Sources of Greenhouse Gas Emissions
Anthropogenic GHG emissions worldwide in 2019 (the most recent year for which data is available) totaled approximately 52,400 million metric tons ( MMT) of CO 2e, excluding land use change and forestry (PBL 2020). The top six GHG emitters include China, the United States, the Russian Federation, India, Japan, and the European Union, which accounted for approximately 62% of the total global emissions, or approximately 32,500 MMT CO2e (PBL 2020).
Per the U.S. Environmental Protection Agency (EPA) Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 to 2019 (EPA 2021), total United States GHG emissions were approximately 6,558.3 MMT CO2e in 2019 (EPA 2021). The primary GHG emitted by human activities in the United States was CO2, which represented approximately 80.1% of total GHG emissions (5,255.8 MMT CO2e). The largest source of CO 2, and of overall GHG emissions, was fossil -fuel combustion, which accounted for approximately 92.4% of CO2 emissions in 2019 (4,856.7 MMT CO2e). Relative to 1990, gross United States GHG emissions in 2019 were 1.8% higher; however, the gross emissions were down from a high of 15.6% above 1990 levels in 2007. GHG emissions decreased from 2018 to 2019 by 1.7% (113.1 MMT CO2e) and overall, net emissions in 2019 were 13% below 2005 levels (EPA 2021).
According to California’s 2000 –2019 GHG emissions inventory (2021 edition), California emitted approximately 418 MMT CO 2e in 2019, including emissions resulting from out -of-state electrical generation (CARB 2021a). The sources of GHG emissions in California include transportation, industry, electric power production from both in -state and out -of-state sources, residential and commercial activities, agriculture, high-GWP substances, and recycling and waste. Table 3.7-2 presents California GHG emission source categories and their relative contributions to the emissions inventory in 2019.
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Between 2000 and 2019, per-capita GHG emissions in California have dropped from a peak of 14.0 MT per person in 2001 to 10.5 MT per person in 2019, representing an approximate 25% decrease.
In addition, total GHG emissions in 2019 were approximately 7 MMT CO2e lower than 2018 emissions (CARB 2021a).
Table 3.7-2
Greenhouse Gas Emissions Sources in California
Source Category Annual GHG Emissions (MMT CO2e) Percent of Total Transportation 166.1 39.7
Industrial 88.2 21.1
Electric power 58.8 14.1
Commercial and residential 43.8 10.5
Agriculture 31.8 7.6
High global-warming potential
substances
20.6 4.9
Recycling and waste 8.9 2.1
Totals 418.2 100
Source: CARB 2021a.
Notes: GHG = greenhouse gas; GWP = global warming potential; MMT CO2e = million metric tons of carbon dioxide equivalent.
Emissions reflect 2019 California GHG inventory.
Totals may not sum due to rounding.
The City of San Marcos (City) has established a goal to reduce its community-wide GHG to reduce GHG emissions 40% below 1990 levels by 2030 (City of San Marcos 2020). The City’s community-wide GHG emissions inventory for baseline year 2012 is presented in Table 3.7-3 for informational purposes.
Table 3.7-3
City of San Marcos (Year 2012) Communitywide Greenhouse Gas Emissions Inventory Community Sector Total MT CO2e per year CO2e (percent)
On-Road Transportation 322,000 54
Electricity 162,000 27
Natural Gas 75,000 12
Solid Waste 15,000 3
Off-Road Transportation 14,000 2
Water 9,000 1
Wastewater 3,000 <1
Total 599,000 100
Source: City of San Marcos 2020.
Note: GHG = greenhouse gas; MT CO2e = metric tons of carbon dioxide equivalent.
Totals may not sum due to rounding.
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Potential Effects of Climate Change
In California, climate change impacts have the potential to affect sea-level rise, agriculture, snowpack and water supply, forestry, wildfire risk, public health, and electricity demand and supply. The primary effect of global climate change has been a rise in average global tropospheric temperature. Reflecting the long-term warming trend since pre -industrial times, observed mean surface temperature for the decade 2006–2015 was 0.87°C (likely between 0.75°C and 0.99°C) higher than the average over the 1850–1900 period (IPCC 2018). Scientific modeling predicts that continued emissions of GHGs at or above current rates would induce more extreme climate changes during the twenty-first century than were observed during the twentieth century. Human activities are estimated to have caused approximately 1.0°C (1.8°F) of global warming above pre-industrial levels, with a likely range of 0.8°C to 1.2°C (1.4°F to 2.2°F) (IPCC 2018). Global warming is likely to reach 1.5°C (2.7°F) between 2030 and 2052 if it continues to increase at the current rate (IPCC 2018).
Although climate change is driven by global atmospheric conditions, climate change impacts are felt locally. A scientific consensus confirms that climate change is already affecting California. The Office of Environmental Health Hazard Assessment identified various indicators of climate change in California, which are scientifically based measurements that track trends in various aspects of climate change. Many indicators reveal discernible evidence that climate change is occurring in California and is havi ng significant, measurable impacts in the state. Changes in the state’s climate have been observed, including an increase in annual average air temperature with record warmth from 2012 to 2016, more frequent extreme heat events, more extreme drought, a decline in winter chill, an increase in cooling degree days and a decrease in heating degree days, and an increase in variability of statewide precipitation (OEHHA 2018).
Warming temperatures and changing precipitation patterns have altered California’s physical systems—the ocean, lakes, rivers and snowpack—upon which the state depends. Winter snowpack and spring snowmelt runoff from the Sierra Nevada and southern Cascade M ountains provide approximately one-third of the state’s annual water supply. Impacts of climate on physical systems have been observed, such as high variability of snow -water content (i.e., amount of water stored in snowpack), decrease in snowmelt runoff, glacier change (loss in area), rise in sea levels, increase in average lake water temperature and coastal ocean temperature, and a decrease in dissolved oxygen in coastal waters (OEHHA 2018).
In California, climate change impacts have the potential to affect sea-level rise, agriculture, snowpack and water supply, forestry, wildfire risk, public health, frequency of severe weather events, and electricity demand and supply. Potential effects of climate change are outlined in detail in Appendix B to this environmental impact report.
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3.7.2 Regulatory Setting
The following section provides a summary of the applicable regulatory requirements pertaining to GHGs, including federal, state, and local guidelines; additional detail can be found in Appendix B.
Federal
Massachusetts v. EPA
In Massachusetts v. E nvironmental Protection Agency (EPA) (April 2007), the U.S. Supreme Court directed the EPA administrator to determine whether GHG emissions from new motor vehicles cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare, or whether the scie nce is too uncertain to make a reasoned decision. In December 2009, the administrator signed a final rule with the following two distinct findings regarding GHGs under Section 202(a) of the federal Clean Air Act:
• The Administrator found that elevated concentrations of GHGs —CO2, CH 4, N 2O, HFCs, PFCs, and SF 6—in the atmosphere threaten the public health and welfare of current and future generations. This is the “endangerment finding.”
• The Administrator further found the combined emissions of GHGs—CO2, CH4, N2O, and HFCs—from new motor vehicles and new motor vehicle engines contribute to the GHG air pollution that endangers public health and welfare. This is the “cause or contribute finding.” These two findings were necessary to establish the foundation for regulation of GHGs from new motor vehicles as air pollutants under the Clean Air Act.
Energy Independence and Security Act
The Energy Independence and Security Act of 2007 (December 2007), among other key measures, would do the following, which would aid in the reduction of national GHG emissions:
• Increase the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard requiring fuel producers to use at least 36 billion gallons of biofuel in 2022. • Set a target of 35 miles per gallon for the combined fleet of cars and light trucks by model year 2020, and directs National Highway Traffic Safety Administration (NHTSA) to establish a fuel economy program for medium - and heavy-duty trucks and create a separate fuel economy standard for work trucks.
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• Prescribe or revise standards affecting regional efficiency for heating and cooling products and procedures for new or amended standards, energy conservation, energy -efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances.
Federal Vehicle Standards
In Massachusetts v. EPA (April 2007), the U.S. Supreme Court directed the EPA administrator to determine whether GHG emissions from new motor vehicles cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to make a reasoned decision. In December 2009, the administrator signed a final rule with the following two distinct findings regarding GHGs under Section 202(a) of the federal Clean Air Act:
• The administrator found that elevated concentrations of GHGs —CO2, CH 4, N 2O, HFCs, PFCs, and SF 6—in the atmosphere threaten the public health and welfare of current and future generations. This is the “endangerment finding.”
• The administrator further found that the combined emissions of GHGs —CO2, CH 4, N 2O, and HFCs—from new motor vehicles and new motor vehicle engines contribute to the GHG air pollution that endangers public health and welfare. This is the “cause or contribute finding.” These two findings were necessary to establish the foundation for regulation of GHGs from new motor vehicles as air pollutants under the Clean Air Act (42 USC Section 7401).
In 2007, in response to the Massachusetts v. EPA U.S. Supreme Court ruling, the Bush Administration issued Executive Order (EO) 13432 directing EPA, the Department of Transportation, and the Department of Energy to establish regulations that reduce GHG emissions from motor vehicles, non-road vehicles, and non-road engines by 2008. In 2009, the NHTSA issued a final rule regulating fuel efficiency and GHG emissions from cars and light-duty trucks for model year 2011, and, in 2010, EPA and NHTSA issued a final rule regulating cars and light-duty trucks for model years 2012 through 2016 (75 FR 25324–25728).
In 2010, President Obama issued a memorandum directing the Department of Transportation, Department of Energy, EPA, and NHTSA to establish additional standards regarding fuel efficiency and GHG reduction, clean fuels, and advanced vehicle infrastructure. In response to this directive, EPA and NHTSA proposed stringent, coordinated federal GHG and fuel economy standards for model years 2017 through 2025 light-duty vehicles. The proposed standards projected to achieve 163 grams per mile of CO 2 in model year 20 25, on an average industry fleet -wide basis, which is equivalent to
54.5 miles per gallon if this level were achieved solely through fuel efficiency. The final rule was adopted in 2012 for model years 2017 through 2021 (77 FR 62624–63200). On January 12, 2017,
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EPA finalized its decision to maintain the current GHG emissions standards for model years 2022 through 2025 cars and light trucks.
In addition to the regulations applicable to cars and light -duty trucks described above, in 2011, EPA and NHTSA announced fuel economy and GHG standards for medium- and heavy-duty trucks for model years 2014 through 2018. The standards for CO2 emissions and fuel consumption are tailored to three main vehicle categories: combination tractors, heavy -duty pickup trucks and vans, and vocational vehicles. According to EPA, this regulatory program will reduce GHG emissions and fuel consumption for the affected vehicles by 6% to 23% over the 2010 baselines (76 FR 57106–57513).
In August 2016, EPA and NHTSA announced the adoption of the phase two program related to the fuel economy and GHG standards for medium- and heavy-duty trucks. The phase two program will apply to vehicles with model year 2018 through 2027 for certain trailers, and model years 2021 through 2027 for semi-trucks, large pickup trucks, vans, and all sizes of buses and work trucks. The final standards are expected to lower CO2 emissions by approximately 1.1 billion MT and reduce oil consumption by up to 2 billion barrels over the lifetime of the vehicles sold under the program (EPA and NHTSA 2016).
In August 2018, EPA and NHTSA proposed to amend certain fuel economy and GHG standards for passenger cars and light trucks and establish new standards for model years 2021 through 2026.
Compared to maintaining the post-2020 standards then in place, the 2018 proposal would increase U.S. fuel consumption by about half a million barrels per day (2% to 3% of total daily consumption, according to the Energy Information Administration) and would impact the global climate by 3/1000th of one degree Celsius by 2100 (EPA and NHTSA 2018). California and other states have stated their intent to challenge federal actions that would delay or eliminate GHG reduction measures and have committed to cooperating with other countries to implement global climate change initiatives.
In 2019, EPA and NHTSA published the Safer Affordable Fuel -Efficient Vehicles Rule Part One: One National Program (SAFE -1), which revoked California’s authority to set its own GHG emissions standards and set zero-emissions vehicle (ZEV) mandates in California. In March 2020, Part Two was issued, which set CO 2 emissions standards and corporate average fuel economy standards for passenger vehicles and light-duty trucks for model years 2021 through 2026.
In response to EO 13990 (Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis, January 2021), on December 21, 2021, NHTSA finalized the CAFE Preemption rulemaking to withdraw its portions of the Part One Rule. The final rule concluded that the Part One Rule overstepped the agency’s legal authority and established overly broad prohibitions that did not account for a variety of important state and local interests. Then, in March 2022, NHTSA established new fuel econo my standards that would require an industry -wide fleet average of approximately 49 miles per gallon for passenger cars and light trucks in model year 2026, by increasing fuel efficiency by 8% annually for model years 2024 and 2025, and 10% annually for model
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year 2026. Also in March 2022, EPA reinstated California’s authority under the Clean Air Act to implement its own GHG emission standards and ZEV sales mandate. EPA’s March 2022 action concludes its reconsideration of the 2019 SAFE -1 rule by finding that the actions taken un der the previous administration as a part of SAFE-1 were decided in error and are now entirely rescinded.
The Inflation Reduction Act of 2022
The Inflation Reduction Act was signed into law by President Biden in August 2022. The bill includes specific investment in energy and climate reform and is projected to reduce GHG emissions within the United States by 40% as compared to 2005 levels by 2030. The bill allocates funds to boost renewable energy infrastructure (e.g., solar panels and wind turbines), includes tax credits for the purchase of electric vehicles, and includes measures that will make homes more energy efficient.
State
The statewide GHG emissions regulatory framework is summarized below by category: state climate change targets, building energy, renewable energy and energy procurement, mobile sources, solid waste, water, and other state regulations and goals. The following text describes EOs, Assembly Bills, Senate Bills, and other plans and policies that would directly or indirectly reduce GHG emissions and/or address climate change issues.
State Climate Change Targets
The state has taken a number of actions to address climate change. These include EOs, legislation, and CARB plans and requirements. These are summarized below.
EO S-3-05. EO S-3-05 (June 2005) established California’s GHG emissions reduction targets and laid out responsibilities among the state agencies for implementing the EO and for reporting on progress toward the targets. This EO established the following targets:
• By 2010, reduce GHG emissions to 2000 levels
• By 2020, reduce GHG emissions to 1990 levels
• By 2050, reduce GHG emissions to 80% below 1990 levels EO S -3-05 also directed the California Environmental Protection Agency to report biannually on progress made toward meeting the GHG targets and the impacts to California due to global warming, including impacts to water supply, public health, agriculture, the coastline, and forestry. The Climate Action Team was formed, which subsequently issued reports from 2006 to 2010 (CAT 2016).
Assembly Bill (AB) 32. In furtherance of the goals established in EO S -3-05, the Legislature enacted AB 32 (Núñez and Pavley). The bill is referred to as the California Global Warming Solutions Act of
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2006 (September 27, 2006). AB 32 provided initial direction on creating a comprehensive multiyear program to limit California’s GHG emissions at 1990 levels by 2020 and initiate the transformations required to achieve the state’s long-range climate objectives.
Senate Bill ( SB) 32 and AB 197 . SB 32 and AB 197 (enacted in 2016) are companion bills. SB 32 codified the 2030 emissions reduction goal of EO B -30-15 by requiring CARB to ensure that statewide GHG emissions are reduced to 40% below 1990 levels by 2030. AB 197 established the Joint Legislative Committee on Climate Change Policies, consisting of at least three members of the Senate and three members of the Assembly, in order to provide ongoing oversight over implementation of the state’s climate policies. AB 197 also added two members of t he Legislature to the Board as nonvoting members; requires CARB to make available and update (at least annually via its website) emissions data for GHGs, criteria air pollutants, and toxic air contaminants from reporting facilities; and requires CARB to identify specific information for GHG emissions reduction measures when updating the scoping plan.
EO B-30-15. EO B-30-15 (April 2015) identified an interim GHG reduction target in support of targets previously identified under S-3-05 and AB 32. EO B -30-15 set an interim target goal of reducing GHG emissions to 40% below 1990 levels by 2030 to keep California on i ts trajectory toward meeting or exceeding the long-term goal of reducing GHG emissions to 80% below 1990 levels by 2050 as set forth in S-3-05. To facilitate achieving this goal, EO B-30-15 called for CARB to update the Scoping Plan to express the 2030 target in terms of MMT CO 2e. The EO also called for state agencies to continue to develop and implement GHG emission reduction programs in support of the reduction targets.
EO B -55-18. EO B -55-18 (September 2018) establishes a new statewide goal “to achieve carbon neutrality as soon as possible , and no later than 2045, and achieve and maintain net negative emissions thereafter.” This EO directs CARB to “work with relevant state agencies to ensure future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal.” AB 1279. The Legislature enacted AB 1279, the California Climate Crisis Act, in September 2022. The bill declares the policy of the state to achieve net zero GHG emissions as soon as possible, but no later than 2045, and achieve and maintain net negative GHG emiss ions thereafter. Additionally, the bill requires that by 2045, statewide anthropogenic GHG emissions be reduced to at least 85% below 1990 levels.
AB 1757. AB 1757 (September 2022) requires the California Natural Resources Agency ( CNRA) to determine a range of targets for natural carbon sequestration, and for nature-based climate solutions that reduce GHG emissions for future years 2030, 2038, and 2045. These targets are to be determined by no later than January 1, 2024 and are establish ed to support the state’s goals to achieve carbon neutrality and foster climate adaptation and resilience.
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CARB’s 2007 Statewide Limit . In 2007, in accordance with California Health and Safety Code, Section 38550, CARB approved a statewide limit on the GHG emissions level for year 2020 consistent with the determined 1990 baseline (427 MMT CO2e).
CARB’s Climate Change Scoping Plan . One specific requirement of AB 32 is for CARB to prepare a “scoping plan” for achieving the maximum technologically feasible and cost -effective GHG emission reductions by 2020 (California Health and Safety Code Section 38561[a]), and to update the plan a t least once every 5 years. In 2008, CARB approved the first scoping plan: The Climate Change Proposed Scoping Plan: A Framework for Change (Scoping Plan). The Scoping Plan included a mix of recommended strategies that combined direct regulations, market-based approaches, voluntary measures, policies, and other emission-reduction programs calculated to meet the 2020 statewide GHG emission limit and initiate the transformations needed to achieve the state’s long-range climate objectives.
