))
.
In
order
to
determine
whether
a
project
will
cause
a
substantial
adverse
change
in
the
significance
of
a
historical
resource
, a
lead
agency
will
need
to
determine
whether
there
are
historical
resources
within
the
area
of
potential
effect
(APE).
CEQA
was
amended
significantly
in
2014.
Assembly
Bill
52 (Gatto
, Chapter
532,
Statutes
of
2014)
(AB
52)
amended
CEQA
to
create
a
separate
category
of
cultural
resources,
"tribal
cultural
resources"
(Pub
. Resources
Code
§21074)
and
provides
that
a
project
with
an
effect
that
may
cause
a
substantial
adverse
change
in
the
significance
of
a
tribal
cultural
resource
is
a
project
that
may
have
a
significant
effect
on
the
environment.
(Pub
. Resources
Code
§21084.2).
Public
agencies
shall,
when
feasible,
avoid
damaging
effects
to
any
tribal
cultural
resource
. (Pub.
Resources
Code
§21084.3
(a)).
AB
52 applies
to
any
project
for
which
a
notice
of
preparation,
a
notice
of
negative
declaration,
or
a
mitigated
negative
declaration
is
filed
on
or
after
July
1,
2015.
If your
project
involves
the
adoption
of
or
amendment
to
a
general
plan
or
a
specific
plan,
or
the
designation
or
proposed
designation
of
open
space,
on
or
after
March
1,
2005
, it
may
also
be
subject
to
Senate
Bill
18 (Burton,
Chapter
905
, Statutes
of
2004)
(SB
18)
.
Both
SB
18 and
AB
52 have
tribal
consultation
requirements
.
If your
project
is
also
subject
to
the
federal
National
Environmental
Policy
Act
(42
U.S.C
. §
4321
et
seq.)
(NEPA),
the
tribal
consultation
requirements
of
Section
106
of
the
National
Historic
Preservation
Act
of
1966
( 154
U.S
.C.
300101,
36 C.F.R
. §800
et
seq.)
may
also
apply
.
The
NAHC
recommends
consultation
with
California
Native
American
tribes
that
are
traditionally
and
culturally
affiliated
with
the
geographic
area
of
your
proposed
project
as
early
as
possible
in
order
to
avoid
inadvertent
discoveries
of
Native
American
human
remains
and
best
protect
tribal
cultural
resources.
Below
is
a
brief
summary
of
portions
of
AB
52 and
SB
18 as
well
as
the
NAHC's
recommendations
for
conducting
cultural
resources
assessments
.
Consult
your
legal
counsel
about
compliance
with
AB
52 and
SB
18 as
well
as
compliance
with
any
other
applicable
laws.
Page
1 of
5 AB
52 has
added
to
CEQA
the
additional
requirements
listed
below,
along
with
many
other
requirements:
1. Fourteen
Day
Period
to
Provide
Notice
of
Completion
of
an
Application/Decision
to
Undertake
a
Proiect:
Within
fourteen
( 14)
days
of
determining
that
an
application
for
a
project
is
complete
or
of
a
decision
by
a
public
agency
to
undertake
a
project,
a
lead
agency
shall
provide
formal
notification
to
a
designated
contact
of,
or
tribal
representative
of,
traditionally
and
culturally
affiliated
California
Native
American
tribes
that
have
requested
notice,
to
be
accomplished
by
at
least
one
written
notice
that
includes:
a.
A
brief
description
of
the
project.
b.
The
lead
agency
contact
information.
c.
Notification
that
the
California
Native
American
tribe
has
30 days
to
request
consultation.
(Pub.
Resources
Code
§21080.3.1
(d)).
d.
A
"California
Native
American
tribe"
is
defined
as
a
Native
American
tribe
located
in
California
that
is
on
the
contact
list
maintained
by
the
NAHC
for
the
purposes
of
Chapter
905
of
Statutes
of
2004
(SB
18).
(Pub.
Resources
Code
§21073).
