ATTACHMENT D
ENVIRONMENTAL IMPACT REPORT
APPENDIX K
RESPONSES TO COMMENTS
APPENDIX K
Responses to Comments
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Responses to Comment Letters Received on
the Draft EIR
The Draft Environmental Impact Report (EIR) was circulated for public review from December 21, 2023, through February 5, 2024 , in accordance with Section 15105(a) of the California Environmental Quality Act (CEQA) Guidelines. A total of six written comment letters were received on the Draft EIR from agencies, organizations, and individuals as shown in Table 1. Each of the written comment letters have been assigned an alphanumeric label, and the individual comments within each written comment letter are bracketed and numbered. For example, Comment Letter A1 contains six comments that are numbered A1-1 through A1-6.
The responses to each comment on the Draft EIR represent a good -faith, reasoned effort to address the environmental issues identified by the comments. Pursuant to Section 15088(a) of the CEQA Guidelines, the City of San Marcos (City), as lead agency, is not required to respond to all comments on the Draft EIR, but only those comments that raise environmental issues. In accordance with CEQA Guidelines Sections 15088 and 15204, the City has independently evaluated the comments and prepared the attached writte n responses to any significant environmental issues raised.
Table 1. Comment Letters and Commenters
Comment Letter Commenter Date Received
Agency
A1 California Department of Transportation January 22, 2024 A2 County of San Diego Public Works February 5, 2024
A3 San Diego County Water Authority February 5, 2024
A4 U.S. Fish and Wildlife Service February 12, 2024
Organizations
O1 San Diego County Archaeological Society January 13, 2024 O2 Supporters Alliance for Environmental Responsibility February 5, 2024
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Comment Letter A1
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Response to Comment Letter A1
Agency
California Department of Transportation (Caltrans)
January 22, 2024
A1-1 The comment provides an introduction to comments that follow, an explanation of Caltrans’s mission and priorities. The comment does not raise any specific issues related to the adequacy of the Draft Environmental Impact Report ( EIR), and no further response is required. Please refer the following Responses to Comments A1-2 through A1-6.
A1-2 The comment reviews strategic goals and priorities of Caltrans, including safety. The comment states that Caltrans is committed to prioritizing transportation opportunities in underserved communities. The comment also expresses that Caltrans looks forward to potential opportunities to coordinate with the City of San Marcos (City) to make improvements to safety, access, and mobility. In response, the proposed project includes mobility improvements on site and within project frontage areas, such as sidewalks and bicycle facilities. As outlined in Section 3.15, Transportation, of the EIR, the project would enhance the walkability and safety of the overall pedestrian environment and would not result in any impacts to pedestrian facilities. The comment does not raise any specific issues related to the adequacy of the EIR, and no further response is required.
A1-3 The comment expresses concerns regarding the project ’s significant and partially mitigated impact related to vehicle miles traveled ( VMT). The comment states that the proposed project needs to implement additional measures to further reduce VMT impacts to a less -than-significant level and includes a list of potential measures. In response, t he proposed project explored additional methods to address its VMT impact; however, as documented in Attachment B of the Hughes Circuits – Vehicle Miles Traveled (VMT) Analysis Technical Memorandum (December 2023) (Appendix I-2 to the EIR) , a full list of VMT mitigation measures taken into consideration is provided along with an expla nation as to their feasibility. The proposed project would provide mitigation measures that include some of the suggested measures in the Caltrans letter, such as the following:
▪ Improve bicycle network (CAPCOA T-20)
▪ Provide bicycle parking (CAPCOA T-10)
▪ Provide ride-sharing programs (CAPCOA T-8)”
In conclusion, the proposed project VMT analysis did consider alternative methods to reduce project impacts related to VMT. However, as outlined in Section 3.15 of the EIR, Mitigation Measure (MM) TRA-1, MM-TRA-2, and MM-TRA-3 would reduce impacts related to the VMT per resident, but not to a level of less than significant. Therefore, even with implementation of these mitigation measures, project VMT would remain significant. As a result of the significant and unavoidable impact related to VMT, the proposed project would be required to prepare a Statement of Overriding Considerations. The City of San Marcos Planning Commission would ultimately review the proposed project and approve or deny the project Statement of Overriding Considerations for significant and unavoidable impacts related to VMT.
A1-4 The comment states that perpetuation of survey monuments by a licensed land surveyor is required, if they are being destroyed by any construction. No survey monuments would be destroyed during project construction.