In 2014, CARB approved the first update to the Scoping Plan. The First Update to the Climate Change Scoping Plan: Building on the Framework (First Update) defined the state’s GHG emission reduction priorities for the next 5 years and laid the groundwork to start the transition to the post -2020 goals set forth in EOs S-3-05 and B-16-2012 (CARB 2014). The First Update concluded that California was on track to meet the 2020 target , but recommended a 2030 mid -term GHG reduction target be established to ensure a continuum of action to reduce emissions. The First Update recommended a mix of technologies in key economic sectors to reduce emissions through 2050 including energy demand reduction through efficiency and activity changes; large -scale electrification of on -road vehicles, buildings, and industrial machinery; decarbonizing electricity and fuel supplies; and the rapid market penetration of efficient and clean energy technologies.
In December 2017, CARB released the 2017 Climate Change Scoping Plan Update (Second Update) for public review and comment (CARB 2017a). The Second Update builds on the successful framework established in the initial Scoping Plan and First Update, while identifying new technologically feasible and cost-effective strategies that will serve as the framework to achieve the 2030 GHG target and define the state ’s climate change priorities to 2030 and beyond. The strategies ’ “known commitments” include implementing renewable energy and energy efficiency (including the mandates of SB 350), increased stringency of the Low Carbon Fuel Standard, measures identified in the Mobile Source and Freight Strategies, measures identified in the proposed Short-Lived Climate Pollutant Plan, and increased stringency of SB 375 targets. To fill the gap in additional reductions needed to achieve the 2030 target, the Second Update recommends continuing the Cap -and-Trade Program and a measure to reduce GHGs from refineries by 20 %. The Second Update was approved by CARB ’s Governing Board on December 14, 2017.
The Proposed Final 2022 Scoping Plan for Achieving Carbon Neutrality (Third Update) was issued on November 16, 2022 (CARB 2022). The Third Update lays out a path not just to carbon neutrality by 2045 but also to the 2030 GHG emissions reduction target. The modeling indicates that, if the plan described
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in the Proposed Scenario is fully implemented, and done so on schedule, the state would cut GHG emissions by 85% below 1990 levels, result in a 71% reduction in smog-forming air pollution, reduce fossil fuel consumption by 94%, create 4 million new jobs, among other benefits (CARB 2022). The carbon neutrality goal requires CARB to expand proposed actions from only the reduction of anthropogenic sources of GHG emissions to also include those that capture and store carbon (e.g., through natural and working lands, or mechanical technologies). The carbon reduction programs build on and accelerate those currently in place, including moving to zero-emission transportation; phasing out use of fossil gas use for heating homes and buildings; reducing chemical and refrigerants with high GWP; providing communities with sustainable options for walking, biking, and public transit; displacement of fossil-fuel fired electrical generation through use of renewable energy alternatives (e.g., solar arrays and wind turbines); and scaling up new options such as green hydrogen2 (CARB 2022).
The Third Update also emphasizes that there is no realistic path to carbon neutrality without carbon removal and sequestration, and to achieve the state’s carbon neutrality goal, carbon reduction programs must be supplemented by strategies to remove and sequester carbon. Strategies for carbon removal and sequestration include carbon capture and storage from anthropogenic point sources, where CO2 is captured as it leaves a facility’s smokestack and is injected into geologic formations or used in industrial materials (e.g., concrete); and CO2 removal from ambient air, through mechanical (e.g., direct air capture with sequestration) or nature-based (e.g., management of natural and working lands) applications.
The Scoping Plan recommends strategies for implementation at the statewide level to meet the goals of AB 32, SB 32, and the EOs; it also establishes an overall framework for the measures that will be adopted to reduce California’s GHG emissions. A project is considered consistent with the statutes and EOs if it would meet the general policies in reducing GHG emissions in order to facilitate the achievement of the state’s goals and would not impede attainment of those goals.
CARB’s Regulations for the Mandatory Reporting of Greenhouse Gas Emissions. CARB’s Regulation for the Mandatory Reporting of Greenhouse Gas Emissions (17 CCR 95100–95157) incorporated by reference certain requirements that EPA promulgated in its Final Rule on Mandatory Reporting of Greenhouse Gases (40 CFR, Part 98). Specifically, Section 95100(c) of the Mandatory Reporting Regulation incorporated those requirements that EPA promulgated in the Federal Register on October 30, 2009; July 12, 2010; September 22, 2010; October 28, 2010; November 30, 2010; December 17, 2010; and April 25, 2011.
In general, entities subject to the Mandatory Reporting Regulation that emit over 10,000 MT CO2e per year are required to report annual GHGs through the California Electronic GHG Reporting Tool. Certain sectors, such as refineries and cement plants, are required to report regardless of emission levels. Entities that
2 Green hydrogen refers to hydrogen that is generated by renewable energy or from low -carbon power, and has significantly lower associated carbon emissions than grey hydrogen, which is produced using natural gas and makes up the majority of hydrogen production. For the purposes of the Draft 2022 Scoping Plan, the term “green hydrogen” is not limited to only electrolytic hydrogen produced from renewables.
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emit more than the 25,000 MT CO2e per year threshold are required to have their GHG emission report verified by a CARB-accredited third-party verified.
SB 605 and SB 1383. SB 605 (2014) requires CARB to complete a comprehensive strategy to reduce emissions of short-lived climate pollutants in the state, and SB 1383 (2016) requires CARB to approve and implement that strategy by January 1, 2018. SB 1383 also establishes specific targets for the reduction of short-lived climate pollutants (40% below 2013 levels by 2030 for methane and HFCs, and 50% below 2013 levels by 2030 for anthropogenic black carbon), and provides direction for reductions from dairy and livestock operations and landfills. Accordingly, and as mentioned above, CARB adopted its Short -Lived Climate Pollutant Reduction Strategy (SLCP Reduction Strategy) in March 2017. The SLCP Reduction Strategy establishes a framework for the statewide reduction of emissions of black carbon, methane, and fluorinated gases (CARB 2017b).
Building Energy
Title 24, Part 6. Title 24 of the California Code of Regulations (CCR) was established in 1978 and serves to enhance and regulate California’s building standards. While not initially promulgated to reduce GHG emissions, Part 6 of Title 24 specifically established Building Energy Efficiency Standards that are designed to ensur e new and existing buildings in California achieve energy efficiency and preserve outdoor and indoor environmental quality. These energy efficiency standards are reviewed every few years by the Building Standards Commission and the California Energy Commission (CEC) (and revised if necessary) (California Public Resources Code [PRC] Section 25402[b][1]). The regulations receive input from members of industry, as well as the public, with the goal of “reducing of wasteful, uneconomic, inefficient, or unnecessary consumption of energy” (PRC Section 25402). These regulations are carefully scrutinized and analyzed for technological and economic feasibility (PRC Section 25402[d]) and cost effectiveness (PRC Sections 25402[b][2] and [b][3]). As a result, these standards save energy, increase electricity supply reliability, increase indoor comfort, avoid the need to construct new power plants, and help preserve the environment. The 2022 Title 24 standards are the currently applicable building energy efficiency standards, and became effective on January 1, 2023. The 2022 Energy Code focuses on four key areas in newly constructed homes and businesses:
• Encouraging electric heat pump technology for space and water heating, which consumes less energy and produces fewer emissions than gas-powered units • Establishing electric -ready requirements for single -family homes to position owners to use cleaner electric heating, cooking, and electric vehicle (EV) charging options whenever they choose to adopt those technologies
• Expanding solar photovoltaic (PV) system and battery storage standards to make clean energy available on site and complement the state’s progress toward a 100% clean electricity grid • Strengthening ventilation standards to improve indoor air quality
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Title 24, Part 11 . In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (24 CCR Part 11 ) is commonly referred to as California’s Green Building Standards (CALGreen), and establishes minimum mandatory standards and voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the Ca lifornia Energy Code requirements), water conservation, material conservation, and interior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground -up, new construction of commercial, low -rise residential and state-owned buildings and schools and hospitals. The CALGreen 2022 standards, which are the current standards, became effective January 1, 2023. For nonresidential projects, some of the key mandatory CALGreen standards involve requirements related to bicycle parking, requirements for EV capable space and EV charging stations, shade trees, water conserving plumbing fixtures and fittings, outdoor potable water use in landscaped areas, construction waste management, excavated soil and land clearing debris, and commissioning (24 CCR Part 11).
Title 20. CCR Title 20 requires manufacturers of appliances to meet state and federal standards for energy and water efficiency. The CEC certifies an appliance based on a manufacturer’s demonstration that the appliance meets the standards. New appliances regulated under Title 20 include refrigerators, refrigerator-freezers, and freezers; room air conditioners and room air-conditioning heat pumps; central air conditioners; spot air conditioners; vented gas space heaters; gas pool heaters; plumbing fittings and plumbing fixtures; fluorescent lamp ballasts; lamps; emergency lighting; traffic signal modules; dishwaters; clothes washers and dryers; cooking products; electric motors; low -voltage dry -type distribution transformers; power supplies; televisions and consumer audio and video equipment; and battery charger systems. Title 20 presents protocols for testing each type of appliance covered under the regulations and appliances must meet the standards for energy performance, energy design, water performance and water design. Title 20 contains three types of standards for appliances: federal and state standards for federally regulated appliances, state standards for federally regulated appliances, and state standards for non-federally regulated appliances.
SB 1. SB 1 (Murray) (August 2006) established a $3 billion rebate program to support the goal of the state to install rooftop solar energy systems with a generation capacity of 3,000 megawatts through 2016. SB 1 added sections to the Public Resources Code, inclu ding Chapter 8.8 (California Solar Initiative), that require building projects applying for ratepayer -funded incentives for photovoltaic systems to meet minimum energy efficiency levels and performance requirements. Section 25780 established that it is a goal of the state to establish a self-sufficient solar industry. The goals included establishing solar energy systems as a viable mainstream option for both homes and businesses within 10 years of adoption, and placing solar energy systems on 50% of new homes within 13 years of adoption. SB 1, also termed “Go Solar California,” was previously titled “Million Solar Roofs.”
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California AB 1470 (Solar Water Heating). This bill established the Solar Water Heating and Efficiency Act of 2007. The bill makes findings and declarations of the Legislature relating to the promotion of solar water heating systems and other technologies that reduce natural gas demand. The bill defines several terms for purposes of the act. The bill requires the commission to evaluate the data available from a specified pilot program, and, if it makes a specified determination, to design and implement a program of incentives for the installation of 200,000 solar water heating systems in homes and businesses throughout the state by 2017.
Renewable Energy and Energy Procurement
SB 1078. SB 1078 (Sher) (September 2002) established the Renewable Portfolio Standard program, which required an annual increase in renewable generation by the utilities equivalent to at least 1% of sales, with an aggregate goal of 20% by 2017. This goal was subseq uently accelerated, requiring utilities to obtain 20% of their power from renewable sources by 2010 (see SB 107, EO S-14-08, and EO S-21-09).
SB 1368. SB 1368 (September 2006), required the CEC to develop and adopt regulations for GHG emission performance standards for the long-term procurement of electricity by local publicly owned utilities. These standards must be consistent with the standards adopted by the California Public Utilities Commission.
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.
EO S-14-08. EO S-14-08 (November 2008) focused on the contribution of renewable energy sources to meet the electrical needs of California while reducing the GHG emissions from the electrical sector.
This EO required that all retail suppliers of electricity in Californ ia serve 33% of their load with renewable energy by 2020. Furthermore, the EO directed state agencies to take appropriate actions to facilitate reaching this target. The CNRA, through collaboration with the CEC and California Department of Fish and Wildlife, was directed to lead this effort.
EO S-21-09 and SBX1 -2. EO S -21-09 (September 2009) directed CARB to adopt a regulation consistent with the goal of EO S -14-08 by July 31, 2010. CARB was further directed to work with the California Public Utilities Commission and CEC to ensure that the regulation builds upon the Renewable Portfolio Standard program and was applicable to investor-owned utilities, publicly owned utilities, direct access providers, and community choice providers. Under this order, CARB was to give the highest priority to those renewable resources that provide the greatest environmental benefits with the least environmental costs and impacts on public health and can be developed the most quickly in support of reliable, efficient, cost -effective electricity system operations. On September 23, 2010, CARB initially approved regulations to implement a Renewable Electricity Standard . However, this
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regulation was not finalized because of subsequent legislation (SB X1 -2, Simitian, statutes of 2011) signed by Governor Brown in April 2011.
SB X1 2 expanded the Renewables Portfolio Standard by establishing a renewable energy target of 20% of the total electricity sold to retail customers in California per year by December 31, 2013, and 33% by December 31, 2020, and in subsequent years. Under the bill, a renewable electrical generation facility is one that uses biomass, solar thermal, photovoltaic, wind, geothermal, fuel cells using renewable fuels, small hydroelectric generation (30 megawatts or less), digester gas, municipal solid waste conversion, landfill gas, ocean wave, ocean thermal, or tidal current, and that meets other specified requirements with respect to its location.
SB X1-2 applies to all electricity retailers in the state including publicly owned utilities, investor-owned utilities, electricity service providers, and community choice aggregators. All of these entities must meet the renewable energy goals previously listed.
SB 350. SB 350 (October 2015, Clean Energy and Pollution Reduction Act) further expanded the Renewable Portfolio Standard by establishing a goal of 50% of the total electricity sold to retail customers in California per year by December 31, 2030. In addition, SB 350 included the goal to double the energy efficiency savings in electricity and natural gas final end uses (e.g., heating, cooling, lighting, or class of energy uses on which an energy-efficiency program is focused) of retail customers through ener gy conservation and efficiency. The bill also requires the California Public Utilities Commission, in consultation with the CEC, to establish efficiency targets for electrical and gas corporations consistent with this goal. Regarding mobile sources, as one of its elements, SB 350 establishes a statewide policy for widespread electrification of the transportation sector, recognizing that such electrification is required for achievement of the state’s 2030 and 2050 reduction targets (see California Public Utilities Code Section 740.12).
SB 100. SB 100 (2018) 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. This bill requires that the achievement of 100% zero -carbon e lectricity resources do not increase the carbon emissions elsewhere in the western grid and that the achievement not be achieved through resource shuffling.
SB 1020. SB 1020 (September 2022) revises the standards from SB 100, requiring the following percentage of retail sales of electricity to California end-use customers to come from eligible renewable energy resources and zero -carbon resources: 90% by December 31, 2035 , 95% by December 31, 2040, and 100% by December 31, 2045.
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Mobile Sources
State Vehicle Standards (AB 1493 and EO B-16-12). AB 1493 (July 2002) was enacted in a response to the transportation sector accounting for more than half of California’s CO 2 emissions. AB 1493 required CARB to set GHG emission standards for passenger vehicles, light -duty trucks, and other vehicles determined by the state board to be vehicles that are primarily used for noncommercial personal transportation in the state. The bill required that CARB set GHG emission standards for motor vehicles manufactured in 2009 and all subsequent model years. CARB adopted the standards in September 2004. EO B-16-12 (March 2012) required that state entities under the governor’s direction and control support and facilitate the rapid commercialization of zero -emissions vehicles. It ordered CARB, CEC, California Public Utilities Commission, and other relevant agencies to work with the Plug - in Electric Vehicle Collaborative and the California Fuel Cell Partnership to establish benchmarks to help achieve benchmark goals by 2015, 2020, and 2025. On a statewide basis, EO B -16-12 established a target reduction of GHG emissions from the transportation sector equaling 80% less than 1990 levels by 2050. This directive did not apply to vehicles that have special performance requirements necessary for the protection of the public safety and welfare. As explained under the “Federal Vehicle Standards” description above, EPA and NHTSA approved the SAFE Vehicles Rule Part One and Two, which revoked California’s authority to set its own GHG em issions standards and set ZEV mandates in California. However, in March 2022, EPA reinstated California’s authority under the Clean Air Act to implement its own GHG emission standards and ZEV sales mandate and found that the actions taken under the previous administration as a part of SAFE-1 were decided in error and are now entirely rescinded.
Heavy Duty Diesel. CARB adopted the final Heavy-Duty Truck and Bus Regulation, Title 13, Division 3, Chapter 1, Section 2025, on December 31, 2014, to reduce particulate matter and NOx emissions from heavy -duty diesel vehicles. The rule requires particulate matter filters be applied to newer heavier trucks and buses by January 1, 2012, with older vehicles required to comply by January 1, 2015. The rule will require nearly all diesel trucks and buses to be compliant with the 2010 model year engine requirement by January 1, 2023. CARB also adopted an Airborne Toxic Control Measure to limit idling of diese l-fueled commercial vehicles on December 12, 2013. This rule requires diesel -fueled vehicles with gross vehicle weights greater than 10,000 pounds to idle no more than 5 minutes at any location (13 CCR 2485).
EO S-1-07. EO S-1-07 (January 2007, implementing regulation adopted in April 2009) sets a declining Low Carbon Fuel Standard for GHG emissions measured in CO2e grams per unit of fuel energy sold in California. The target of the Low Carbon Fuel Standard is to reduce the carbon intensity of California passenger vehicle fuels by at least 10% by 2020 (17 CCR 95480 et seq.). The carbon intensity measures the amount of GHG emissions in the lifecycle of a fuel, including extraction/feedstock production, processing, transportation, and final consumption, per unit of energy delivered.
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SB 375 . SB 375 (Steinberg) (September 2008) addresses GHG emissions associated with the transportation sector through regional transportation and sustainability plans. SB 375 requires CARB to adopt regional GHG reduction targets for the automobile and light-truck sector for 2020 and 2035 and to update those targets every 8 years. SB 375 requires the state’s 18 regional metropolitan planning organizations to prepare a Sustainable Communities Strategy (SCS) as part of their Regional Transportation Plan (RTP) that will achieve the GHG reduction targets set by CARB. If a metropolitan planning organization is unable to devise an SCS to achieve the GHG reduction target, the metropolitan planning organization must prepare an Alternative Planning Strategy demonstrating how the GHG reduction target would be achieved through alternative development patterns, infrastructure, or additional transportation measures or policies.