2. Begin
Consultation
Within
30 Days
of
Receiving
a
Tribe's
Request
for
Consultation
and
Before
Releasing
a
Negative Declaration,
Mitigated
Negative
Declaration,
or
Environmental
Impact
Report:
A
lead
agency
shall
begin
the
consultation
process
within
30 days
of
receiving
a
request
for
consultation
from
a
California
Native
American
tribe
that
is
traditionally
and
culturally
affiliated
with
the
geographic
area
of
the
proposed
project.
(Pub.
Resources
Code
§21080.3.1,
subds.
(d)
and
(e))
and
prior
to
the
release
of
a
negative
declaration,
mitigated
negative
declaration
or
Environmental
Impact
Report.
(Pub.
Resources
Code
§21080.3.1
(b)).
a.
For
purposes
of
AB
52,
"consultation
shall
have
the
same
meaning
as
provided
in
Gov.
Code
§65352.4
(SB
18).
(Pub.
Resources
Code
§21080.3.1
{b)).
3. Mandatory
Topics
of
Consultation
If
Requested
by
a
Tribe:
The
following
topics
of
consultation,
if a
tribe
requests
to
discuss
them,
are
mandatory
topics
of
consultation:
a.
Alternatives
to
the
project.
b.
Recommended
mitigation
measures.
c.
Significant
effects.
(Pub.
Resources
Code
§21080.3.2
(a)).
4. Discretionary
Topics
of
Consultation:
The
following
topics
are
discretionary
topics
of
consultation:
a.
Type
of
environmental
review
necessary.
b.
Significance
of
the
tribal
cultural
resources.
c.
Significance
of
the
project's
impacts
on
tribal
cultural
resources.
d.
If necessary,
project
alternatives
or
appropriate
measures
for
preservation
or
mitigation
that
the
tribe
may
recommend
to
the
lead
agency.
(Pub.
Resources
Code
§21080.3.2
(a)).
5. Confidentiality
of
Information
Submitted
by
a
Tribe
During
the
Environmental
Review
Process:
With
some
exceptions,
any
information,
including
but
not
limited
to,
the
location,
description,
and
use
of
tribal
cultural
resources
submitted
by
a
California
Native
American
tribe
during
the
environmental
review
process
shall
not
be
included
in
the
environmental
document
or
otherwise
disclosed
by
the
lead
agency
or
any
other
public
agency
to
the
public,
consistent
with
Government
Code
§6254
(r)
and
§6254.10.
Any
information
submitted
by
a
California
Native
American
tribe
during
the
consultation
or
environmental
review
process
shall
be
published
in
a
confidential
appendix
to
the
environmental
document
unless
the
tribe
that
provided
the
information
consents,
in
writing,
to
the
disclosure
of
some
or
all
of
the
information
to
the
public.
(Pub.
Resources
Code
§21082.3
(c)(l
)).
6. Discussion
of
Impacts
to
Tribal
Cultural
Resources
in
the
Environmental
Document:
If a
project
may
have
a
significant
impact
on
a
tribal
cultural
resource,
the
lead
agency's
environmental
document
shall
discuss
both
of
the
following:
a.
Whether
the
proposed
project
has
a
significant
impact
on
an
identified
tribal
cultural
resource.
b.
Whether
feasible
alternatives
or
mitigation
measures,
including
those
measures
that
may
be
agreed
to
pursuant
to
Public
Resources
Code
§21082.3,
subdivision
(a),
avoid
or
substantially
lessen
the
impact
on
the
identified
tribal
cultural
resource.
(Pub.
Resources
Code
§21082.3
(b)).
Page
2 of
5 7.
Conclusion
of
Consultation:
Consultation
with
a
tribe
shall
be
considered
concluded
when
either
of
the
following
occurs
:
a.
The
parties
agree
to
measures
to
mitigate
or
avoid
a
significant
effect,
if
a
significant
effect
exists,
on
a
tribal
cultural
resource;
or
b.