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A1-5 The comment states that any work performed within Caltrans ’ right-of-way will require discretionary review and approval by Caltrans and an encroachment permit will be required for any work within the Caltrans right -of-way prior to construction. The City acknowledges this comment. Additionally, t he comment states that an encroachment permit would be required for any work within the Caltrans right- of-way, the project would be required to provide an approved final environmental document, the document must address all impacts within the Caltrans right-of-way, and the document must address any impacts from avoidance or mitigation in the document. In response, the project does not propose any work within the Caltrans right -of-way, and an encroachment permit would not be required . The comment does not raise any specific issues related to the adequacy of the EIR, and no further response is required.
A1-6 The comment includes concluding remarks. The comment does not raise any specific environmental issues related to the adequacy of the Draft EIR, and no further response is required.
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Comment Letter A2
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Response to Comment Letter A2
Agency
County of San Diego Public Works
February 5, 2024
A2-1 The comment provides an introduction to comments that follow. The comment does not raise any specific issues related to the adequacy of the Draft Environmental Impact Report (EIR).
A2-2 The comment states that the County of San Diego Department of Public Works Closed Landfills has partial maintenance responsibility for the Bradley Park (Old San Marcos) Landfill , west of the project site across Pacific Street. The County of San Diego Department of Public Works monitors the gas and groundwater at the Bradley Park inactive landfill in order to protect public health, safety, and the environment of nearby residents. The comment also states that if impacts related to land disposal operation are found to be significant, those impacts should be mitigated through changes in building and utility design while implementing different construction measures.
In response, the proposed Hughes Circuits project is not a residential project. It is an industrial project that would be an extension of existing operations at the Hughes Circuits Facility immediate ly south of the project site across South Pacific Street. With the exception of impacts related to biological resources, cultural and tribal cultural resources, paleontological resources, and traffic/circulation, the EIR determined that impacts related to project construction and operation would be less than significant. Specific to this response, less-than-significant impacts were determined in the Hazards and Utilities sections of the EIR (Section 3.8 and 3.17 , respectively), and no associated mitigation is required. The project would connect to existing electrical and utility lines within South Pacific Street.
Regarding sewer facilities, there are existing gravity sewer lines within South Pacific Street and one line that runs through the project site. The sewer line i n South Pacific Street ’s depth is 8 to 12 fe et, increasing in depth as it goes north. The existing sewer main that runs through the project site would be relocated to South Pacific Street. No impacts are determined with this off -site improvement. The inactive Bradley Park landfill unit itself would stay intact, and the project would not create a corridor for gas or groundwater migration as utilities already exist within Pacific Street. Under the California Environmental Quality Act (CEQA), the EIR prepared for the project is required to analyze the p roject’s impacts on the existing environment and is not required to analyze fugitive gas from other sites.
The City of San Marcos (City) is responsible for the upper 36 inches of topsoil including vegetation and improvements at Bradley Park/Old San Marcos Landfill. The County of San Diego (County) is responsible for the “subsurface,” which includes gas and groundwater monitoring at Bradley Park/Old San Marcos Landfill. A specific monitoring and reporting program was established in 2010 that requires the County to provide the gas and groundwater data to the City as part of the overall semi-annual and annual report submittal to the San Diego Regional Water Quality Control Board. Based on the years of data collected from probes located on the perimeter of the park, there is no evidence that methane or any other gases are migrating from the park. There are also methane detectors in all structures on site, and no exceedances have been observed. Quarterly inspections are completed by the City and by County Department of Environmental Health and Quality (DEHQ) and Solid Waste Local Enforcement Agency (LEA) staff. In addition, County Public Works staff performs monthly site observations. All reports and associated documentation are provided on Geo Tracker online at https://geotracker. waterboards.ca.gov/profile_report?global_id=L10006943141.
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Furthermore, the California Department of Resources Recycling and Recovery has documented reports of other work activities on the existing closed landfill site (such as replacement of sewer line, sewer line repair, fence installation, tree removal and replacement, and excavation) dating back to 2015 that would have created potential concerns rather than those associated with construction of the proposed project. The project is not a residential project, nor is the project site adjacent to any residential zoning.
The comment does not raise any specific issues related to the adequacy of the EIR.