A SCS does not (i) regulate the use of land; (ii) supersede the land use authority of cities and counties; or (iii) require that a city ’s or county’s land use policies and regulations, including those in a general plan, be consistent with it (California Government Code Section 65080[b][2][K]). Nonetheless, SB 375 makes regional and local planning agencies responsible for developing those strategies as part of the federally required metropolitan transportation planning process and the state -mandated housing element process.
In 2010, CARB adopted the SB 375 targets for the regional metropolitan planning organizations. The targets adopted for the San Diego Association of Governments (SANDAG) in 2010 are a 7% reduction in per-capita passenger-vehicle GHG emissions by 2020 and a 13% reduction by 2035, measured relative to 2005 GHG emissions. In 2018, CARB adopted the second round of SB 375 reduction targets, and increased SANDAG’s 2020 target to a 15% reduction in per-capita passenger-vehicle GHG emissions, and the 2035 target to a 19% reduction using the same 2005 baseline.
SANDAG completed and adopted its 2050 RTP/SCS in October 2011. In November 2011, CARB, by resolution, accepted SANDAG’s GHG emissions quantification analysis and determination that, if implemented, the SCS would achieve CARB’s 2020 and 2035 GHG emissions reduction targets for the region.
After SANDAG’s 2050 RTP/SCS was adopted, a lawsuit was filed by the Cleveland National Forest Foundation and others ( Cleveland National Forest Foundation v. San Diego Association of Governments [2017] 3 Cal. 5th 497). regarding analysis of EO S-3-05’s 2050 goal of an 80% reduction in GHG emissions from 1990 levels. The Supreme Court of California held that the Environmental Impact Report at issue was sufficient to inform the public, based on the information available at the time, about the regional plan’s GHG impacts and its potential inconsistency with state climate change goals without including an explicit analysis of the consistency of projected 2050 GHG emissions with the goals in the executive order.
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In 2015, SANDAG adopted the next iteration of its RTP/SCS in accordance with statutorily mandated timelines and no subsequent litigation challenge was filed. More specifically, in October 2015, SANDAG adopted San Diego Forward: The Regional Plan (Regional Plan) (SANDAG 2015). Like the 2050 RTP/SCS, San Diego Forward: Regional Plan meets CARB’s 2020 and 2035 reduction targets for the region (SANDAG 2015). In December 2015, CARB, by resolution, accepted SANDAG’s GHG emissions quantification analysis and deter mination that, if implemented, the SCS would achieve CARB’s 2020 and 2035 GHG emissions reduction targets for the region. The Regional Plan was updated in 2021, which was the result of years of planning, data analysis, and community engagement to reimagine the San Diego region with a transformative transportation system, a sustainable pattern of growth and development, and innovative demand and management strategies (SANDAG 2021).
Advanced Clean Cars Program and Zero-Emissions Vehicle Program. The Advanced Clean Cars (ACC) I program (January 2012) is an emissions -control program for model years 2015 through 2025. The program combines the control of smog- and soot-causing pollutants and GHG emissions into a single coordinated package of regulations: the low-emission vehicle regulation for criteria air pollutant and GHG emissions and a technology forcing regulation for ZEV s that contributes to both types of emission reductions (CARB 2021 b). The package includes elements to reduce smog-forming pollution, reduce GHG emissions, promote clean cars, and provide the fuels for clean cars. To improve air quality, CARB has implemented new emission standards to reduce smog -forming emissions beginning with 2015 model year vehicles. It is estimated that in 2025 cars will emit 75% less smog-forming pollution than the average new car sold in 2015. The ZEV program will act as the focused technology of the ACC I program by requiring manufacturers to produce increasing numbers of ZEVs and plug-in hybrid EVs in the 2018 to 2025 model years.
The ACC II program is currently in development to establish the next set of low-emission vehicle and ZEV requirements for model years after 2025 to contribute to meeting federal ambient air quality ozone standards and California’s carbon neutrality standards (CARB 2021b). The main objectives of ACC II are:
1. Maximize criteria and GHG emission reductions through increased stringency and real - world reductions.
2. Accelerate the transition to ZEVs through both increased stringency of requirements and associated actions to support wide-scale adoption and use.
The ACC II rulemaking package was adopted by CARB on August 25, 2022.
EO N -79-20. EO N-79-20 (September 2020) requires CARB to develop regulations as follows:
(1) Passenger vehicle and truck regulations requiring increasing volumes of new ZEVs sold in the state towards the target of 10 0% of in -state sales by 2035; (2) medium - and heavy -duty vehicle regulations requiring increasing volumes of new zero -emission trucks and buses sold and operated
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in the state towards the target of 100 % of the fleet transitioning to zero -emission vehicles by 2045 everywhere feasible and for all drayage trucks to be zero emission by 2035; and (3) strategies, in coordination with other state agencies, EPA and local air districts, to achieve 100 % zero-emission from off -road vehicles and equipment operations in the state by 2035. EO N-79-20 called for the development of a Zero -Emissions Vehicle Market Development Strategy, which was released February 2021, to be updated every 3 years, that ensures coordination and implementation of the EO and outlines actions to support new and used ZEV markets. In addition, the EO specifies identification of near -term actions, and investment strategies, to improve clean transportation, sustainable freight, and transit options; and calls for development of strategies, recommendations, and actions by July 15, 2021, to manage and exped ite the responsible closure and remediation of former oil extraction sites as the state transitions to a car bon-neutral economy.
Advanced Clean Trucks Regulation. The Advanced Clean Trucks Regulation was also approved by CARB in 2020. The purpose of the Advanced Clean Trucks Regulation is to accelerate the market for zero - emission vehicles in the medium - and heavy-duty truck sector and to reduce air pollutant emissions generated from on-road mobile sources (CARB 2021c). The regulation has two components including (1) a manufacturer sales requirement and (2) a reporting requirement:
1. Zero-emission truck sales: Manufacturers who certify Class 2b-8 chassis or complete vehicles with combustion engines will be required to sell zero -emission trucks as an increasing percentage of their annual California sales from 2024 to 2035. By 2035, zero -emission truck/chassis sales would need to be 55% of Class 2b-3 truck sales, 75% of Class 4–8 straight truck sales, and 40% of truck tractor sales.
2. Company and fleet reporting: Large employers including retailers, manufacturers, brokers and others will be required to report information about shipments and shuttle services. Fleet owners, with 50 or more trucks, will be required to report about their existing fleet operations. This information will help identify future strategies to ensure that fleets purchase available zero-emission trucks and place them in service where suitable to meet their needs.
Solid Waste
AB 939, AB 341, AB 1826, and SB 1383. In 1989, AB 939, known as the Integrated Waste Management Act (PRC 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 reduct ion of waste being disposed where jurisdictions were required to meet diversion goals of all solid waste through source reduction, recycling, and composting activities of 25% by 1995 and 50% by the year 2000.
AB 341 (Chapter 476, Statutes of 2011 [Chesbro]) amended the California Integrated Waste Management Act of 1989 to include a provision declaring that it is the policy goal of the state that not
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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 develop strategies to ach ieve the state’s policy goal. CalRecycle has conducted multiple workshops and published documents that identify priority strategies that it believes would assist the state in reaching the 75% goal by 2020.
AB 1826 (Chapter 727, Statutes of 2014, effective 2016) requires businesses to recycle their organic waste (i.e., food waste, green waste, landscape and pruning waste, nonhazardous wood waste, and food-soiled paper waste that is mixed in with food waste) depending on the amount of waste they generate per week. This law also requires local jurisdictions across the state to implement an organic waste recycling program to divert organic waste generated by businesses, including multifamily residential dwellings that consist of five or more units. The minimum threshold of organic waste generation by businesses decreases over time, which means an increasingly greater proportion of the commercial sector will be required to comply.
SB 1383 (2016) requires a 50% reduction in organic waste disposal from 2014 levels by 2020, and a 75% reduction by 2025—essentially requiring the diversion of up to 27 million tons of organic waste— to reduce GHG emissions. SB 1383 also requires that not less than 20% of edible food that is currently disposed be recovered for human consumption by 2025.
Water
EO B-29-15. In response to the ongoing drought in California, EO B -29-15 (April 2015) set a goal of achieving a statewide reduction in potable urban water usage of 25% relative to water use in 2013.
The term of the EO extended through February 28, 2016, although many of the directives have become permanent water-efficiency standards and requirements. The EO includes specific directives that set strict limits on water usage in the state. In response to EO B-29-15, the California Department of Water Resources has modified and adopted a revised version of the Model Water Efficient Landscape Ordinance that, among other changes, significantly increases the requirements for landscape water use efficiency and broadens its applicability to include new development pr ojects with smaller landscape areas.
EO B-37-16. Issued May 2016, EO B -37-16 direct ed the State Water Resources Control Board (SWRCB) to adjust emergency water conservation regulations through the end of January 2017 to reflect differing water supply conditions across the state. The SWRCB also developed a proposal to achieve a mandatory reduction of potable urban water usage that builds off the mandatory 25% reduction called for in EO B-29-15. The SWRCB and Department of Water Resources will develop new, permanent water use targets that build upon the existing state law requirements that the state achieve 20% reduction in urban water usage by 2020. EO B-37-16 also specifies that the SWRCB permanently prohibit water -wasting practices such as hosing off sidewalks, driveways, and other hardscapes;
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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 N-10-21. In response to a state of emergency due to severe drought conditions, EO N -10-21 (July 2021) called on all Californians to voluntarily reduce their water use by 15% from their 2020 levels. Actions suggested in EO N -10-21 include reducing landscape irrigation, running dishwashers and washing machines only when full, finding and fixing leaks, installing water-efficient showerheads, taking shorter showers, using a shut -off nozzle on hoses, and taking cars to commercial car washes that use recycled water.
Other State Regulations and Goals
SB 97. SB 97 (Dutton) (August 2007) directed the Governor’s Office of Planning and Research to develop guidelines under CEQA for the mitigation of GHG emissions. In 2008, the Governor’s Office of Planning and Research issued a technical advisory as interim guidance regarding the analysis of GHG emissions in CEQA documents. The advisory indicated that the lead agency should identify and estimate a project’s GHG emissions, including those associated with vehicular traffi c, energy consumption, water usage, and construction activities (OPR 2008). The advisory further recommended that the lead agency determine significance of the impacts and impose all mitigation measures necessary to reduce GHG emissions to a level that is less than significant. The CNRA adopted the CEQA Guidelines amendments in December 2009, which became effective in March 2010.
Under the amended Guidelines, a lead agency has the discretion to determine whether to use a quantitative or qualitative analysis or apply performance standards to determine the significance of GHG emissions resulting from a particular project (14 CCR 15064.4[a]). The Guidelines require a lead agency to consider the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]). The Guidelines also allow a lead agency to consider feasible means of mitigating the significant effects of GHG emissions, including reductions in emissions through the implementation of project features or off-site measures. The adopted amendments do not establish a GHG emission threshold, instead allowing a lead agency to develop, adopt, and apply its own thresholds of significance or those developed by other age ncies or experts. The CNRA also acknowledges that a lead agency may consider compliance with regulations or requirements implementing AB 32 in determining the significance of a project’s GHG emissions (CNRA 2009a).
With respect to GHG emissions, the CEQA Guidelines state in Section 15064.4(a) that lead agencies should “make a good faith effort, to the extent possible on scientific and factual data, to describe, calculate or estimate” GHG emissions. The CEQA Guideline s note that an agency may identify emissions by either selecting a “model or methodology” to quantify the emissions or by relying on
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“qualitative analysis or other performance -based standards” (14 CCR 15064.4 [a]).
Section 15064.4(b) states that the lead agency should consider the following when assessing the significance of impacts from GHG emissions on the environment: (1) the extent a project may increase or reduce GHG emissions as compared to the existing environmental s etting; (2) whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project; and (3) the extent to which the pr oject complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]).
EO S-13-08. EO S-13-08 (November 2008) is intended to hasten California’s response to the impacts of global climate change, particularly sea -level rise. Therefore, the EO directs state agencies to take specified actions to assess and plan for such impacts. The final 2 009 California Climate Adaptation Strategy report was issued in December 2009 (CNRA 2009b), and an update, Safeguarding California:
Reducing Climate Risk, followed in July 2014 (CNRA 2014). To assess the state’s vulnerability, the report summar izes key climate change impacts to the state for the following areas: Agriculture, Biodiversity and Habitat, Emergency Management, Energy, Forestry, Ocean and Coastal Ecosystems and Resources, Public Health, Transportation, and Water. Issuance of the Safeg uarding California:
Implementation Action Plans followed in March 2016 (CNRA 2016). In January 2018, the CNRA released the Safeguarding California Plan: 2018 Update, which communicates current and needed actions that state government should take to build climate change resiliency (CNRA 2018).
Local
San Diego County Air Pollution Control District
The San Diego County Air Pollution Control District does not have established GHG rules, regulations, or policies.
City of San Marcos
City of San Marcos Climate Action Plan
The City adopted its Climate Action Plan (CAP) on December 8, 2020 (City of San Marcos 2020). The CAP acts as a roadmap to address challenges of climate change within the City. The CAP builds on the efforts and strategies identified in the City’s 2013 CAP and establishes GHG emission reduction targets and identifies achievable, locally based actions to reduce GHG emissions from municipal and community activities. The CAP includes a baseline GHG emissions inventory for 2012, GHG emissions forecasts for 2020 and 2030, local GHG emissions reduction strategies and measures to help the City achieve th e 2030 target, climate adaptation measures for the City, and implementation and monitoring mechanisms to ensure the City’s measures and targets are achieved. The CAP established GHG emissions reduction goals of 4% below 2012 levels by 2020 and 42% below 2012 levels by 2030
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(City of San Marcos 2020). The CAP was prepared in accordance with the requirements within CEQA Guidelines Section 15183.5, and the CAP Consistency Checklist was u sed to evaluate the project’s significance with respect to GHG emissions.
City of San Marcos General Plan
The City’s General Plan (City of San Marcos 201 2) includes various policies related to reducing Air Quality and GHG emissions. Applicable policies include the following:
Land Use and Community Design Element
o Policy LU-2.1: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use. o Policy LU -2.3: Promote landscaping (e.g., native, drought tolerant plants) that minimizes demands on water supply.
o Policy LU-2.7: Promote the instillation of trees to reduce the urban heat -island effect and green infrastructure to reduce storm water runoff.
o Policy LU -3.1: Require that new development and redevelopment incorporate connections and reduce barriers between neighborhoods, transit corridors, and activity centers within the City.
Mobility Element
o Policy M-2.1: Work with new development to design roadways that minimize traffic volumes and/or speed, as appropriate within residential neighborhoods; while maintaining the City’s desire to provide connectivity on the roadway network.
Conservation and Open Space Element
o Policy COS -4.5: Encourage energy conservation and the use of alternative energy sources within the community.
o Policy COS-4.6: Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure and equipment.
o Policy COS -4.8: Encourage and support the generation, transmission and use of renewable energy.
o Policy COS-4.9: Encourage use and retrofitting of existing buildings under Title 24 of the California Building Energy Code.
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As detailed in response to Threshold #2 below, the project would be consistent with the applicable goals and policies pertaining to greenhouse gasses.
3.7.3 Thresholds of Significance
California has developed guidelines to address the significance of GHG emissions impacts that are contained in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). Appendix G provides that a project would have a significant environmental impact if it would:
• Threshold #1: Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.
• Threshold #2: Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases.
Global climate change is a cumulative impact; a project participates in this potential impact through its incremental contribution combined with the cumulative increase of all other sources of GHGs. There are currently no established thresholds for assessing whether the GHG emissions of a project, such as the project, would be considered a cumulatively considerable contribution to global climate change; however, all reasonable efforts should be made to minimize a project’s contribution to global climate change. In addition, while GHG impacts are recognized exclusively as cumulative impacts (CAPCOA 2008), GHG emissions impacts must also be evaluated on a project-level under CEQA.
The CEQA Guidelines do not prescribe specific methodologies for performing an assessment, do not establish specific thresholds of significance, and do not mandate specific mitigation measures.
Rather, the CEQA Guidelines emphasize the lead agency’s discret ion to determine the appropriate methodologies and thresholds of significance consistent with the manner in which other impact areas are handled in CEQA (CNRA 2009 a).
The City adopted the Final CAP on December 8, 2020. The CAP relies on a screening threshold and a CAP Consistency Checklist to determine whether a project’s emissions would be consistent with GHG emissions estimated within the City’s CAP. Projects that are consistent with the City’s CAP, as determined through the CAP Consistency Checklist, would result in a less-than-significant cumulative impact regarding GHG emissions. If a project is not consistent with the City’s CAP, as determined through the CAP Consistency Checklist, potentially significant cumulative GHG impacts would occur.
Approach and Methodology
Construction
CalEEMod Version 2020.4.0 was used to estimate potential project-generated GHG emissions during construction. Construction of the project would result in GHG emissions primarily associated with use
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of off-road construction equipment, on-road hauling and vendor (material delivery) trucks, and worker vehicles. Please see Appendix B for a detailed discussion of construction emissions calculation methodology and assumptions.
Operation
Emissions from the operational phase of the project were estimated using CalEEMod Version 2020.4.0 for mobile sources (vehicular traffic), energy sources (natural gas and electricity), area sources (landscaping equipment), solid waste, water supply and wastewater treatment, and off-road equipment (one CNG forklift). Please see Appendix B for detailed operational scenario assumptions for these sources .
Operational year 2025 was assumed as the first full year after completion of project construction.
Project Design Features
Project Design Features (PDFs) that are relevant to the GHG analysis are presented below. This impact analysis assumes that all PDFs would be implemented as conditions of approval, as defined below.
PDF-GHG-1 The project applicant will install a minimum of 9,700 square-feet of photovoltaic panels.