A
party,
acting
in
good
faith
and
after
reasonable
effort,
concludes
that
mutual
agreement
cannot
be
reached
.
(Pub.
Resources
Code
§21080.3
.2
(b))
.
8. Recommending
Mitigation
Measures
Agreed
Upon
in
Consultation
in
the
Environmental
Document:
Any
mitigation
measures
agreed
upon
in
the
consultation
conducted
pursuant
to
Public
Resources
Code
§21080.3.2
shall
be
recommended
for
inclusion
in
the
environmental
document
and
in
an
adopted
mitigation
monitoring
and
reporting
program
, if determined
to
avoid
or
lessen
the
impact
pursuant
to
Public
Resources
Code
§21082.3
,
subdivision
(b),
paragraph
2,
and
shall
be
fully
enforceable.
(Pub
. Resources
Code
§21082.3
(a))
.
9. Required
Consideration
of
Feasible
Mitigation
:
If mitigation
measures
recommended
by
the
staff
of
the
lead
agency
as
a
result
of
the
consultation
process
are
not
included
in
the
environmental
document
or
if
there
are
no
agreed
upon
mitigation
measures
at
the
conclusion
of
consultation,
or
if consultation
does
not
occur,
and
if
substantial
evidence
demonstrates
that
a
project
will
cause
a
significant
effect
to
a
tribal
cultural
resource
, the
lead
agency
shall
consider
feasible
mitigation
pursuant
to
Public
Resources
Code
§21084.3
(b).
(Pub
. Resources
Code
§21082
.3
(el)
.
10. Examples
of
Mitigation
Measures
That,
If
Feasible,
May
Be
Considered
to
Avoid
or
Minimize
Significant
Adverse
Impacts
to
Tribal
Cultural
Resources
:
a.
Avoidance
and
preservation
of
the
resources
in
place,
including
, but
not
limited
to:
i.
Planning
and
construction
to
avoid
the
resources
and
protect
the
cultural
and
natural
conte
xt.
ii.
Planning
greenspace,
parks,
or
other
open
space,
to
incorporate
the
resources
with
culturally
appropriate
protection
and
management
criteria
.
b.
Treating
the
resource
with
culturally
appropriate
dignity,
taking
into
account
the
tribal
cultural
values
and
meaning
of
the
resource
, including
, but
not
limited
to,
the
following:
i.
Protecting
the
cultural
character
and
integrity
of
the
resource.
ii.
Protecting
the
traditional
use
of
the
resource.
iii.
Protecting
the
confidentiality
of
the
resource.
c.
Permanent
conservation
easements
or
other
interests
in
real
properly,
with
culturally
appropriate
management
criteria
for
the
purposes
of
preserving
or
utilizing
the
resources
or
places.
d.
Protecting
the
resource.
(Pub
. Resource
Code
§21084
.3
(bl).
e.
Please
note
that
a
federally
recognized
California
Native
American
tribe
or
a
non-federally
recognized
California
Native
American
tribe
that
is
on
the
contact
list
maintained
by
the
NAHC
to
protect
a
California
prehistoric,
archaeological
, cultural
, spiritual
, or
ceremonial
place
may
acquire
and
hold
conservation
easements
if
the
conservation
easement
is
voluntarily
conveyed
.
(Civ.
Code
§815
.3
(c))
.
f.
Please
note
that
it
is
the
policy
of
the
state
that
Native
American
remains
and
associated
grave
artifacts
shall
be
repatriated.
(Pub.
Resources
Code
§5097
.991).
11. Prerequisites
for
Certifying
an
Environmental
Impact
Report
or
Adopting
a
Mitigated
Negative
Declaration
or
Negative
Declaration
with
a
Significant
Impact
on
an
Identified
Tribal
Cultural
Resource:
An
Environmental
Impact
Report
may
not
be
certified
, nor
may
a
mitigated
negative
declaration
or
a
negative
declaration
be
adopted
unless
one
of
the
following
occurs
:
a.