A2-3 The comment states that active and inactive landfills could potentially increase the risk of public health, safety, and the environment due to the generation of landfill gases and leachate. In response, under CEQA, the EIR analyzes project impacts on the existing environment. The project EIR is not responsible for analyzing environmental impacts of the mentioned active and inactive landfills in the vicinity. Concerns of environmental impacts from the mentioned active and inactive landfills should be addressed by the County or those responsible for the facility operations. As mentioned in Response to Comment A2-2, the project is not a residential project, nor is the project site adjacent to any residential zoning. The project would not introduce any new sensitive receptors to the area. The comment does not raise any specific issues related to the adequacy of the EIR. Please refer to Response to Comment A2-2.
A2-4 The comment states that utility easements and electrical and utility infrastructure could serve as a pathway for landfill gas if fugitive emissions exist. The comment also suggests that the Draft EIR should consider the cumulative nuisance impacts of the adjacent landfill. In response, neither construction nor operation of the project would create a new corridor for landfill gases/fugitive gas emissions from the adjacent Bradley Park inactive landfill, as utilities already exist within Pacific Street. The EIR determined no project or cumulative project impacts related to hazards or utilities. Under CEQA, the EIR prepared for the project is required to analyze the project ’s impacts on the existing environment and is not required to analyze fugitive gas from other sites.
As outlined in Sections 3.8, Hazards and Hazardous Materials, and 3.17, Utilities and Service Systems, of the EIR, project impacts related to hazards/hazardous materials and utilities and service systems were determined to be less than significant. Cumulative project impacts are analyzed throughout Chapter 3 of the EIR. Currently, there are multiple utilities that traverse through the project vicinity, within Pacific Street, including sewer, water, drainage, and dry utilities. As mentioned in Response to Comment A2-2 above, the project is not a residential project, nor is the project site adjacent to any residential zoning. The project purpose is to expand existing operations of the adjacent Hughes Circuits facility, and the project would not introduce any new sensitive receptors to the area. The comment does not raise any specific issues related to the adequacy of the EIR. Please refer to Response to Comment A2-2.
A2-5 The comment includes concluding remarks. The comment does not raise any specific environmental issues related to the adequacy of the Draft EIR.
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Comment Letter A3
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Response to Comment Letter A3
Agency
San Diego County Water Authority (SDCWA)
February 5, 2024
A3-1 The comment provides an introduction to comments that follow. The comment does not raise any specific issues related to the adequacy of the Environmental Impact Report (EIR).
A3-2 The comment provides background regarding the agency and its history regarding water in San Diego County. The comment does not raise any specific issues related to the adequacy of the EIR.
A3-3 The comment states that the project site saddles Pipeline 5 of the Second Aqueduct, which SDCWA owns and maintains. The comment does not raise any specific issues related to the adequacy of the EIR.
A3-4 The comment expresses concern that the proposed project’s storm drain inlet could restrict the flow of water into the adjacent parcel owned by SDCWA, leading to water ponding above their pipeline and flooding critical infrastructure. The comment requests that the project’s storm drain inlet be designed so that the system can accommodate the free flow of a significant storm event and that its design and impacts account for regular maintenance and cleaning of the inlet.
In response, the project would install a public storm drain system through the project site. The public storm drain system would be an extension of existing dual 66-inch culverts that currently accept flows from SDCWA property and the project site at the northern edge of existing improvements for South Pacific Street along the project frontage. The City of San Marcos (City) would own the completed storm drain system and would include this system in their maintenance program. The City would be granted a 30-foot public drainage easement to provide access to the facility for public inspection and maintenance to ensure flows are not reduced or restricted by sediment, debris, and/or trash . The design of the storm drain syste m would be in accordance with the latest San Diego County hydrology and hydraulic manual. The storm drain system would convey the 100-year storm and would be analyzed using the Water Surface Pressure Gradient (WSPG) hydraulic analysis computer program to ensure that the systems hydraulics does not impact upstream and downstream properties.
A3-5 The comment describes Mitigation Measure (MM) BIO-2, one that is designed to offset impacts to wetland habitats. The comment does not raise any specific issues related to the adequacy of the EIR.
A3-6 The comment states that neither the EIR o r the biological technical report identify which vernal pools would be subject to the mitigation and restoration efforts. In response, mitigation measure MM-BIO-2 in Section 3.3, Biological Resources, of the Draft EIR has been revised and is reflected in the Final EIR to include the following language: Mitigation will not occur within the San Diego County Water Authority owned parcels. The project applicant will consult with the U.S. Fish and Wildlife Service to ensure that the mitigation plan does not impact listed species.