3.7.4 Project Impact Analysis
This section evaluates the GHG emissions impacts associated with the project. The significance criteria described in Section 3.7.3, Thresholds of Significance, were used to evaluate impacts associated with the construction and operation of the project.
Threshold #1: Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Threshold #2: Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Construction of the project would result in GHG emissions, which are primarily associated with the use of off-road construction equipment, haul trucks, on-road vendor trucks, and worker vehicles. CalEEMod was used to calculate the annual GHG emissions based on the construction scenario. On-site sources of GHG emissions include off-road equipment and off-site sources including trucks and worker vehicles.
CalEEMod was also used to estimate potential operational GHG emissions from area sources (landscaping equipment), energy sources (natural gas and electricity), mobile sources, solid waste, and water supply and wastewater treatment for the project. In addition, GHGs generated by a CNG forklift was estimated for the project. These emissions were quantified to determine the increase in GHGs from the project and are included below for disclosure and to provide a full understanding of the project’s potential contribution to climate change. However, as discussed in Section 3. 7.3, the
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significance thresholds are based on whether the project is consistent with the City’s CAP , which is also detailed below.
Construction and Operational GHG Emissions
Table 3.7-4 presents construction emissions for the project in 2023 and 2024 from on-site and off-site emission sources.
Table 3.7-4
Estimated Annual Construction Greenhouse Gas Emissions - Unmitigated Year
CO2 CH4 N2O CO2e
Metric Tons per Year
2023 180.99 0.02 0.01 185.35
2024 209.36 0.03 <0.01 211.56
Total 390.36 0.05 0.02 396.91
Amortized Construction Emissions Over 30-years 13.23
Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent; <0.01 = reported value less than 0.01.
See Appendix B for complete results. Totals may not add due to rounding.
As shown in Table 3.7-4, the estimated total GHG emissions during construction of would be approximately 397 MT CO2e over the construction period. Estimated project-generated construction emissions amortized over 30 years would be approximately 13 MT CO2e per year. As with project- generated construction criteria air pollutant emissions, GHG emissions generated during construction of the project would be short-term in nature, lasting only for the duration of the construction period, and would not represent a long-term source of GHG emissions. Amortized construction emissions were added to operational emissions of the project for this assessment.
Table 3.7-5 presents the increase in GHG emissions from the project.
Table 3.7-5
Estimated Annual Operational Greenhouse Gas Emissions
Emission Source
CO2 CH4 N2O CO2e
Metric Tons per Year
Area <0.01 <0.01 0.00 <0.01
Energy 38.21 <0.01 <0.01 38.38
Mobile 431.09 0.01 0.01 434.64
Off-Road 45.59 0.01 0.00 45.96
Solid waste 6.89 0.41 0.00 17.07
Water supply and wastewater 44.63 0.41 0.01 61.76
Total 559.52 0.84 0.02 597.81
Amortized Construction Emissions Over 30-Years 13.23
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Table 3.7-5
Estimated Annual Operational Greenhouse Gas Emissions
Emission Source
CO2 CH4 N2O CO2e
Metric Tons per Year
Project Operations + Amortized Construction Total 611.04 Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent; <0.01 = reported value less than 0.01.
See Appendix B for complete results. Totals may not add due to rounding.
The values shown are the annual emissions reflect ed in the CalEEMod “mitigated” output in order to account for implementation of PDF -GHG-1 ( photovoltaic panels) and consistency with regulations, specifically AB 939 (50% waste diversion) and CALGreen (low-flow fixtures requirement).
As shown in Table 3.7-5, the estimated GHG emissions from operation of the project would be approximately 611 MT CO2e per year, including amortized construction emissions.
City of San Marcos’ Climate Action Plan Consistency
This section evaluates the project’s impacts to GHG in accordance with the City’s 2020 CAP Consistency Checklist. A completed CAP Checklist is included as Appendix B. New discretionary development projects subject to CEQA review that are below the applicable screening size listed in the CAP Checklist would emit less than 500 MT CO 2e annually and would not contribute considerably to cumulative climate change impacts, and therefore, would be considered consistent with the CAP and associated emissions projections.
For projects that are subject to CAP consistency review, the next step in determining consistency is to assess the project’s consistency with the growth projections used in development of the CAP. This section allows the City to determine a project’s consistency with the land use assumptions used in the CAP.
Step 1
Question 1
Step 1 of the CAP Checklist determines land use consistency. Question 1 of Step 1 asks if a project would exceed a certain size. If the project is below the specified size, it is deemed consistent with the City’s CAP by emitting fewer than 500 MT CO2e per year and would be less than significant. The project exceeds the screening size of 58,000 square feet for General Light Industrial identified in the CAP Consistency Checklist and therefore would answer “Yes” to this question and must proceed to Question 2 of Step 1.
Question 2
Question 2 of Step 1 asks if the project is consistent with the existing General Plan land use designation. The project site is designated as Light Industrial (LI) in the City’s General Plan and is zoned
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Light Industrial (L-I). The project would be consistent with these designations. The project would answer “Yes” to Question 2 of Step 1 and can proceed to Step 2 of the Checklist.
Step 2
The second step of CAP consistency review is to evaluate a project’s consistency with the applicable strategies and measures of the CAP. Each checklist item is associated with a specific GHG reduction measure in the City’s CAP. “N/A” should only be checked based on the direction provided in each checklist item question. All projects for which the measure is applicable must demonstrate that the project would implement measures consistent with the checklist item, or fully substantiate how the item would be infeasible for project implementation. “N/A” responses are subject to Planning Division review and approval. If “No” is provided as a response to a question, the project would be determined to be inconsistent with the CAP and would result in a significant GHG impact.
Checklist Item 1. Electric Vehicle Charging Stations (Measure T-2) This checklist item applies to multi-family residential and non-residential projects. It asks if the project will install electric vehicle charging stations (Level 2 or better) in at least 5% of the total parking spaces provided on site.
The project would answer “Yes” to this question. By project design, there are four EV Level 2 charging stations and three additional EV ready spaces proposed in compliance with the 2022 CALGreen code at 10% of the total 72 space parking on site.
Checklist Item 2. Bicycle Infrastructure (Measure T-8)
This checklist item applies to residential and non-residential projects. It asks if the following conditions are met, would the project pay its fair-share contribution to bicycle infrastructure improvements of the following:
• Intersection or roadway segment improvements are proposed as part of the project. • The City’s General Plan Mobility Element identifies bicycle infrastructure improvements at any intersection(s) or roadway segment(s) that would be improved as part of the project.
The project would answer “N/A” to this checklist question. According to the General Plan, Pacific Street is not a Mobility Element roadway, nor does it call for bike infrastructure in this roadway segment.
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Checklist Item 3. Transportation Demand Management (Measure T-9) This checklist item applies to residential and non -residential projects. Will the project develop and implement a Transportation Demand Management (TDM) Plan that includes, at a minimum, all of the TDM strategies listed below?
• Provide discounted monthly transit pass or provide at least 25 % transit fare subsidy to residents/employees.
• Provide designated car-share, carpool, vanpool, and/or park-and-ride parking spaces. • Provide pedestrian connections between all internal uses and to all existing or planned external streets around the project site(s).
• Provide secure bicycle parking spaces or bicycle racks, showers, and clothes lockers. • Encourage telecommuting for employees (allow one telecommute day per week or compressed work weeks) or provide a telecommute work center with common office space and equipment available to residents.
-or
• Would the project implement and monitor for 4 years a TDM program that demonstrates an alternative transportation (i.e. carpool, public transit, bicycle, walk, telecommute) mode share of at least 29% for all residents?
The project would answer “Yes” to this checklist question. The project would comply with all feasible and appropriate TDM strategies as indicated in Appendix B; however, as a light industrial facility on a 2-shift/5-day per week schedule, employees are not able to work remotely. Additionally, transit routes are limited in relation to the workforce, especially with late night shiftwork , but transit passes will be offered as part of the TDM program. Based on the preceding considerations, this measure would not apply in its entirety to the project.
Checklist Item 4. Reduce Parking Near Transit (Measure T-12) This checklist item applies to multi-family residential projects. If located within one-half mile of a major transit stop, would the project provide at least 27% fewer parking spaces than required for the same use based on the City’s municipal code parking requirements? The project would answer “N/A” this checklist item. As an industrial facility, this measure would not apply to the project.
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Checklist Item 5. Water Heaters (Measure E-1)
This checklist item applies to residential projects and asks if the project would install one of, or a combination of, the following water heater types in place of natural gas water heaters:
• Electric heat pump water heater
• Instantaneous electric water heater
• Electric tank
• Solar water heater with heat pump water heater backup • Solar water heater with electric tank backup
The project would answer “N/A” this checklist item. As an industrial facility, this measure would not apply to the project.
Checklist Item 6. Photovoltaic Installation (Measure E-2) This checklist item applies to non-residential projects and asks if the project would install photovoltaic systems with a minimum capacity of two watts per square foot of gross floor area? The project would answer “Yes” to this checklist item. The project will install a photovoltaic system to meet the City’s requirement.
Checklist Item 7. Landscaping Water Use (Measure W-1)
This checklist item applies to residential and non -residential projects and asks if the project would comply with the City’s Water Efficient Landscape Ordinance.
The project would answer “Yes” to this checklist item. As identified in the landscape plans, the project design will comply with the City’s Water Efficient Landscape Ordinance.
Checklist Item 8. Urban Tree Canopy (Measure C-2)
This checklist item applies to residential and non-residential projects and asks if the project is providing more than 10 parking spaces, will the project plant at least one tree per five parking spaces provided? The project would answer “Yes” to this checklist item. As identified in the landscape plans, the project would design meets the requirement of at least one tree per five parking spaces and would provide a total of 59 trees across the site.
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Summary
The project was shown to implement all applicable checklist items within the City’s CAP. Therefore, the project would be consistent with the City’s CAP, and impacts to GHG emissions would be less than significant.
Consistency with Other Plans and Regulations
Numerous plans, policies, and regulations have been adopted for the purpose of reducing GHG emissions. The principal overall state plan and policy are AB 32, SB 32, and AB 1279. The quantitative goal of AB 32 is to reduce GHG emissions to 1990 levels by 2020 and the goal of SB 32 is to reduce GHG emissions to 40% below 1990 levels by 2030. AB 1279 requires GHG emissions be reduced to 85% below 1990 levels by 2045 and that the state achieve net zero GHG emissions by no later than 2045 and achieve and maintain net negative GHG emissions thereafter. The City’s CAP outlines the measures for the City to achieve its share of state GHG reductions. As discussed above, the project would be consistent with the CAP and, therefore, would be consistent with state GHG reduction goals.
At the regional level, the SANDAG’s RTP/SCS has been adopted for the purpose of reducing GHG emissions attributable to passenger vehicles in the San Diego region. In October 2015, SANDAG adopted its Regional Plan, which was subsequently updated in 2021. The RTP/SCS is not directly applicable to the project because the underlying purpose of the RTP/SCS is to provide direction and guidance on future regional growth (i.e., the location of new residential and nonresidential land uses) and transportation patterns throughout the City and greater San Diego County, as stipulated under SB 375.
CARB has recognized that the approved RTP/SCS is consistent with SB 375. The SANDAG Regional Plan is generally consistent with the local government plans. As described in Section 3.12, Population and Housing, the City of San Marcos is forecasted to grow from 94,258 persons and 41,096 employees in 2016 to 119,098 persons and 63,031 employees in 2050, which is a population and employment increase of 24,840 and 21,935, respectively (SANDAG 2021). As such, the project-related increase of approximately 60 employees would represent a nominal percentage of the City’s projected future population and employees. Since the project is within the scope of development that was anticipated in the General Plan, it would not result in growth that would conflict with the Regional Plan.
Based on the preceding considerations, the project would not conflict with an applicable plan adopted for the purpose of reducing GHG emissions, or generate GHG emissions that would have a significant impact on the environment; therefore, the project’s impacts on GHG emissions would be less than significant.
3.7.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects that, when considered together, are considerable or that 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: (1) a list of past, present, and
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probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regional, or statewide plan, or a 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, Project Impact Analysis, 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 CNRA 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 2009a). The Resources Agency similarly advised that an environmental document must analyze the incremental contribution of a project to GHG levels and determine whether those emissions are cumulatively considerable (CNRA 2009 b). 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.”
3.7.6 Mitigation Measures
The project would not result in significant impacts; therefore, no mitigation is required.
3.7.7 Conclusion
As presented in Section 3.7.4 above, 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 strategies of the state, 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, and no mitigation is required.
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3.8 Hazards and Hazardous Materials
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3.8 HAZARDS AND HAZARDOUS MATERIALS
This section describes the existing hazards and hazardous materials within the vicinity of the proposed Hughes Circuits Project (project), identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the project.
Table 3.8-1, Hazards and Hazardous Materials Summary of Impacts, 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
#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
#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
#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
#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
#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
#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
#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 project site is undeveloped and predominantly contains grasses and vegetation.
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Modern debris (e.g., refuse) is strewn throughout the project site and a homeless encampment was observed in the bushes on the northwestern portion of the project site.
Hazardous materials include solids, liquids, or gaseous materials that, because of their quantity, concentration, or physical, chemical, or infectious characteristics, could pose a threat to human health or the environment. Hazards with all existing development or construction of development include the risks associated with potential explosions, fires, or release of hazardous substances in the event of an accident or natural disaster, which may cause or contribute to an increase in mortality or serious illness or pose substantial harm to human health or the environment.
The 10.46-acre project site is an undeveloped lot located in the western portion of San Marcos in an urbanized area. The project site is located in an area largely characterized by retail/commercial and industrial facilities, with Bradley Park located across from the site’s western border. The project site is bounded by numerous industrial facilities to the north , South Pacific Street and Bradley Park to the west, undeveloped land and a Chevron gas station to the east, and South Pacific Street and the current Hughes Circuit buildings to the south.
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 obstructions 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 Federal Aviation Regulations. The notification of proposed development enables the FAA to do the following:
• 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
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• Provide recommendations for identifying the construction or alteration in accordance with current FAA Advisory Circular AC 70/7460-1K dated August 1, 2000, Obstruction Marking and Lighting • 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 of San Marcos is one of the communities covered by the County of San Diego Multi -Jurisdictional Hazard Mitigation Plan, described below, which 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 are 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 system 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.
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Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA) gives the United States Environmental Protection Agency (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 the EPA to address environmental problems that could result from underground tanks storing petroleum and other hazardous substances.
Hazardous and Solid Waste Amendments of 1984
The Hazardous and Solid Waste Amendments of 1984 Amends the Solid Waste Disposal Act (as amended by the Resource Conservation and Recovery Act of 1976) to authorize appropriations for fiscal year 1985 through 1988 for (1) general administration by the Administrator of the 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); (2) grants to state hazardous waste programs; (3) the hazardous waste site inventory; (4) development and implementation of plans by state, local, regional, and interstate authorities; (5) implementation of state, local, and intermunicipal programs for solid waste management, resource recovery, resource conservation, and hazardous waste management; (6) special communities assistance; (7) assistance to states for recycled oil programs; (8) the Secretary of Commerce to carry out resource and recovery duties; (9) additional EPA officers or employees to conduct criminal investigations under such Act and for support costs for such additional criminal investigators; (10) underground storage tank regulation; (11) grants to states for state underground storage tank release detection, prevention, and correction programs; (12) small quantity generator waste education programs; (13) state and other programs requiring compliance with open dumping/sanitary landfill criteria by solid waste management facilities within 36 months after ena ctment of this Act; and (14) 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 Su bstance Control, the State Water Resources Control Board, and the Integrated Waste Management Act also regulate the generation of hazardous materials, also described below.
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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.
California Fire Code
The California Fire Code (CFC) is Chapter 9 of Title 24 of the California Code of Regulations. The Code 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 California Building Code use a hazard classification system to determine what protective measures a re required to protect 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 classificat ion. The CFC is updated every 3 years. The San Marcos Fire Department (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 Health and Safety Code, Chapter 6.95, the California Department of Environmental Health implements the Hazardous Materials Business Plan program and the California Accidental Release Program in San Diego County. The Hazardous Materials Business Plan and California Accidental Release Program programs provide threshold quantities for regulated hazardous substances.
When the indicated quantities are exceeded, a Hazardous Materials Business Plan 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 the EPA’s Envirofacts Data Warehouse.
California Integrated Waste Management Act
This act requires the development and implementation of household hazardous waste disposal plans.
The Department of Resources Recycling and Recovery (CalRecycle), 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
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coordinates the responses of other agencies, including the California EPA, California Highway Patrol, the California Department of Fish and Wildlife, and the Regional Water Quality Control Board.
Emergency Services Act
Under the Emergency Services Act (California Government Code Section 8850 et seq.), the state 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 Emergency Services administers the plan, coordinating the responses of other agencies, including EPA, California Highway Patrol, Regional Water Quality Control Boards, air quality management districts, and county disaster response offices.
Government Code Section 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 Sec tion 65962.5 requires the California EPA to develop an updated Cortese List annually, at minimum. The Department of Toxic Substance Control is responsible for a portion of the information contained in the Cortese List. Other California state and local gove rnment 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 s uch wastes. Under these regulations, the generator of hazardous waste material must complete a manifest 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 Substance Control.
Unified Program
The California EPA delegates to qualifying local agencies 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
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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) • California Accidental Release Prevention Program (CalARP) • Underground Storage Tank 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 • California Uniform Fire Code: Hazardous material management plans and hazardous material inventory statements
The County of San Diego (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 purpose of establishing minimum wildfire protection standards in conjunction with building, construct ion, 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; prepare and adopt airport land use 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 Regional 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 located within the McClellan-Palomar Airport Influence Review Area 2 (San Diego County Regional Airport Authority 2011). The influence area is
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regulated by the Airport Land Use Commission, which regulates land uses in the area to be compatible with airport -related noise, safety, airspace protection, and over -flight factors through review of development proposals within the airport influence area. Review Area 2 consists of limits on heights of structures in areas of high terrain. Residential development in Review Area 2 may be subject to annoyances commonly associated with proximity to airports, such as noise, vibration, and overflights.