The
consultation
process
between
the
tribes
and
the
lead
agency
has
occurred
as
provided
in
Public
Resources
Code
§21080
.3.
l and
§21080.3.2
and
concluded
pursuant
to
Public
Resources
Code
§ 21080
.3.2.
b.
The
tribe
that
requested
consultation
failed
to
provide
comments
to
the
lead
agency
or
otherwise
failed
to
engage
in
the
consultation
process
.
c.
The
lead
agency
provided
notice
of
the
project
to
the
tribe
in
compliance
with
Public
Resources
Code
§21080
.3.
l (d)
and
the
tribe
failed
to
request
consultation
within
30 days
.
(Pub.
Resources
Code
§21082.3
(d))
.
The
NAHC's
PowerPoint
presentation
titled,
"Tribal
Consultation
Under
AB
52:
Requirements
and
Best
Practices"
may
be
found
on
line
at:
http://nahc
.ca.gov/wp-content
/uploads/20
15/
l 0/A
B52
Triba
IConsulta
tion
Ca
l EPA
PDF
.pdf
Page
3 of
5 SB
18 SB
18 applies
to
local
governments
and
requires
local
governments
to
contact
, provide
notice
to,
refer
plan
s to,
and
consult
with
tribes
prior
to
the
adoption
or
amendment
of
a
general
plan
or
a
specific
plan,
or
the
designation
of
open
space
. (Gov.
Code
§65352.3).
Local
governments
should
consult
the Governor'
s Office
of
Planning
and
Research's
"T
ribal
Consultation
Guidelines,"
which
can
be
found
online
at
:
https
://www
.opr.ca.gov/docs/09
14 05
Updated
Guidelines
922
.pdf
.
Some
of
SB
18's
provisions
include
:
1. Tribal
Consultation:
If a
local
government
considers
a
proposal
to
adopt
or
amend
a
general
plan
or
a
specific
plan
, or
to
designate
open
space
it is
required
to
contact
the
appropriate
tribes
identified
by
the
NAHC
by
reque
sting
a
"Tribal
Consultation
List
." If a
tribe
, once
contacted
, requests
consultation
the
local
government
must
consult
with
the
tribe
on
the
plan
proposal.
A
tribe
has
90 days
from
the
date
of
receipt
of
notification
to
request
consultation
unless
a
shorter
timeframe
has
been
agreed
to
by
the
tribe.
(Gov
. Code
§65352
.3
(a)(2))
.
2. No
Statutory
Time
Limit
on
SB
18 Tribal
Consultation
. There
is no
statutory
time
limit
on
SB
18 tribal
consultation.
3. Confidentiality
: Consistent
with
the
guidelines
developed
and
adopted
by
the
Office
of
Planning
and
Research
pursuant
to
Gov
. Code
§65040.2
, the
city
or
county
shall
protect
the
confidentiality
of
the
information
concerning
the
specific
identity
, location
, character
, and
use
of
places,
features
and
objects
described
in
Public
Resources
Code
§5097.9
and
§5097.993
that
are
within
the
city's
or
county's
jurisdiction
.
(Gov
. Code
§65352
.3
(b))
.
4. Conclu
sion
of
SB
18 Tribal
Consultation
:· Consultation
should
be
concluded
at
the
point
in
which:
a.
The
parties
to
the
consultation
come
to
a
mutual
agreement
concerning
the
appropriate
measures
for
preservation
or
mitigation;
or
b.
• Either
the
local
government
or
the
tribe,
acting
in
good
faith
and
after
reasonable
effort,
concludes
that
mutual
agreement
cannot
be
reached
concerning
the
appropriate
measures
of
preservation
or
mitigation
. (Tribal
Consultation
Guidelines,
Governor's
Office
of
Planning
and
Research
(2005)
at
p. 18).
Agencies
should
be
aware
that
neither
AB
52 nor
SB
18 precludes
agencies
from
initiating
tribal
consultation
with
tribes
that
are
traditionally
and
culturally
affiliated
with
their
jurisdictions
before
the
timeframes
provided
in
AB
52 and
SB
18 .