A3-7 The comment reiterates that SDCWA’s ability to access, maintain, and improve Pipeline 5 of the Second Aqueduct is critical to ensure the continued delivery of reliable water to San Diego. The comment states that the restoration of vernal pools and watersheds on the project ’s parcels must not interfere with SDCWA’s ability to access, maintain, and improve their parcels and infrastructure. The comment also
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requests that the project proponent coordinates with SDCWA during development of the restoration plan. In response, habitat restoration as proposed by the project would not interfere with SDCWA’s ability to access and maintain their infrastructure. As outlined in Response to Comment A3-6, MM-BIO-2 in Section 3.3 of the Draft EIR has been revised and is reflected in the Final EIR to include the following language: Mitigation will not occur within the San Diego County Water Authority owned parcel s. The project applicant will consult with the U.S. Fish and Wildlife Service to ensure that the mitigation plan does not impact listed species.
The mitigation plan would be shared with SDCWA for comment, and the mitigation plan would be approved by U.S. Fish and Wildlife Service prior to any ground disturbance.
A3-8 The comment states that throughout the Draft EIR and appendices, parcels owned in fee by SDCWA are incorrectly described as “Water Authority right-of-way.” The comment requests that the documents should clarify that these parcels are owned by SDCWA. In response, revisions have been made where necessary to clarify that these parcels are owned by SDCWA. Please see revisions made in tracked changes in Chapter 2 , Project Description; Section 3.1, Aesthetics; Section 3.3; 3.10, Land Use and Planning; and Section 3.16, Tribal Cultural Resources of the Final EIR. All revisions made to the Draft EIR are shown in Table 2-2 in Chapter 2 of the Final EIR.
A3-9 The comment states that Section 3.17.1 incorrectly says that Vallecitos Water District receives its water from Metropolitan Water District when in fact, they receive their water from SDCWA. In response, this citation is from the City’s General Plan. Further along in Section 3.17.1, the text clarifies that SDCWA is the largest member agency of MWD and supplies water to its 24 member agencies serving the San Diego region, which includes Vallecitos Water District.
A3-10 The comment includes concluding remarks. The comment does not raise any specific environmental issues related to the adequacy of the Draft EIR.
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Comment Letter A4
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Response to Comment Letter A4
Agency
U.S. Fish and Wildlife Service (USFW S)
February 12, 2024
A4-1 The comment provides an introduction to comments that follow. The comment does not raise any specific issues related to the adequacy of the Environmental Impact Report (EIR).
A4-2 The comment reviews the goals and priorities of USFWS, which include the protection of fish and wildlife. The comment states that USFW S has legal responsibility for the welfare of migratory birds, anadromous fish, threatened animals, endangered species, and habitat conservation plans. The comment does not raise any specific issues related to the adequacy of the EIR.
A4-3 The comment reviews the description of the proposed project and existing site before discussing the listed species supported by the vernal pools in the central/eastern portion of the property site, which include the San Diego button celery (Eryngium aristulatum var. parishii) and threatened spreading navarretia (Navarretia fossalis). The comment also mentions that the project site also supports native grassland occupied by the threatened thread -leaved brodiaea (Brodiaea filifolia). The comment does not raise any specific issues related to the adequacy of the EIR.
A4-4 The comment discusses the agency’s correspondence with the applicant and describes the measures implemented by the City of San Marcos (City) to avoid impacts to vernal pools and native grassland occupied by federally listed species. The comment does not raise any specific issues related to the adequacy of the EIR.
A4-5 The comment states that the threatened coastal California gnatcatcher (Polioptila californica californica) has a moderate potential to occur on site and recommends that protocol gnatcatcher surveys should be conducted on the project site. In response, City staff met with USFWS staff, the applicant representatives, and environmental consultants on the project site in May 2023 for a site visit and to review biological resource findings. At that site visit, USFWS requested completion of additional California gnatcatcher and brodiaea surveying as a result of the wet winter/spring season that had occurred. A 2023 focused California gnatcatcher survey report was completed for the site on June 29, 2023, and was submitted to USFWS for review at that time. This June 2023 report found that no coastal California gnatcatchers were observed during any survey. Thirty-eight species of wildlife were detected during the surveys and are provided in Appendix A of the subject report. No rare species were detected within the impact area, and the report re -confirmed that the impact area on site is highly disturbed compared to the rest of the site , which is consistent with the findings of the biological technical report prepared for the project.
Furthermore, the project would implement Mitigation Measure (MM) BIO-10 (California Gnatcatcher Survey), MM-BIO-11 (California Gnatcatcher Nest Avoidance and Minimization Measures), and MM-BIO- 12 (General Pre-Construction Surveys), as outlined in Section 3.3, Biological Resources, of the EIR.