County of San Diego Multi-Jurisdictional Hazard Mitigation Plan To comply with the Disaster Mitigation Act of 2000, the County of San Diego prepared the Multi - Jurisdictional Hazard Mitigation Plan. The plan serves as both a county-wide 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 objectives 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 of San Marcos (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 of San Diego, California Department of Forestry and Fire Protection and the United States Forest Service. The Community Wildfire Protection Plan supplements San Diego 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 wildfir e 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 Municipal Code to adopt the most recent version of the California Fire Code. This ordinance also requires all buildings or structures to provide and maintain an effective fuel modification zone of 150 feet.
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City of San Marcos General Plan
Safety Element
The Safety Element of the San Marcos General Plan 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 result ing from structure or wildland fire hazards.
o 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. o 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.
o 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. o 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.
o 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.
o 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. o 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. o 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.
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• 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. o 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. o 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 [Airport Land Use Compatibility Plan].
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 overall goals and policies of the General Plan pertaining to hazards and hazardous materials.
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 California Environmental Quality Act ( 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 #1: Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.
• Threshold #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 #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 #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 result, would i t create a significant hazard to the public or the environment.
• Threshold #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 #6: Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.
• Threshold #7: Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires.
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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 #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 limited 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 m aterials from construction equipment could occur with the transport, use, or disposal of these materials. However, existing federal and state standards listed in Section 3.8.2, Regulatory Setting, related to the handling, storage, and transport of these materials would be implemented during construction of the project.
The project would involve the operation and maintenance of a new light industrial building. Operation of the project would likely involve the use of industrial -grade chemicals used in the day -to-day operation of the facilities as well as commercially available cleaning products, landscaping chemicals and fertilizers, and various other c ommercially available products. While these materials could be stored on the project site, storage would be required to comply with the guidelines established by the manufacturer’s recommendations. Existing operations of Hughes Circuits Inc. adjacent to the project site conducts PCB fabrication and has a permit to discharge pretreated industrial wastewater . This operation would not be conducted in the new proposed building; only assembly would occur under project operation. Assembly does not generate any hazardous waste.
Consistent with federal, state, and local requirements, the transport, removal, and disposal of hazardous materials from the project site would be conducted by a permitted and licensed service provider. Any handling, transport, use, or disposal must comply with all applicable federal, state, and local agencies and regulations.
The project’s compliance with all standards required through federal, state, county, and municipal regulations, in addition to project-specific plans 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 of the project would be less than significant.
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Threshold #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 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, and lubricant oils. 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 involve the operation and maintenance of a new light industrial building. Operation of the project would likely involve the use of industrial-grade chemicals used in the day-to-day operation of the facilities as well as commercially available cleaning products, landscaping chemicals and fertilizers, and various other commercially available products. While these materials could be stored on the project site, storage would be required to comply with the guidelines established by the manufact urer’s recommendations. Consistent with federal, state, and local requirements, the transport, removal, and disposal of hazardous materials from the project site would be conducted by a permitted and licensed service provider. Any handling, transport, use, or disposal must comply with all applicable federal, state, and local agencies and regulations. Therefore, impacts would be less than significant.
Threshold #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 propos ed school. The closest school to the project site is High Tech Elementary North County , located approximately 0. 1 miles south of the project site. However, as previously stated, the project’s compliance with all standards required through federal, state, county, and municipal regulations, in addition to project-specific plans 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. Additionally, the project would support the expansion of the existing operations of Hughes Circuits Inc., located adjacent to the project site to the south. As described above, existing operations of Hughes Circuits Inc., adjacent to the site conducts PCB fabrication and has a permit to discharge pretreated industrial wastewater, this operation would not be conducted in the new proposed building; only assembly would occur under project operation, and assembly does not generate any hazardous waste.
As such, the project would be consistent with the surrounding industrial uses as well as the current industrial use zoning designation for the project site. Therefore, project impacts would be less than significant.
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Threshold #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 result, would i t create a significant hazard to the public or the environment?
The Hazardous Waste and Substances Sites (Cortese List) is a planning document providing information about the location of hazardous materials release sites. California Government Code Section 65962.5 requires the California Environmental Protection Agency to develop, at least annually, an updated Cortese List. The Department of Toxic Substances Control is responsible for a portion of the information contained in the Cortese List. Other state and local government agencies are required to provide additional hazardous materials release information for the Cortese List (CalEPA 2022). The project site is not located on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5 (DTSC 2022; RWQCB 2022 ). The closest hazardous materials site is located approximately 63 feet south of the project site and is considered a Tiered Permit site (71003390) (DTSC 2022). This site has not been evaluated and no potential contaminants of concern have been identified. Therefore, this impact would be less than significant.
Threshold #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 McClellan-Palomar Airport, which is located approximately
3.9 miles west of the project site. The project site is located within the McClellan -Palomar Airport Influence, Review Area 2 (San Diego County Regional Airport Authority 2011). Per the McClellan - Palomar Airport Land Use Compatibility Plan, limits on the heights of structures, particularly in areas of high terrain, are the only restrictions on land uses within Review Area 2. The project site would not be characterized as an area of high terrain, defined as a maximum height of 795 feet amsl or as in an area of Terrain Penetration to Airspace Surfaces. The project site is characterized by undeveloped terrain and is relatively flat. Elevation ranges from approximately 520 feet above mean sea level in the eastern portion of the project site to 535 feet above mean sea level in the northwest portion of the project site. The proposed building would be a maximum of 43 feet high. The height and density of the project would be consistent with the existing surrounding development. Therefore, this impact would be less than significant.
Threshold #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 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).
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The project would be required to abide by the standards set forth in the San Marcos Emergency Operations Plan. 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 adopted emergency response plan or emergency evacuation plan. As required under the California Fire Code, the project would be required to present development plans that afford fire and emergency responders suitable fire access roads dimensions and surfaces (Chapter 5, Section 503.1 through Section 503.4 of the California Fire Code), an adequate number of emergency rated entrances to the community (Appendix D, Section D106 of the California Fire Code), and entryway gate access for first responders (Chapter 5 of the California Fire Code, Section 503.6).
The proposed point of entry 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 Section 3.13, Public Services, of this environmental impact report, the Fire Response Technical Memorandum prepared for the project (Appendix H) determined that SMFD would arrive at the project site between 3:37 - and 3:50-minute travel time (6:07- to 6:40-minute total response time). This results in up to 53 seconds to drive within the project site to the most remote unit, which is achievable based on the project site’s roads and smaller overall size.
Therefore, it is determined that i mpacts related to emergency response or emergency evacuation as a result of the project would be less than significant.
Threshold # 7: Would the project expose people or structures , either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? 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 near lands classified as very high fire hazards severity zones according to the California Department of Forestry and Fire Protection (CAL FIRE) (CAL FIRE 202 2). The project site is an undeveloped lot that is relatively flat and shows signs of previous disturbance. The project would be required to comply with all applicable sta te and local fire codes, including compliance with the California Fire Code and the SMFD, which require a design that affords fire and emergency responders suitable fire access roads dimensions and surfaces (Chapter 5, Section 503.1 through 503.4 of the California Fire Code). Furthermore, as determined in the Fire Response Technical Memorandum prepared for the project (Appendix H), SMFD’s existing Station 2 would adequately serve the project site while maintaining SMFD’s response goals.
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.
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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, a ny 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 in Section 3.8.4, Project Impact Analysis, above, 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 all 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.
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3.9 Hydrology and Water Quality
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3.9 HYDROLOGY AND WATER QUALITY
This section describes the existing hydrology and water quality of the proposed Hughes Circuits Project (project), identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the project.
The analysis in this section relies on the following reports prepared for the project:
• Hydrology Study, prepared by Excel Engineering, June 3, 2022 (included as Appendix F-1 to this environmental impact report [EIR]).
• Storm Water Quality Management Plan, prepared by Excel Engineering, November 13, 2023 (included as Appendix F-2 to this EIR).
• Preliminary Geotechnical Investigation, prepared by Geocon Inc, October 1, 2021 (included as Appendix E to this EIR).
Table 3.9 -1, Hydrology and Water Quality Summary of Impacts, 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
#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
#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
#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
#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
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Table 3.9-1
Hydrology and Water Quality Summary of Impacts
Threshold of Significance
Project-Level
Impact
Cumulative-Level
Impact
Significance
Determination
#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
#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
#7: In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation.
No Impact No Impact No Impact
#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 north east corner of South Pacific Street in the city of San Marcos, San Diego County, California. The project site is currently undeveloped and consists of sparse to dense vegetation with drainage conveyance. Total change in elevation across the site is approximately 8 feet, with surface drainage directed toward the southern edge of the property. The project site is relatively flat, with elevations on site rang ing from approximately 524 feet to 5 32 feet above mean sea level (amsl) (Appendix E).
Water arrives on site via natural rainfall and off-site runoff. The majority of the existing off-site surface slopes generally from the north to the south. When the water reaches South Pacific Street along the west border of the project site, it flows into the existing dual 48-inch-diameter pipes then flow through vacant property before entering the project area . When water reaches the north edge of the project site, it flows along the slope until it reaches the point of connection (POC) at the southern edge of the
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property at South Pacific Street (Appendix F-1). The project site is located in Zone X of the Flood Insurance Rate Map (FIRM) Panel 06073C0789H. Zone X is designated to be areas determined to be outside the 500-year floodplain (FEMA 2012).
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 904.52), within the San Marcos Hydrologic Area (HA 904.52) which is part of the Carlsbad Watershed (Hydrologic Unit 904.00) (RWQCB 2022). The Carlsbad Hydrologic Unit (904.00) is a triangular area covering approximately 210 square miles (SW RCB 2002). This hydrologic unit is bordered by San Luis Rey Hydrologic Unit to the north and San Dieguito Hydrologic Unit to the east and south. The Carlsbad Hydrologic Unit 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 Hydrologic Unit is separated into four primary sub-watersheds 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 sub-watershed areas is further refined by eight creek system branches by hydrographic subareas (HSAs) (City of San Marcos 2012a).
The protection of watersheds and water quality is a prominent concern for the City of San Marcos (City) because 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 Management Plans in coordination with the San Diego RWQCB Region 9 for nutrients and bacteria 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 a Basin Plan that outlines beneficial uses and water quality objectives that are protective of the beneficial uses for each of the HSA areas in the General Plan area.
In addition, the S an Diego RWQCB has adopted Order R9 -2007-0001, the San Diego Municipal Stormwater Permit, the Bacteria I Order total maximum daily load (TMDL), and is providing oversight with a stakeholder -driven nutrient TMDL for Upper San Marcos Creek (HSA 904.52 and 904.53) to address the impairments in San Marcos Creek and Lake San Marcos. The City is the lead agency for the Upper San Marcos Creek nutrient TMDL. The City of San Marcos regionally and locally implements the requirements of Order R9 -2007-0001. This includes best management practice inspection programs for businesses, municipal facilities, and treatment control facilities; preventative programs such as street sweeping and storm drain facility cleaning; monitoring water quality within the City of San Marcos; and integrating site design, source co ntrol, low -impact development (LID), treatment
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controls, and hydromodification design for City projects and private development and redevelopment to reduce polluted storm water from 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 Investigation prepared for the project (Appendix E), groundwater was encountered between 4 and 10 feet below existing grade. The use of dewatering techniques may be necessary if excavations below the groundwater elevation occur.
The San Diego RWQCB Basin Plan identifies beneficial uses for groundwater in the four primary subwatersheds as municipal, agricultural, and industrial uses. The City of San Marcos is located in the California Department of Water Resources (DWR) South Coast Hydrologic Region. DWR Bulletin 118 identifies the San Marcos Area as Basin 9 -32. The DWR San Marcos Area is 2,129 acres. This groundwater basin is located entirely within San Marcos Creek HSA 904.52, which i s designated as impaired and has a hydrologic connection to Lake San Marcos. Other minor groundwater basins and wells are located throughout the San Marcos General Plan area outside of Basin 9 -32; however, the DWR Basin 9-32 is the only groundwater basin formally designated in the General Plan Area.
Protection of the groundwater beneficial uses identified in the Basin Plan through the implementation of watershed protection programs in the City 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.
Federal
Federal Emergency Management Agency
The 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
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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). The project site is not 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 into the waters of the United States and regulating quality standards for surface waters. The basis of the CWA was enacted in 1948 and was called the Federal Water Pollution Control Act, but the Act was significantly reorganized and expanded in 1972. “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 m ade 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 safet y. The TMDL must also include an analysis that shows the linkage between loading reductions and the attainment of water quality objectives. The EPA must either approve a TMDL prepared by the state or, if it disapproves the state’s TMDL, issue its own. Nati onal Pollutant Discharge Elimination System permit limits for listed pollutants must be consistent with the waste load allocation prescribed in the TMDL. After implementation of the 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 Pollutant Discharge Elimination System
The National Pollutant Discharge Elimination System (NPDES) permit system was established in the federal CWA to regulate municipal and industrial discharges to surface waters of the U nited States.
Sections 401 and 402 of the CWA contain general requirements regarding NPDES permits.
Section 307 of the CWA describes the factors that the federal EPA must consider in setting effluent limits for priority pollutants.
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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. However, three types of nonpoint source discharges are controlled by the NPDES program: nonpoint source discharge caused by general construction activities, the general quality of storm water in municipal storm water systems, and discharges associated with industrial operations. The 1987 amendments to the CWA directed the federal 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 the 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 best management practices (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 SWPPPs 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 syste m or surface water; developing and implementing 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 the state water resources including groundwater and surface water. The SWRCB and RWQCBs 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 ground and surface water quality objectives.
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State Water Resources 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 Department 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 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, 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 reduce pollutants in storm water 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 Hydrologic Subarea within the San Marcos Hydrologic Area, which is part of the Carlsbad Watershed. The Water Quality Control Plan for the San Diego Basin (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 bodies in the area . Because the City of San Marcos is located within the R WQCB’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 permit for 39 municipal, county government, and special district entities located in southern Orange County, southwestern Riverside County, and San Diego County who own and operate large municipal separate storm sewer systems (MS4s) that discharge storm water runoff and non-stormwater runoff to surface waters throughout the San Diego Region. This permit has requirements for development projects to
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minimize or eliminate the impacts of such development on water quality. The project is subject to the requirements of the municipal 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 waters. 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 previous Orders and pursuant to the approved Hydromodification Management Plan (January 2011). The City of San Marcos is one of the co-permittees.
To comply with Order R9-2013-0001, as amended, the February 2016 Model BMP Design Manual – San Diego Region (BMP Design Manual) was developed to provide County-specific project design and post-construction storm water requirements for development projects and replace the prior San Diego Regional Model Standard Urban Stormwater Mitigation Plan. The BMP Design Manual was used to recommend BMPs and LID features for the project. LID is an approach to land development that uses multiple small-scale natural deten tion and filtration features to manage storm water 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 storm water as a resource rather than a waste product.
Local
Carlsbad Watershed Management Area Water Quality Improvement Plan On May 8, 2013, the San Diego RWQCB 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 Quality 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 Area are identified, and strategies are implemented through the Responsible Agencies ’ Jurisdictional Runoff Management Programs to progressively improve water quality. The plans contain an adaptive planning and management process and a public participation component. The Carlsbad Management Area Water WQIP was prepared in June 2016 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. The 2021 update of the WQIP was submitted to the Regional Board in September 2021 and was accepted by the Regional Board in December 2021 (Carlsbad Watershed Management Area Responsible Agencies 2021).
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San Marcos Storm Water Standards
The City has adopted the use of the 2020 Model 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 Open Space Element
The following are applicable goals and policies from the City of San Marcos General, Conservation and Open Space Element related to hydrology and water quality (City of San Marcos 2012a):
• 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 sub watersheds.
o 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. o 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 City of San Marcos General Plan, Safety Element 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. o Policy S-2.2: Require existing private development to take responsibility for maintenance and repair of structures to resist flood damage.
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Land Use and Community Design Element
The following goal and policies in the City of San Marcos General Plan, Land Use and Community Design Element are applicable to storm water 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.
o Policy LU-15.1: Implement activities, practices, procedures, or facilities that avoid, prevent, or reduce pollution of the San Marcos Storm Water Conveyance System and receiving waters. o Policy LU-15.2: Improve inadequate or undersized drainage/flood control facilities to solve both small neighborhood and large regional drainage and flood control problems. o Policy LU-15.3: Avoid, to the extent possible, development in floodplain and flood prone areas. o Policy LU-15.4: Retain drainage courses in their natural condition, to the extent possible.
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 storm water pollution prevention requirements. These storm water 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 California Environmental Quality Act (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 #1: Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. • Threshold #2: Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin.
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• Threshold #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. • Threshold #4: 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 manner which would result in flooding on- or offsite. • Threshold #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 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 #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 # 7: In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.
• Threshold #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 #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, fuels, oils, lubricants, and other hazardous substances used during construction could be rele ased and potentially impact water quality.
The project would be required to comply with the NPDES SWRCB Construction General Permit Order No. 2009 -0009-DWQ for storm water discharges and general construction activities, and would incorporate standard BMPs , such as regular cleaning or sweeping of construction areas and impervious areas, and various storm water 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
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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 storm water 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 F-2).
The proposed biofiltration features on site would be subject to regular inspection and maintenance.
The property owner is required, pursuant to the City’s Municipal Code Section 14.15 and the BMP Design Manual, to enter into a storm water management and discharge control maintenance agreement for 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, operation of the project would likely involve the use of industrial -grade chemicals used in the day -to-day operation of the facilities as well as commercially available cleaning products, landscaping chemicals and fertilizers, and various other commercially available products. Operation of the project is not expected to include such uses that would violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality.
The implementation of biofiltration, source control, 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 or ground water quality. I mpacts are expected to be less than significant.
Threshold #2: Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
As discussed above, groundwater was encountered between 4 and 10 feet below existing grade. The use of dewatering techniques may be necessary if excavations below the groundwater elevation occur.