For
that
reason
, we
urge
you
to
continue
to
request
Native
American
Tribal
Contact
Lists
and
"Sacred
Land
s
File"
searches
from
the
NAHC.
The
request
forms
can
be
found
online
at
: http
://nahc
.ca.gov/resources/forms/
.
NAHC
Recommendations
for
Cultural
Re
sources
Asse
ssments
To
adequately
assess
the
existence
and
significance
of
tribal
cultural
resources
and
plan
for
avoidance,
preservation
in
place
, or
barring
both,
mitigation
of
project-related
impacts
to
tribal
cultural
resources,
the
NAHC
recommends
the
following
actions
:
1. Contact
the
appropriate
regional
California
Historical
Research
Information
System
(CHRIS)
Center
(https://ohp
.parks.ca
.gov
/?page_id=30331)
for
an
archaeological
records
search.
The
records
search
will
determine:
a.
If part
or
all
of
the
APE
has
been
previously
surveyed
for
cultural
resources
.
b.
If any
known
cultural
resources
have
already
been
recorded
on
or
adjacent
to
the
APE.
c.
If the
probability
is
low,
moderate,
or
high
that
cultural
resources
are
located
in
the
APE
.
d.
If a
survey
is
required
to
determine
whether
previously
unrecorded
cultural
resources
are
present
.
2. If an
archaeological
inventory
survey
is
required
, the
final
stage-is
the
preparation
of
a
professional
report
detailing
the
findings
and
recommendations
of
the
records
search
and
field
survey.
a.
The
final
report
containing
site
forms
, site
significance,
and
mitigation
measures
should
be
submitted
immediately
to
the
planning
department
. All
information
regarding
site
locations
, Native
American
human
remains
, and
associated
funerary
objects
should
be
in
a
separate
confidential
addendum
and
not
be
made
available
for
public
disclosure.
b.
The
final
written
report
should
be
submitted
within
3 months
after
work
ha
s been
completed
to
the
appropriate
regional
CHRIS
center
.
Page
4 of
5 3.
Contact
the
NAHC
for:
a.
A
Sacred
Lands
File
search.
Remember
that
tribes
do
not
always
record
their
sacred
sites
in
the
Sacred
Lands
File,
nor
are
they
required
to
do
so
. A
Sacred
Lands
File
search
is
not
a
substitute
for
consultation
with
tribes
that
are
traditionally
and
culturally
affiliated with
the
geographic
area
of
the
project's
APE.
b.
A
Native
American
Tribal
Consultation
List
of
appropriate
tribes
for
consultation
concerning
the
project
site
and
to
assist
in
planning
for
avoidance,
preservation
in
place,
or,
failing
both,
mitigation
measures
.
4. Remember
that
the
lack
of
surface
evidence
of
archaeological
resources
(including
tribal
cultural
resources)
does
not
preclude
their
subsurface
existence.
a.
Lead
agencies
should
include
in
their
mitigation
and
monitoring
reporting
program
plan
provisions
for
the
identification
and
evaluation
of
inadvertently
discovered
archaeological
resources
per
Cal.
Code
Regs.,
tit.
14,
§ 15064.S(f)
(CEQA
Guidelines§
15064.5(f)).
In
areas
of
identified
archaeological
sensitivity,
a
certified
archaeologist
and
a
culturally
affiliated
Native
American
with
knowledge
of
cultural
resources
should
monitor
all
ground-disturbing
activities.
b.
Lead
agencies
should
include
in
their
mitigation
and
monitoring
reporting
program
plans
provisions
for
the
disposition
of
recovered
cultural
items
that
are
not
burial
associated
in
consultation
with
culturally
affiliated
Native
Americans
.
c.
Lead
agencies
should
include
in
their
mitigation
and
monitoring
reporting
program
plans
provisions
for
the
treatment
and
disposition
of
inadvertently
discovered
Native
American
human
remains.