A4-6 The comment states that MM -BIO-1 says a long-term manager would be selected and a biological conservation easement recorded before a grading permit is issued, but appropriate funding and a long- term management plan has not been identified for the preserve. The comment recommends the
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applicant establish a non-wasting endowment for an amount approved by USFWS based on a Property Analysis Record (PAR). The comment states that ongoing funding needs to be secured for the perpetual management, maintenance, and monitoring of the biological conservation area by an agency, non - profit, or other entity approved by USFWS. In response, a PAR-like analysis would be completed, and the cost for an endowment would be developed as part of the Mitigation Plan. The following text has been added to MM-BIO-2 under Habitat Restoration Plan in Section 3.3 of the Final EIR, to address this comment: As part of the mitigation planning a PAR-like cost evaluation will be developed and approved by USFWS to help determine long term costs in the endowment required to support those costs. The applicant is required to fund the endowment before the issuance of grading permits , and the endowment agreement shall be approved by USFWS.
A4-7 The comment states that MM-BIO-2 mitigates the loss of 1.1 acres of wetland vegetation by removing invasive species and performing vernal pool restoration, including some minor recontouring within the preserve. The comment reiterates that the project site is known to be occupied by brodiaea, button celery, and navarretia. The comment also states that the project site is designated a critical habitat for the federally endangered San Diego fairy shrimp (Branchinecta sandiegonensis ). The comment recommends conducting protocol fairy shrimp surveys and evaluating potential impacts from invasive species removal and vernal pool restoration to brodiaea, button celery, navarretia, and fairy shrimp.
The comment also requests including mitigation measures to avoid and minimize potential impacts, that the invasive species removal and restoration plan be prepared in coordination with USFWS, and that all restoration exclude vernal pools within the San Diego County Water Authority easement. In response, it is acknowledged that fairy shrimp are present on site. However, fairy shrimp would not be impacted during project construction or restoration. All protocol surveys would include fairy shrimp in plans, and fairy shrimp would be a species targeted in the planning effort.
Additionally, mitigation measures MM-BIO-2 and MM-BIO-13 have been modified in Section 3.3 of the Draft EIR, as reflected in the Final EIR, to address this comment. MM -BIO-2 has been modified to include the following language under Vernal Pool Restoration: Any recontouring will avoid impacts to existing vernal pools and existing sensitive species and is intended to develop new pools or to expand pools from existing locations. Mitigation measure MM -BIO-13 has been modified to include the following language: The project applicant will consult with the U.S. Fish and Wildlife Service and get approval of the mitigation plan to ensure that it does not impact listed species.
A4-8 The comment includes concluding remarks. The comment does not raise any specific environmental issues related to the adequacy of the Draft EIR.
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Comment Letter O1
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Response to Comment Letter O1
Organization
San Diego County Archaeological Society (SDCAS)
January 13, 2024
O1-1 The comment states that SDCAS has reviewed the Draft Environmental Impact Report (EIR) and agrees with the conclusions and proposed Mitigation Measure (MM) CR-1 through MM -CR-4. The comment does not raise any specific environmental issues related to the adequacy of the Draft EIR , and no further response is required.
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Comment Letter O2
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Response to Comment Letter O2
Organization
Supporters Alliance for Environmental Responsibility
February 5, 2024
O2-1 The comment provides an introduction to comments that follow and a summary of the project description. The comment does not raise any specific issues related to the adequacy of the Draft Environmental Impact Report (EIR).
O2- 2 The comment states that the Draft EIR fails as an informational document and fails to implement all feasible mitigation measures to reduce the project’s significant impacts and that the Draft EIR needs to be recirculated . The comment does not raise any specific issues related to specific topics or mitigation measures in the Draft EIR that they believe are not adequately addressed. As discussed in the D raft EIR, with the exception of impacts related to vehicle miles traveled (VMT) , all potentially significant impacts are mitigated to less -than-significant levels, and no further mitigation is required.
As outlined in the Draft EIR, VMT cannot be mitigated to a level below significance and a Statement of Overriding Considerations has been prepared for the project for consideration by the Planning Commission. No further response is required because the comment does not raise an issue related to the adequacy of any specific section or analysis of physical environmental impacts in the Draft EIR.
O2-3 The comment states that they reserve the right to supplement their comment during the review of the Final EIR and at public hearings for the project. The City acknowledges this comment. The comment does not raise any specific issues related to the adequacy of the Draft EIR.
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