As described in response to Threshold #1, the project would treat storm water runoff through the use of biofiltration basins. All storm water would 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 e ventually reach groundwater. As the project would use biofiltration and BMPs that would effectively treat storm water 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 receiving 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, who in turn, receives its water from the Metropolitan Water District
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of Southern California. The Metropolitan Water District of Southern California obtains water from 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 2021). As the project would not use groundwater for construction or operation, and would not interfere with infiltration and groundwater recharge , 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 would be less than significant.
Threshold #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 is currently a vacant lot and has no existing impervious areas. However, project implementation would introduce new impervious areas and include on-site drainage systems which would alter the existing drainage pattern on the project site.
The project proposes to build a building, parking and landscape areas. The proposed parking slopes to the project’s biofiltration basin (BMP -A) at 0.5%. To decrease impervious area on the site, the parking stalls would be installed with pervious concrete. The proposed building would discharge roof water into BMP-A, and BMP-B. After all storm water from parking lot and roof get collected and treated in BMP-A and BMP-B, it would flow into the 48-inch storage tank, which would be located at the north and east edge of the project site. This storage tank would be used for detaining post -developed on- site water. At the end of the storage tank, a weir plate with two orifices would be used for regulating low flow. Each of the proposed biofiltration basins would have an emergency spillway that ultimately allow water to go to the street.
A 24 -inch-diameter pipe would connect the storage tank with two proposed new 66 -inch culverts.
These two new 66 -inch-diameter culverts would run from the north to the south and meet with the existing two 66 -inch culverts at South Pacific Street. These two 66 -inch culverts would route storm water through the site and finally collect into the POC at South Pacific Street. At the west and south edge of the project site, there would be approximately 0.5 acres that include pervious and landscaped slope that would not flow to the basins. This section would drain surface water from the north to the south and collect in an existing 18-inch storm drain pipe which would tie to an existing 27-inch storm drain to the POC.
At the south side of the project site, BMP -C would be located within a modular wetland system to convey storm water from north to south. The proposed 18 -inch outlet pipe of the modular wetland would connect with the existing 18-inch reinforced concrete pipe. Storm water would drain southernly
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to the modular wetland system and get treated, then would drain into the existing 18-inch storm drain pipe to the POC.
At the southeast corner of the project site, a dispersion area would be located to route surface runoff from impervious street area to the adjacent pervious area. This is to slow surface runoff and reduce discharge by infiltration and evapotranspiration. BMP -D is the dispersion area for DMA -4. A total of 100% of the impervious area would be going to the dispersion area. Lastly, at the east part of the project site, water would be intercepted at the south easterly corner at a headwall which connects to dual 24-inch pipes. These two new 24-inch pipes go under BMP-B and connect with the two proposed new 66-inch culverts to route storm water to the POC at South Pacific Street (Appendix F-2).
With implementation of the proposed BMPs and 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 in the SWQMP and a SWPPP would ensure construction of the project would not result in substantial erosion or siltation on or off site. The Hydrology Study (Appendix F-1) recommends storm drains, such as biofiltration basins, for the project site which would reduce the peak storm water discharge of the site by 0.18 cubic feet per second when comparing pre- and post- development conditions. Recommendations outlined in the Hydrology Study and SWQMP would be conditions of approval for the project. These components would properly handle runoff to meet regulatory requirements and to ensure that post -development run-off quantities and rates that are similar to, or less than, pre-development conditions. Therefore, it is determined that impacts to existing drainage on site would be less than significant.
Threshold #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 manner which would result in flooding on- or off-site?
Please refer to response to Threshold #3 above. 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 Hydrology Study (Appendix F-1).
These BMPs would be sized to treat, store, and release storm water runoff such that it does not substantially alter the existing drainage patterns and will not exceed the capacity of the downstream storm system. Implementation of BMPs would be a condition of approval for the project to ensure
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facilities would be des igned to collect and convey runoff from 100-year storm events , as well as carefully handle runoff and comply with applicable regulatory requirements outlined in Section 3.9.2, Regulatory Setting, above. 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. Impacts would be less than significant.
Threshold #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 #3. Implementation of the project would increase impervious areas on site. However, adequate on -site drainage and off -site storm drain connection would be incorporated into the project site design to manage storm water on and off site as a result of project development. The Hydrology Study (Appendix F-1) recommends storm drains, such as biofiltration basins, for the project. 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 a dditional sources of polluted runoff. For these reasons, it is determined that implementation 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 storm water drainage systems, nor result in substantial sources of polluted runoff. Therefore, impacts related to storm water drainage would be less than significant.
Threshold #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 response to Threshold #3, #4 and #5, above. 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 is relatively flat and does not currently result in flooding during storms. Storm drainage components recommended by the Hydrology Study (Appendix F-1) would properly handle runoff to meet regulatory requirements and to ensure that post- development run-off quantifies rates that are similar to or less than pre -development conditions. 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 storm water drainage would be less than significant.
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Threshold #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 miles inland from the Pacific Ocean and would not be subject to inundation by tsunami. The project site is not located within a 100-year flood hazard area, and is not located in flood hazard, tsunami, or seiche zones. Given that the project site is not located 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 ; and therefore, potential no impacts related to inundation would occur.
Threshold #8: Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
The Carlsbad Management Area Water WQIP update was accepted in December 2021 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. The purpose of the Carlsbad WQIP is to guide the Responsible Agencies’ Jurisdictional Runoff Management Plans toward achieving improved water quality in MS4 discharges (or storm water discharges) and receiving water bodies. Responsible Agencies’ Jurisdictional Runoff Management Program s contain the strategies, standards and protocols by which each Responsible Agencies will implement their individual program in response to the priorities and goals established in the WQIP (Carlsbad Watershed Management Area Responsible Agencies 2021).
The project is located within the San Marcos Hydrologic Area, which is the second larges t within the Carlsbad Watershed Management Area. The Carlsbad Management Area Water WQIP outlines areas of priority water quality conditions and highest priority water quality conditions. As such, the project would not conflict with or obstruct implementation of the Carlsbad 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 are determined to be less than significant.
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, each individual project applicant would be required 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 Hydrologic Area, have the potential to increase the concentration of pollutants in surface runoff and downstream water quality. However, all cumulatively considered projects would be subject to the same federal water
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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 on the analysis presented in Section 3.9.4 , Project Impact Analysis, and Section 3.9.5, Cumulative Impact Analysis, no impacts were identified, and no mitigation measures are required.
3.9.7 Conclusion
The project would increase the amount of impervious surface area in comparison to existing conditions. However, as described above, storm drainage components recommended by the Hydrology Study (Appendix F-1) 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 Hydrology Study and development-specific drainage plans would ensure the p roject 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 is determined to be less than significant.
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3.10 Land Use and Planning
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3.10 LAND USE AND PLANNING
This section analyzes potential land use and planning impacts for the proposed Hughes Circuits Project (project). This section considers consistency with applicable land use plans and habitat conservation plans. Table 3.10-1 summarizes the 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
#1: Physically divide an established community. No Impact No Impact No Impact #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 2-1 and 2-2, the project is located in north San Diego County within the western portion of the City of San Marcos (City). The undeveloped project site is an approximately 10.46-acre site, located at the northeast corner of South Pacific Street and South Pacific Street in an urban area of the City, located in the City’s Business/Industrial District (City of San Marcos 2012a). The project site is currently vacant and has no existing impervious areas. Topography within the project boundary is relatively flat with multiple wetlands, vernal pools, and vegetation communities throughout; additionally, a parcel of land owned by the San Diego County Water Authority right-of-way as well as a dirt walking path bisect the site. This is not a maintained walking path and does not provide access to other parcels beyond the project area. Elevation ranges from approximately 520 feet above mean sea level in the eastern portion of the review area to 535 feet above mean sea level in the northwest portion of the review area. Adjacent land uses include mixed commercial development to the north and south, a public recreational park (Bradley Park) to t he west, and undeveloped land to the east.
The closest freeway is State Route 78, located approximately 0.8 miles north of the project site.
Existing General Plan Designation
As shown on Figure 2 -4, the City of San Marcos General Plan designates the 10.46-acre project site as Light Industrial (LI) (City of San Marcos 2012a). The Light Industrial (LI) designation generally allows
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for light manufacturing, processing, assembly, wholesale, office, and research and development laboratories, all within enclosed buildings with limited outdoor storage . Development allowed under this land use designation must be consistent with those uses outlined in the City’s municipal code and zoning ordinance, as well as the Light Industrial land use designation of the General Plan.
Existing Zoning Designation
As shown on Figure 2 -5, existing zoning of the project site is Light Industrial (L-I). The purpose of the Light-Industrial zoning designation is to “provide for the grouping of light- and medium-intensity industrial and support service uses in a business -supportive setting. Generally, these areas will not include pedestrian-oriented businesses and will serve the loading, delivery, and indoor warehousing needs of light industrial space ” (City of San Marcos 20 22). The L-I Zone is intended to implement and be consistent with the Light Industrial land use designation of the General Plan (City of San Marcos 2022).
Surrounding Land Uses
The project site is immediately bordered by South Pacific Street to the south and west. Adjacent land uses include industrial and mixed commercial development to the north and south, a public recreational park (Bradley Park) to the west, and undeveloped land to the east. The closest freeway is State Route 78 located approximately 0.7 miles north 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 state, regional, and local regulation and planning documents.
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 relation to its planning” (Section 65300). The General Plan expresses the community ’s development goals and embodies public pol icy 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 discret ion of the jurisdiction that relate to the physical development of the county or city.
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Regional/Local
San Diego Association of Governments San Diego Forward: The Regional Plan The Regional Comprehensive Plan , adopted in 2004 by the San Diego Association of Governments (SANDAG), lays out key principles for managing the region’s growth while preserving natural resources and limiting urban sprawl. The plan covers eight policy areas, including urban form, transportation, housing, healthy environment, economic prosperity, public facilities, our borders, and social equity.
On October 9, 2015, the SANDAG Board of Directors adopted San Diego Forward: The Regional Plan (Regional Plan). The Regional Plan combines the two previously described existing regional planning documents: the Regional Comprehensive Plan and the 2050 Regional Transportation Plan/Sustainable Communities Strategy ( RTP/SCS). The Regional Plan updates growth forecasts and is based on the most recent planning assumptions considering currently adopted land use plans, including the City ’s General Plan. SANDAG ’s Regional Plan will be updated every 4 years to account for changes from ongoing land use planning decisions by local agencies. The most recent regional plan is the 2019 San Diego Forward Federal Transportation Plan, which builds off of the 2015 plan (SANDAG 2019). SANDAG is in the process of finalizing its 2021 Regional Plan, which will provide the long-term blueprint for the San Diego region that seeks to meet regulatory requirements, address traffic congestion, and create equal access to jobs, education, healthcare, and other community resources.
SANDAG Multiple Habitat Conservation Program
The Multiple Habitat Conservation Program (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 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 contr ibute toward the habitat preserve system for the protection of more than 80 rare, threatened, or endangered species.
The City of San Marcos began preparing a draft of the City Subarea Plan of the MHCP in May 2001 and although the 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 City ’s Draft Subarea Plan is to identify a citywide preserve system that meets local and regional biolo gical goals while minimizing fiscal and economic impacts to the City and adverse impacts on private property owners. To help achieve this goal, certain areas, known as Focused Planning Areas , have been designated with parcel -level preserve goals which would contribute to achieving local and regional conservation goals while minimizing adverse effects on property rights
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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 located approximately 5 miles west 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 alre ady developed with existing uses, and to protect the public health, safety, and welfare. Using airport -related forecasts and background data approved by the Calif ornia 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 located within the McClellan -Palomar Airport Influence Review Area 2 and an overflight notification is required (San Diego County Regional Airport Authority 2011). The influence area is regulated by the Airport Land Use Commission, which regulates land uses in the area to be compatible with airport -related noise, safety, airspace protection, and over-flight factors through review of development proposals within the airport influence area. Review Area 2 consists of limits on heights of structures in areas of high terrain.
Residential development in Review Area 2 may be subject to annoyances commonly associated with proximity to airports, such as noise, vibration, and overflights.
City of San Marcos General Plan
The San Marcos 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 connects people with the City. • Conservation and Open Space Element – Recognizes the habitat and scenic value of natural 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.
3.10 Land Use and Planning
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• 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 2013–2021 planning period.
The following goals and policies from the City ’s Land Use Element pertain to planning and are applicable to the project:
• 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. o Policy LU-1.1: Ensure that adjacent land uses complement one another by considering compatibility of activities, development patterns and architectural character elements, and access to various mobility choices.
o 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. • Goal LU-2: Promote development standards and land use patterns that encourage long -term environmental sustainability.
o Policy LU -2.1: Promote compact development patterns that reduce air pollution and automobile dependence and facilitate walking, bicycling, and transit use. o Policy LU-2.2: Encourage new development to be sited to respond to climatic conditions, such as solar orientation, wind, and shading patterns.
o Policy LU -2.3: Require the incorporation of green building practices, technologies, and strategies into development projects per code standards. o Policy LU-2.5: Promote landscaping (e.g., native, drought -tolerant plants) that minimizes demands on water supply.
o Policy LU-2.7: Promote the installation of trees to reduce the urban heat island effect and green infrastructure to reduce storm water runoff.
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• Goal LU-3: Develop land use patterns that are compatible with and support a variety of mobility opportunities and choices.
o 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. o Policy LU-3.3: Where feasible, consolidate inadequately sized land into parcels suitable for integrated development with improved pedestrian and vehicular circulation. o Policy LU -3.5: Provide an interconnected open space system that is accessible to the public, including pedestrian and equestrian links, bicycle paths, multi-use trails, recreation areas, and drainage-ways.
o Policy LU-3.7: Require new development to prepare traffic demand management programs. o 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. o 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.
o 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. o 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. o Policy LU-5.6: Require a specific plan for strategic areas/properties that require high-quality design, orientation and development due to their location or visibility within the community. o Policy LU-5.7: Architecture shall be enhanced with high-end building materials, varied roof lines, and decorative details.
• 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.
o Policy LU-7.2: Coordinate pedestrian, transit and infrastructure upgrades with infill and redevelopment opportunities.
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• Goal LU -8: Ensure that existing and future development is adequately serviced by infrastructure and public services.
o Policy LU-8.1: New development shall pay its fair share of required improvements to public facilities and services.
o Policy LU-8.2: Promote development timing that is guided by the adequacy of existing and/or expandable infrastructure, services, and facilities. • Goal LU -14: Wastewater: Ensure an adequate wastewater system for existing and future development.
o 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. o 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.
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, Project Impact Analysis.
San Marcos Municipal Code and 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 publ ic 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.
3.10.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to land use and planning are based on Appendix G of the California Environmental Quality Act (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 #1: Physically divide an established community. • Threshold #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.
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3.10.4 Project Impact Analysis
This section considers the impacts to land use and planning that would result from the project.
Threshold #1: Would the project physically divide an established community? The physical division of an established community typically refers to the construction of a linear feature (e.g., a major highway or railroad tracks) or removal of a means of access (e.g., a local road or bridge) that would impair mobility within an existing community or between a community and outlying area.
Under the existing condition, t he project site is currently undeveloped land and is not used as a connection between established communities. Instead, connectivity within the area surrounding the project site is facilitated via local roadways. As such, the project would not impede movement within the project area, within an established community, or from one established community to another.
As described in Chapter 2 , Project Description, of this environmental impact report (EIR), the project proposes development of a 67,410-square-foot light industrial building, which would be located at the western-most portion of the project site, and the disturbance area associated with project construction would be limited to approximately 113,877 square feet or 2.61 acres of the 10.46-acre project site.
The remaining 7.85 acres of the 10.46-acre project site would be preserved and restored open space and habitat area. Therefore, no impacts associated with the division of an established community would occur.
Threshold #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 be consistent with the current General Plan and zoning designations for the site.
Although the project would be consistent with the land use designation, a consistency analysis with the City’s General Plan goals are included in Table 3.10-2.
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 Mitigation
Measure (MM-)BIO-1 through MM-BIO-12 outlined in
Section 3.3, Biological Resources, would ensure that
the project would not conflict with the Multiple
Habitat Conservation Program or draft San Marcos
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Table 3.10-2
General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy Subarea Plan, or other applicable regulations related
to biological resources. Additionally, 7.85 acres of
the 10.46-acre project site would be preserved in
place as open space and habitat area.
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 Industrial uses. Implementation of the
project would not convert any designated open
space or agricultural uses. Additionally, 7.85 acres of the 10.46-acre project site would be preserved and
restored open space and habitat area.
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 Industrial uses. Development of the
project site would not significantly alter existing
characteristics of the surrounding area as described
in Section 3.1, Aesthetics, of this environmental
impact report (EIR). Additionally, 7.85 acres of the
10.46-acre project site would be preserved and
restored open space and habitat area.
Goal COS-4: Improve regional air quality and reduce
greenhouse gas emissions that contribute to climate
change.
Consistent. The project would be consistent with the
land use and zoning designation of the project site.
The project’s proposed growth would be within the
growth projections for the City and, at a regional
level, the project is consistent with the underlying
growth forecasts in the State Implementation Plan
and Regional Air Quality Strategy. Therefore,
implementation of the project would not conflict with
the Regional Air Quality Strategy or State
Implementation Plan and proposed development
would be consistent with the growth in the region.
Implementation of the project also would not violate
any air quality standards or contribute substantially
to an existing or projected air quality violation during construction or operation. Additionally, the project
would not expose sensitive receptors to substantial
pollutant concentrations or expose a substantial
number of people to objectionable odors. In
summary, impacts with regard to air quality would be
less than significant, and no mitigation is required.
Related to greenhouse gas emissions, the project
would be consistent with the City’s 2020 Climate
Action Plan. Furthermore, the project would be
consistent with and would not conflict with the
applicable greenhouse gas–reducing strategies of
the state, would be consistent with the California Air
Resources Board’s Scoping Plan, and would be
consistent with San Diego Association of
Governments’s 2050 Regional Transportation
Plan/Sustainable Communities Strategy. Impacts
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Table 3.10-2
General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy with regard to greenhouse gas emissions would be
less than significant, and no mitigation is required.
Please refer to Section 3.2, Air Quality, and Section
3.7, Greenhouse Gas Emissions, of this EIR.