Health
and
Safety
Code
§ 7050.5,
Public
Resources
Code
§ 5097
. 98,
and
Cal.
Code
Regs
., tit
. 14,
§ 15064.5
,
subdivisions
( d)
and
( e)
( CEQA
Guidelines
§ 15064.5,
subds.
( d)
and
( e))
address
the
processes
to
be
followed
in
the
event
of
an
inadvertent
discovery
of
any
Native
American
human
remains
and
associated
grave
goods
in
a
location
other
than
a
dedicated
cemetery.
If you
have
any
questions
or
need
additional
information,
please
contact
me
at
my
email
address:
Pricilla
.Torres
Fuentes
@
nahc
.ca
.qov
.
Sincerely, Pricilla
Torres-Fuentes
Cultural
Resources
Analyst
cc
: State
Clearinghouse
Page
5 of
5 ,. ~i.::::::::;:-::;~;.;_-,..-• ► San Diego County Archaeological Society, Inc. ~ ~ /; Environmental Review Committee
,s. c,'
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~oc, cP-\.
To:
Subject:
13 May 2023
Mr. Sean del Solar, Senior Planner
Planning Division
City of San Marcos
1 Civic Center Drive
San Marcos, California 92069
RECEM!D
MAY 18 2023
CITY OF SAN u~os
Pl.ANNING DiV'IS!ON
Notice of Preparation of a Draft Environmental Impact Report Capalina Apartments
GPA22-0003, R22-0003, SDP22-0007, EIR23-003
Dear Mr. del Solar:
Thank you for the Notice of Preparation for the subject project, which was received by this Society earlier this month.
We are pleased to note the inclusion of historical resources in the list of subject areas to be addressed in the DEIR and look forward to reviewing it during the upcoming public comment period. To that end, please include us in notification of the public review of the DEIR and ensure availability of a copy of the cultural resources technical report(s).
SDCAS appreciates being included in the environmental review process for this project. cc: SDCAS President
File
..
Sincerely,
~yle, Jr., Chairp on
Environmental Review Committee
P.O. Box 81106 San Diego, CA 92138-1106 (858) 538-0935
1 Sean del Solar
From: Lionel Burton <[email protected]>
Sent: Saturday, April 29, 2023 12:10 PM
To: Sean del Solar
Subject: SUGGESTION ON PROPOSED CAPALINA ROAD PROJECT
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
My name is Jeff Burton. My phone
contact is == (760) 566-3999.
My suggestion on the
proposed project at Capalina Road is
create a City Park Project instead of
an Apartment Unit Project.
Hopefully, this e=mail will be put
with others who would prefer my
suggestion.
1 Sean del Solar
From: Shannon <[email protected]>
Sent: Friday, May 5, 2023 7:49 PM
To: Sean del Solar
Subject: Capalina Apartments
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Shannon Doyle
1515 Capalina Road
Space 33
San Marcos, CA 92069
(714) 783-8746
Attn: Sean del Solar, Senior Planner for Chris Garcia City of San Marcos Planning Division Re:
Re: Response to NOP for proposed Capalina Apartments:
While I can certainly see the advantages to this development, I have some concerns regarding this proposed project. Please note the following:
No street lights or crosswalks on Capalina from Rancho Santa Fe to Pacific. Traffic: Congestion on Rancho Santa Fe with offramp activity to and from the 78 freeway. Pacific cut through turn is in an industrial area with a severe right curve and has a hard left unregulated turn onto Capalina right before 7-11 parking entrance. Noise: Will new tenants be advised considering Sprinter train, and 2 Nightclubs with loud music up to 2am?
El Dorado Mobil Home Park at 1515 Capalina is a SENIOR PARK with owners and tenants needing to live in a quiet, safe environment. Please don't disregard us in the name of progress or profits.
Finally, when the construction is complete, the success or failure of the project will depend on the quality of the management. Hopefully, the owners and the City of San Marcos, will recognize this.
Thank you for your time.
Mr>-d
RE: CA 1 A IN A AfA 1<TMENT S
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