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 National Pollutant Discharge Elimination
System State Water Resources Control Board
Construction General Permit Order No. 2009-0009-
DWQ for stormwater discharges and general
construction activities, and incorporate standard
best management practices (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 Stormwater
Pollution Prevention Plan (SWPPP) would be required
for the project site that 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
Stormwater Quality Management Plan.
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 Hydrology Study (Appendix F-1)
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,
Storm Water Quality Management Plan and BMPs,
and implementation of all recommendations from
the Hydrology 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. 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
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Table 3.10-2
General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy 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 a level of significance through
implementation of MM-CR-1 through MM-CR-4.
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 land use designation would
be consistent with adjacent industrial and
commercial land uses as well as the City’s 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 light industrial uses near
existing commercial and industrial uses; designating
opportunities for open space areas; and supporting
vehicular, bicycle, and pedestrian modes of travel.
As described in Section 3.15, Transportation, of the
EIR, the project would implement Class II bicycle
facilities along South Pacific Street between Linda
Vista Drive and West San Marcos Boulevard. The
Class II bicycle lanes would have a 1.5-foot buffer
where on-street parking is allowed and a 3-foot
buffer where on-street parking is prohibited.
Additionally, sidewalks are proposed along the
segment of South Pacific Street fronting the project.
Sidewalks are also proposed throughout the internal
roadways providing direct access to the proposed
building. The project would incorporate sidewalks
where they do not currently exist, and as outlined in
the Local Transportation Analysis (LTA), project
construction of curb ramps located along project
driveways to include detectable surface warning
tactiles to meet ADA requirements would further
enhance the walkability and safety of the pedestrian
environment at the project site.
Goal LU-3: Develop land use patterns that are
compatible with and support a variety of mobility
opportunities and choices.
Consistent. The North County Transit District
operates the Palomar College Station Sprinter and
Breeze transit station located within 1 mile of the
project. The project would 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.
As described above, the project would implement
Class II bicycle facilities along South Pacific Street
between Linda Vista Drive and West San Marcos
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Table 3.10-2
General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy Boulevard. The Class II bicycle lanes would have a
1.5-foot buffer where on-street parking is allowed
and a 3-foot buffer where on-street parking is
prohibited. Additionally, sidewalks are proposed
along the segment of South Pacific Street fronting
the project. Sidewalks are also proposed throughout
the internal roadways providing direct access to the
proposed building. The project would incorporate
sidewalks where they do not currently exist, and as
outlined in the LTA, project construction of curb
ramps located along project driveways to include
detectable surface warning tactiles to meet ADA
requirements would further enhance the walkability
and safety of the pedestrian environment at the
project site.
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
renderings would be reviewed by the City, and would
be expected to create a cohesive character with the
surrounding environment.
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 the proposed light-industrial
development on a site currently zoned for light
industrial uses, and adjacent to other similar land
uses in an urban area of the City. The project would
be required to comply with Title 24 requirements,
and would include amenities such as electric vehicle
charging stations, installation of bicycle facilities,
implement a Transportation Demand Management
plan.
Goal LU-8: Ensure that existing and future
development is adequately serviced by
infrastructure and public services.
Consistent. As outlined in Section 3.13, Public
Services, of this EIR, the project would be adequately
served by San Marcos Fire Department and San
Marcos Sheriff’s Department, as well as utility
infrastructure, as outlined in Section 3.17, Utilities
and Service Systems, of this EIR. The project’s
estimated water and wastewater demand would be
adequately provided by the Vallecitos Water District
(VWD). Furthermore, the project would be required to
comply with the City’s Development Services Fees,
and the applicant would be required to pay
applicable fees for fire and police services;
applicable school fees under Senate Bill 50; and
applicable Public Facility Fees for City parks.
Goal LU-10: Fire protection, emergency services, and
law enforcement: Provide effective, high-quality and
responsive services.
Consistent. As outlined in Section 3.13 of this EIR,
the project would be adequately served by San
Marcos Fire Department and San Marcos Sheriff’s
Department.
Goal LU-13: Water Service and Supply: Manage and
conserve domestic water resources by reducing
Consistent. As outlined in Section 3.17 of this EIR,
the VWD Sewer and Water Study prepared for the
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Table 3.10-2
General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy water usage and waste on a per capita basis, to
ensure an adequate water supply for existing and
future residents.
project determined that there would be no
deficiencies in the distribution system under normal
or peak demand conditions. The Master Plan from
2018 indicated that the maximum demand for this
project would be three times the average demand,
and peak hour demand would be over six times the
average. The project is located entirely within the
VWD 855 pressure zone, which has water storage
located in the 920 zone and 1028 Twin Oaks
pressure zones. The project is expected to increase
the average water demand by 3,393 gallons per day,
which equates to a 500% increase in storage
requirements or 16,965 gallons. However, the
analysis showed that the current water storage
capacity would be sufficient to meet the increased
demand (Appendix J). Further, the project site would
be developed in compliance with the California
Green Building Code, which implements water
efficiency standards for appliances and fixtures.
Compliance with the California Green Building Code
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 ability to service any development and
capacity fees to be paid. A “Water Availability” letter will be required for processing the project.
Compliance with these regulations and conservation
measures will ensure sufficient water supplies are
available to service the project.
Goal LU-14: Wastewater: Ensure an adequate
wastewater system for existing and future
development.
Consistent. Implementation of the project would
require the construction of on-site sewer lines that
would connect to the public sewer system at one or
more locations. The connections to the existing
system will depend on on-site grading and utility
design. A Water and Sewer Study was prepared for
the project and is included as Appendix J to the EIR.
The Hughes Circuits project is expected to increase
the average wastewater generation by 3,393 gallons
per day compared to the 2018 Master Plan land
use. The modeling conducted not only focused on
the sewer collection infrastructure within the
immediate vicinity of the project but also on all
downstream infrastructure up to Lift Station No. 1 on
San Marcos Boulevard that would be impacted by
the project flows. The modeling results revealed that
there were no issues identified under the current
approved density even under peak wet weather
flows during ultimate build-out conditions. This EIR
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Table 3.10-2
General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy has determined that impacts related to wastewater
are 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.
Electricity and natural gas would be provided by San
Diego Gas & Electric. Electrical facilities throughout
the City include a combination of above-ground and
below-ground electrical distribution lines and utilities structures. 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 San Diego Gas & Electric. Project
operation would require electricity for multiple
purposes, including cooling, lighting, appliances, and
various equipment. The project will be subject to the
Title 24 building code that is adopted at the time
building permits are obtained and thus may be
subject to a more stringent energy standard than
what was assumed herein, and the additional
electricity demand for the project would not be
unusual or wasteful as compared to overall local and
regional demand for energy resources.
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 the proposed light-industrial
development on a site currently zoned for light
industrial uses, and adjacent to other similar land
uses in an urban area of the City. The project would
be required to comply with Title 24 requirements,
and would include amenities such as electric vehicle
charging stations, installation of bicycle facilities,
implement a Transportation Demand Management
plan, reduced landscaping water use, and tree
planting. The project would implement Class II
bicycle facilities along South Pacific Street between
Linda Vista Drive and West San Marcos Boulevard.
The Class II bicycle lanes will have a 1.5-foot buffer
where on-street parking is allowed and a 3-foot
buffer where on-street parking is prohibited. By
installing frontage improvements such as sidewalks
and bike lanes, the project provides and encourages
multimodal transportation in the area.
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Table 3.10-2
General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy 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 project would be served by two
driveways. Project Driveway #1 would be located
along the east side of South Pacific Street to the
west of the project site. This driveway would be a
new side-street stop-controlled intersection with
South Pacific Street as the uncontrolled approach
and the project driveway as the stop-controlled
approach. Project Driveway #2 would be located
along the north side of South Pacific Street to the
south of the project site. This driveway will be a new
side-street stop-controlled intersection with South
Pacific Street as the uncontrolled approach and the
project driveway as the stop-controlled approach.
The internal roadway on the project site would allow
for two-way flow of vehicle traffic. The LTA
recommends that the project incorporate
appropriate signage to warn drivers of pedestrian
foot traffic and consider installation of speed
cushions/bumps along the internal roadway to calm
traffic. Furthermore, sidewalks are proposed along
the segment of South Pacific Street fronting the
project. The LTA recommends that the project
construct curb ramps located along project
driveways to include detectable surface warning
tactiles (yellow truncated domes) and meet all ADA
requirements. As described above, the project would
implement Class II bicycle facilities along South
Pacific Street between Linda Vista Drive and West
San Marcos Boulevard. The Class II bicycle lanes will
have a 1.5-foot buffer where on-street parking is
allowed and a 3-foot buffer where on-street parking
is prohibited.
The internal circulation network for the project would
not include any hazardous design features or
incompatible uses that would affect nearby
neighborhoods.
Goal M-3: Promote and encourage use of alternative
transportation modes, including transit, bicycles,
neighborhood electric vehicles (NEVs), and walking,
within the City.
Consistent. As outlined in the Traffic Impact Analysis
prepared for the project (Appendix I), in order to
reduce project impacts related to vehicle miles
traveled, mitigation measures including a
ridesharing program and on-site bicycle facilities
would be incorporated into the project. Additionally,
the project would provide electric vehicle charging
infrastructure on site.
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Table 3.10-2
General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy 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
Investigation (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. 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 is relatively flat and does not
currently result in flooding during storms. The project site is located in Zone X of the Flood Insurance Rate
Map, Zone X is designated to be areas determined to
be outside the 500-year floodplain. Storm drainage
components recommended by the Hydrology Study
(Appendix F-1) would properly handle runoff to meet
regulatory requirements and to ensure that post-
development run-off quantifies rates that are similar
to or less than pre-development conditions. On-site
drainage facilities and off-site drainage connections
would be designed to collect and convey runoff from
100-year storm events.
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 within or
adjacent to a State Responsibility Area or Local
Responsibility Area Very High Fire Hazard Severity
Zone (CAL FIRE 2009). The existing project site is an
undeveloped 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
California Fire Code and the San Marcos Fire
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Table 3.10-2
General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy Department, which require a design that affords fire
and emergency responders suitable fire access
roads dimensions and surfaces (Chapter 5, Section
503.1 through 503.4 of the California Fire Code); an
adequate number of emergency rated entrances to
the community (Appendix D, Section D106 of the
California Fire Code); and entryway gate access for
first responders (Chapter 5 of the California Fire
Code, Section 503.6).
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. Project operation would support the
expansion of the existing operations of Hughes
Circuits Inc., located adjacent to the project site to
the south. Existing operations of Hughes Circuits
Inc., adjacent to the site conducts PCB fabrication
and has a permit to discharge pretreated industrial
wastewater. This operation would not be conducted
in the new proposed building; only assembly would
occur under project operation, and assembly does
not generate any hazardous waste.
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
adhere to standards contained within 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
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Table 3.10-2
General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy 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 n.d.).
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 located within
McClellan-Palomar Airport Influence Areas Review
Area 2. The influence area is regulated by the Airport
Land Use Commission, which regulates land uses in
the area to be compatible with airport-related noise,
safety, airspace protection, and over-flight factors
through review of development proposals within the
airport influence area. Review Area 2 consists of
limits on heights of structures in areas of high
terrain. The project would be consistent with the
City’s land use designation for the project site and
would not conflict with the McClellan-Palomar Airport
Land Use Compatibility Plan. The project site would
not be characterized as an area of high terrain,
defined as a maximum height of 795 feet above
mean sea level or as in an area of Terrain
Penetration to Airspace Surfaces. The height and
density of the project would be consistent with the
existing surrounding development.
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
industrial and mixed-commercial uses to the north
and south. Noise generated by the project would be
similar to that of existing land uses in the vicinity.
Goal N-2: Control transportation-related noise from
traffic, rail, and aviation sources near noise sensitive land uses.
Consistent. The nearest noise-sensitive receivers are
approximately 500 feet west-southwest of the
project and represented by multi-family homes along
Beverly Way in the Lake Park Terrace community
that is zoned Residential R-3-10. 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 Community Noise
Equivalent Level increase of less than 3 decibels,
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Table 3.10-2
General Plan Consistency
Applicable General Plan Goals Project Consistency with Policy 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. 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. As described in response to Goal N-2,
the nearest noise-sensitive receivers are
approximately 500 feet west-southwest of the
project and represented by multi-family homes along
Beverly Way in the Lake Park Terrace community
that is zoned Residential R-3-10. The Noise
Technical Report prepared for the project
determined that stationary project operational noise
would result in less than significant impacts to
nearby receptors (please see Section 3.11 of the
EIR).
As shown in Table 3.10-2, the project would not result in a significant environmental impact due to a conflict with applicable Land Use Element goals in the City’s General Plan. Land Use Element goals not referenced above, including LU-4, 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. Instead, 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, as well as systems and demand management. The 2050 RTP/SCS presents a transportation system designed to maximize transit enhance ments, integrate biking and walking elements, and promote programs to reduce demand and increase efficiency. The project would not conflict with any programs, plans, ordinances and policies addressing the circulation system, including transit, roadw ay, bicycle, and pedestrian facilities. Additionally, t he project would be consistent with the existing zoning and land use designations. Thus, the project would not increase land use intensities as provided in the RTP/SCS and would therefore not result in environmental impacts due to inconsistency with this plan.
For the CEQA transportation vehicle miles traveled (VMT) analysis, the project’s VMT per employee was obtained from the SANDAG VMT screening maps. Per the City’s Traffic Impact Analysis Guidelines, an
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Hughes Circuits Project Environmental Impact Report March 2024 City of San Marcos 3.10-20
employee project is determined to have a significant impact if the project generates VMT per employee greater than 85% of the regional average. The regional average VMT was determined using the SANDAG Series 14 ABM2+/2021 RP Year 2016 Base model. The project is anticipated to generate a VMT per employee of 16.80 miles, which exceeds the significance threshold of 16.07 miles. Therefore, the project would have a significant VMT impact and mitigation measures are required to reduce the VMT per employee. Howeve r, even with implementation of mitigation outlined in the Traffic Impact Analysis (Appendix I to this EIR), and Section 3.15 , Transportation, of this EIR, proposed mitigation measures would not reduce the VMT per employee to less than significant levels, and impacts would be significant and unavoidable.
Multiple Habitat Conservation Program
As described under Section 3.10.2 , Regulatory Setting, above, 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). As described throughout Section 3.3, Biological Resources, of this EIR, project implementation would result in potentially significant impacts to biological resources. However, compliance with existing regulations and implementation of MM-BIO- 1a through MM-BIO-12 outlined in Section 3.3 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. 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.
San Marcos Municipal Code Zoning Ordinance, Title 20
As described above, the project site is zoned for Light Industrial uses, which would be consistent with the project.
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 are determined to be less than significant.
3.10.5 Cumulative Impact Analysis
As described in Section 3.10.3, Thresholds of Significance, above, the project would be consistent the City’s General Plan land use designation, zoning, and the goals of the City’s General Plan. In addition to the City’s General Plan, t he project would also be consistent with the City ’s Municipal Code , SANDAG’s 2050 RTP/SCS , and applicable plans and polices described in the regulatory setting sections throughout Chapter 3, Environmental Analysis.
All cumulative projects would be subject to similar criteria as the project, which would ensure compliance with existing applicable land use plans with jurisdiction over the project area. Any
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cumulative projects would be required 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 are determined to 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 on the analysis presented in Sections 3.10.4 and 3.10.5, development of the project 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, implementation of the project would not result in any significant unavoidable impacts, with the exception of impacts related to transportation, as a result of VMT. All potentially significant impacts to biological resources, cultural resources, 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 are determined to be less than significant.
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3.11 Noise
Hughes Circuits Project Environmental Impact Report March 2024 City of San Marcos 3.11-1
3.11 NOISE
This section discusses the existing noise and vibration setting of the proposed Hughes Circuits Project (project), identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the project. This section is based on the Noise and Vibration Analysis Technical Report prepared for the project by Dudek in January 2023 , which is included as Appendix G to this environmental impact report.
Table 3.11-1 summarizes the project- and cumulative-level noise impact analysis for the project.
Table 3.11-1
Noise Summary of Impacts
Threshold of Significance
Project Direct
Impact
Project Cumulative
Impact
Significance
Determination
#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
#2- Generation of excessive
groundborne vibration or groundborne
noise levels.
Less Than
Significant
Less than
Significant
Less Than
Significant
#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, and 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. The sound pressure level 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). Under controlled conditions in an acoustics laboratory, the trained, healthy human ear is able to discern changes in sound levels of 1 dB
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when exposed to steady, single-frequency signals in the mid-frequency range. Outside such controlled conditions, the trained ear can detect changes of 2 dB in normal environmental noise. It is widely accepted that the average healthy ear, however, can bare ly perceive noise level changes of 3 dB. A change of 5 dB is readily perceptible, and an upward change of 10 dB is perceived as twice as loud (Caltrans 2013). A doubling of sound energy results in a 3 dB increase in sound, which means that a doubling of sound energy (e.g., doubling the number of ground vehicle daily trips along a given road segment) 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.
Several descriptors of noise (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 Leq measurement of 60 dBA would represent the average amount of energy contained in all the noise that occurred in that hour. Leq 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 (L max), which is the greatest sound level measured during a designated time interval or event. The minimum sound level (Lmin) is often called the floor of a measurement period.
Unlike the Leq, Lmax, and Lmin metrics, Ldn and CNEL descriptors always 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. Noise during the evening (7:00 p.m. to 10:00 p.m.) is penalized by adding 5 dB, and nighttime (10:00 p.m. to 7:00 a.m.) noise is penalized by adding 10 dB. L dn 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. L dn 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 to 1 dB, and are often considered or actually defined as being essentially equivalent by many jurisdictions (Appendix G).
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Vibration Fundamentals
Vibration is oscillatory movement of mass (typically a solid) over time. It is described in terms of frequency and amplitude and, unlike sound, can be expressed as displacement, velocity, or acceleration. For environmental studies, vibration is often studi ed as a velocity that, akin to the discussion of sound pressure levels, can also be expressed in dB as a way to cast a large range of quantities into a more convenient scale. These vibration velocity decibels (VdB) are based on the root- mean-square (RMS) of a vibration velocity signal, and often used in the context of assessing building occupant detection or annoyance towards received groundborne vibration. Potential vibration impacts to buildings, on the other hand, are usually discussed in terms of inches per second (ips) peak particle velocity (PPV). Both of these vibration velocity descriptors will be used herein to discuss predicted project-attributed groundborne vibration levels and their comparison with relevant standards.
Common sources of vibration within communities include construction activities and railroads.
Groundborne vibration generated by construction projects is usually highest during pile driving, rock blasting, soil compacting, jack hammering, and demolition-related activities where sudden releases of subterranean energy or powerful impacts of tools on hard materials occur. Depending on their distances to a sensitive receptor, operation of large bulldozers, graders, loaded dump trucks, or other heavy construction equipment and vehicles on a construction site also have the potential to cause high vibration amplitudes. The maximum vibration level standard used by the California Department of Transportation (Caltrans) for the prevention of structural damage to typic al residential buildings is
0.3 ips PPV (Caltrans 2020).
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 infill area, bordered by existing roadways and industrial and commercial uses. Sources of noise in the surrounding area primarily include traffic from the local roadways, including South Pacific Street.
Sound pressure level measurements were conducted near the project site on February 25, 2022, to quantify and characterize samples of the existing (a.k.a., baseline or pre -project) outdoor sound environment. Table 3.11-2 provides the location (and adjoining land use) and time at which these baseline noise level measurements were taken. The sound pressure level measurements were performed by an attending Dudek field investigator using a Rion 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 in the field using a reference sound signal (i.e., field calibrator) before and after the measurements, and the measurements were conducted with the microphone positioned approximately 5 feet above the ground.
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Hughes Circuits Project Environmental Impact Report March 2024 City of San Marcos 3.11-4
Three short -term noise level measurement locations (ST1 –ST3) are depicted on Figure 3.11 -1, Baseline Outdoor Ambient Sound Level Measurement Positions, and include one of each receiving land use (multifamily, public-institutional, and light industrial). Table 3.11-2 presents Leq, Lmax, and Lmin values for these surveyed positions, which were affected by the investigator -noted acoustical contributors as follows:
• ST1 – Heating, ventilation, and air-conditioning (HVAC) equipment on nearby building, birdsong, distant aircraft, distant conversations, yelling, distant industrial, distant roadway traffic • ST2 – Birdsong, distant aircraft, distant conversations, yelling, distant industrial, rustling leaves, backup alarms, HVAC
• ST3 – roadway traffic, birdsong, construction saw across street, distant car wash tunnel As shown in Table 3.11-2, the measured sound levels ranged from approximately 43.1 dBA Leq at ST1 to 64.0 dBA L eq at ST2. Noise measurement data and photographs of the survey locations appear in Appendix A, Baseline Noise Measurement Field Data , of Appendix G . These samples of daytime L eq measured at the three representative receptor positions in Table 3.11 -2 can be interpreted as approximations of CNEL, since evening sound pressure level would likely be 5 dBA less, and nighttime sound pressure level would be 10 dBA less than the daytime values (FTA 2018).
Detailed noise measurement data is included as part of Appendix G to this environmental impact report.
Table 3.11-2
Measured Outdoor Ambient Sound Environment Samples
Survey
Position Location/Address
Start and End Time
(hh:mm)
Leq
(dBA)
Lmax
(dBA)
Lmin
(dBA)
ST1 Tennis and basketball courts near
501 Beverly Place
10:00 AM to 10:15 AM 43.1 47.7 39.3
ST2 542 S. Pacific Street (Hughes
Circuits existing facility)
10:45 AM to 11:00 AM 64.0 79.7 51.4
ST3 Bradley Park baseball diamond
across from 1520 Linda Vista Drive
10:30 AM to 10:45 AM 61.0 70.4 52.2
Source: Appendix G.
Notes: Leq = equivalent continuous sound level (time -averaged sound level); L max = maximum sound level during the measurement interval; dBA = A-weighted decibels; ST = short-term noise measurement locations.
Sensitive Receptors
Uses that are typically considered noise sensitive include residences, schools, hospitals, parks, and wildlife habitats. The nearest noise-sensitive receivers are approximately 500 feet west-southwest of the project and represented by multifamily homes along Beverly Way in the Lake Park Terrace community that is zoned Residential R-3-10 (City of San Marcos 2022).
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3.11.2 Regulatory Setting
Federal
Occupational Safety and Health Administration
With regard to noise exposure and workers, the federal Occupational Safety and Health Administration (OSHA) establishes regulations to safeguard the hearing of workers exposed to occupational noise (29 Code of Federal Regulations, Section 1910.95). OSHA specifies that sustained noise that is louder than 85 dBA (8-hour time-weighted average) can be a threat to workers’ hearing and if worker exposure exceeds this amount, the employer must develop and implement a monitoring program (29 Code of Federal Regulations, Section 1910.95[d][1]).
Federal Transit Administration
In its Transit Noise and Vibration Impact Assessment guidance manual, the Federal Transit Administration (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. Although 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.
The same aforementioned FTA guidance manual also includes recommended groundborne vibration thresholds for building damage risk that depend on the receiving structure type and condition. By way of example, it indicates that for “non -engineered timber and masonry buildings,” the criterion would be 0.2 ips PPV or 94 VdB when this value is converted to an RMS signal by a crest factor of 4 (FTA 2018). For “engineered concrete and masonry (no plaster)” buildings, the threshold is less stringent:
0.3 ips PPV or 98 VdB.
For purposes of assessing building occupant annoyance, FTA guidance suggests that residences would be “Category 2” receivers (i.e., “where people normally sleep”) for which 72 VdB to 80 VdB would be an appropriate standard depending on the frequency of vibration occurrence (FTA 2018).
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State
California Noise Control Act of 1973
Sections 46000 through 46080 of the California Health and Safety Code, known as the California Noise Control Act of 1973, declares that excessive noise is a serious hazard to the public health and welfare and that exposure to certain levels of noise can re sult in physiological, psychological, and economic damage. It also identifies a continuous and increasing bombardment of noise in the urban, suburban, and rural areas. The California Noise Control Act declares that the State of California has a responsibility to protect the health and welfare of its citizens by the control, prevention, and abatement of noise. It is the policy of the State to provide an environment for all Californians free from noise that jeopardizes their health or welfare. The California Noise Control Act seeks to provide assistance to local agencies in preparation of ordinances to control and abate noise.
California Code of Regulations
California Government Code Section 65302(f) mandates that the legislative body of each county and city adopt a noise element as part of its comprehensive general plan. The local noise element must recognize the land use compatibility guidelines established by the State Department of Health Services. The guidelines rank noise land use compatibility in terms of “normally acceptable ,” “conditionally acceptable ,” “normally unacceptable ,” and “clearly unacceptable” noise levels for various land use types. Single-family homes are “normally acceptable” in exterior noise environments up to 60 dBA CNEL and “conditionally acceptable” up to 70 dBA CNEL. Multiple-family residential uses are “normally acceptable” up to dBA 65 CNEL and “conditionally acceptable” up to dBA 70 CNEL.
Schools, libraries, and churches are “normally acceptable” up to 70 dBA CNEL, as are office buildings and business, commercial, and professional uses.
California Department of Transportation
In its Transportation and Construction Vibration Guidance Manual, Caltrans recommends a vibration velocity threshold of 0.2 ips PPV (Caltrans 2020) for assessing “annoying” vibration impacts to occupants of residential structures. Although this Caltrans gu idance is not a regulation, it can serve as a quantified standard in the absence of such limits at the local jurisdictional level. Similarly, thresholds to assess building damage risk due to construction vibration vary with the type of structure and its fr agility, but tend to range between 0.2 ips and 0.3 ips PPV for typical residential structures (Caltrans 2020).
For office building occupants, the same Caltrans guidance manual refers to International Organization of Standardization (ISO) 2631 that indicates 0.016 ips RMS (80 VdB) would be an appropriate threshold in the context of “detection or discomfort .” Converted to PPV using the FTA -recommended crest factor of 4 (FTA 2018), this value translates to 0.04 ips. A building with workshops (or similar
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interior uses) would have a recommended vibration criteria of 0.08 ips PPV per the same guidance based on ISO 2631, or an RMS value of 0.032 ips (86 VdB). The Caltrans guidance manual also refers to the aforementioned FTA impact criteria for Category 3 land uses that ranges between 75 VdB and 83 VdB depending on frequency of vibration occurrence (Caltrans 2020).
Local
The following are summarized or reproduced portions of relevant City of San Marcos (City) regulations and General Plan policies.
City of San Marcos Municipal Code
The City of San Marcos Municipal Code Chapter 10.24: Noise ( City of San Marcos 2017) addresses construction noise. Erection and demolition of buildings is exempt 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. Commonly, the City has utilized the County of San Diego’s Noise Ordinance construction noise limit of 75 dBA (8-hour average) as received by occupied properties.
Chapter 20.300 (Site Planning and General Development Standards) of the City’s Municipal Code includes noise regulations in the form of noise standards by zone (Section 20.300.070, Performance Standards). It should be noted that Municipal Code noise standa rds typically pertain to stationary (i.e., non-transportation-related) noise sources. The relevant portions of these noise standards are provided below:
1. Noise shall be measured with a sound -level meter that meets the standards of the American National Standards Institute (ANSI) (Section S1.4-1979, Type 1 or Type 2). Noise levels shall be measured in decibels at the property line of the receptor property, and at least five (5) feet above the ground and ten (10) feet from the nearest structure or wall. The unit of measure shall be designated as an A-weighted decibel (dBA) Leq standard. A calibration check shall be made of the instrument at the time any noise measurement is made (Ord. No. 2017-1446, 7-25-2017)
2. No person shall create or allow the creation of exterior noise that causes the noise level to exceed the noise standards established by Table 20.300-4 (shown in this report as Table 3.11- 3). Increases in exterior noise levels listed in Table 20.300 -4 are permitted but depend on cumulative duration of the increase within the measured hour. For instance, a 5 dB increase is allowed for up to fifteen (15) minutes within the hour, but a 10 dB increase above the limit is allowed for up to 5 cumulative minutes within that hour.
3. Use of compressors or other equipment, including vents, ducts, and conduits, but excluding window or wall-mounted air conditioners, that are located outside of the exterior walls of any building, shall be enclosed within a permanent, non-combustible, view-obscuring enclosure to ensure that the equipment does not emit noise in excess of the ANSI standards.
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Table 3.11-3
City of San Marcos Exterior Noise Standards
Zone Applicable Limit (decibels) Time Period
Single-Family Residential (A, R-1, R-2) 1, 2 60
50 7:00 a.m. to 10:00 p.m.
10:00 p.m. to 7:00 a.m.
Multifamily Residential (R-3) 1, 2 65
55 7:00 a.m. to 10:00 p.m.
10:00 p.m. to 7:00 a.m.
Commercial (C, O-P, SR) 3 65
55 7:00 a.m. to 10:00 p.m.
10:00 p.m. to 7:00 a.m.
Industrial 65
60 7:00 a.m. to 10:00 p.m.
10:00 p.m. to 7:00 a.m.
Source: City of San Marcos 2017 (Table 20.300-4).
1 For single-family detached dwelling units, the “exterior noise level” is defined as the noise level measured at an outdoor living area that adjoins and is on the same lot as the dwelling and that 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 that 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 a gency, normally including swimming pools, recreation courts, patios, open landscaped areas, and greenbel ts 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.
City of San Marcos General Plan
The Noise Element of the City of San Marcos General Plan (City of San Marcos 2012) establishes target maximum noise levels in the City. Table 7 -3 in the City’s Noise Element depicts “acceptable,” “conditionally acceptable,” and “unacceptable” transportation -related exterior noise levels for the indicated land use designations.
With respect to commercial/industrial developments like the project, the Noise Element states: “the City should consider noise generation and potential impacts to surrounding development. New development can be made compatible with the noise environment by using noise and land use compatibility standards and the Future Noise Contour Diagram (see Figure 7-2) as a guide for planning and development decisions. During the project design review process, the City can work with the project applicant to identify of potential impacts and reasonable mitigation measures. For example, the City can require an acoustical analysis for projects that will potentially generate noise that would affect sensitive receptors. These mitigation measures can include, but not be limit ed to, acoustically treated and/or quiet designs for furnaces, fans, motors, compressors, valves, pumps and other mechanical equipment. The City may also require limited delivery hours and/or hours of operation in order to reduce impacts to adjacent sensitive uses. In addition, all City departments must comply with state and federal OSHA standards. Any new equipment or vehicles purchased by the City will comply with local, state, and federal noise standards.”
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The following are applicable goals and policies from the City of San Marcos General Plan, Noise Element (City of San Marcos 2012):
• Goal N-1: Promote a pattern of land uses compatible with current and future noise levels. o 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. o Policy N-1.2: Ensure that acceptable noise levels are maintained near noise-sensitive uses. o 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. o 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.
o 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.
o Policy N -2.1: Encourage only noise -compatible land uses along existing and future roadways, highways, and freeways.
o Policy N-2.2: Promote coordinated site planning and traffic control measures that reduce traffic noise on noise-sensitive land uses.
o 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 sources on noise sensitive land uses.
o Policy N-3.1: When adjacent to noise sensitive receptors, require developers and contractors to employ noise reduction techniques during construction and maintenance operations. o Policy N-3.2: Limit the hours of construction and maintenance operations located adjacent to noise-sensitive land uses.
The following are applicable goals and policies from the City of San Marcos General Plan, Safety Element:
• Goal S-7: Comply with the McClellan-Palomar Airport Land Use Compatibility Plan.
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o 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 [Airport Land Use Compatibility Plan].
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.
3.11.3 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 #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 #2: Generation of excessive groundborne vibration or groundborne noise levels. • Threshold #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 2 miles of a public airport or public use airport, expose 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’s construction noise threshold of not exceeding 75 dBA for an 8-hour period, between 7:00 a.m. and 7:00 p.m., when measured at any occupied property where the noise is being received. • 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 project were 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 project exceeded 65 dBA hourly Leq at the property line from 7:00 a.m. to 10:00 p.m., and 55 dBA hourly L eq from 10:00 p.m. to 7:00 a.m.
• Construction vibration – A variety of thresholds are utilized herein for purposes of impact significance assessment:
o Guidance from Caltrans indicates that a vibration velocity level of 0.2 ips PPV received at a structure would be considered annoying by occupants within residential buildings
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(Caltrans 2020), which for purposes of this analysis would apply during normal daytime hours. For occupants of office buildings, the criterion would be 80 VdB; and for occupants of workshops (or comparable uses, such as factories), the criterion would be 86 VdB. Both of these non-residential receiving land use types presume occupants only during normal daytime business hours.
o If construction activity needed to occur during nighttime hours, such as to accommodate a concrete pour or other activity for which the City may permit at its discretion, for purposes of residential building occupant annoyance during such times (i.e., when occupants would normally be sleeping) an FTA guidance threshold of 78 VdB (or 0.033 ips PPV) would be applied.
o For typical receiving residential structures, aforementioned Caltrans guidance from Section 3.11.2, Regulatory Setting, recommends that a vibration level of 0.2 ips PPV would represent the threshold for building damage risk. For commercial and industrial buildings having more robust structure, Caltrans guidance recommends a threshold of
0.3 ips PPV.
3.11.4 Project Impact Analysis
Threshold #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, varying 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 constru ction would include, in part, graders, scrapers, backhoes, rubber-tired dozers, loaders, cranes, forklifts, cement mixers, pavers, rollers, and air compressors. The typical maximum noise levels for various pieces of construction equipment at a distance of 50 feet are presented in Table 3.11 -4. Usually, construction equipment operates in alternating cycles of full power and low power, which the Federal Highway Administration Roadway Construction Noise Model User’s Guide (FHWA 2006) characterizes as “acoustical usage factor” (AUF) and thereby produces energy -average noise levels over time (L eq) that are less than the listed maximum noise level (L max). The average sound level of construction activity also depends on the amount of time that the equipment actually operates on site.
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Table 3.11-4
Typical Construction Equipment Maximum Noise Levels
FHWA RCNM Equipment Type
Acoustical Usage
Factor (percent)
Typical Equipment Lmax
(dBA at 50 Feet)
Typical Equipment Leq
(dBA at 50 Feet)
All other equipment >5
horsepower
50 85 82
Backhoe 40 78 74
Compressor (air) 40 78 74
Concrete mixer truck 40 79 75
Crane 16 81 73
Dozer 40 82 78
Generator 50 72 69
Grader 40 85 81
Man lift 20 75 68
Paver 50 77 74
Roller 20 80 73
Scraper 40 84 80
Welder / torch 40 73 69
Source: FHWA 2006.
Note: FHWA = Federal Highway Administration; RCNM = Roadway Construction Noise Model; Lmax = maximum sound level; where Leq = energy-equivalent sound level and can be calculated here with Leq = Lmax + 10*LOG(AUF); dBA = A-weighted decibels.
Aggregate noise emission from project construction activities, broken down by sequential phase, was predicted at the closest distance between the project construction zone and the nearest occupied building—consistent with the City’s adoption of the County of San Diego construction noise standard.
In a manner comparable to the “general assessment” technique per FTA guidance (FTA 2018), and because the exact positions of on-site equipment activity vary over the course of a typical construction day, all construction equipment for a given phase were treated as emitting noise from a common origin point located at the geographic “acoustic centroid” of the project site. For purposes of this analysis, two noise source-to-receptor distance values were studied as follows:
• With respect to the existing Hughes Circuits buildings on the south side of South Pacific Street, the acoustical centroid of the project site appears to be approximately 275 feet from the nearest existing building facade.
• To the north of the project is an occupied commercial structure, apparently 345 feet from the project acoustical centroid.
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 structure. (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
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are often used for other types of construction.) Input variables for the predictive modeling consist of the equipment type and number of each, the afore -mentioned acoustical usage factor, the expected duration (in hours) of on -site activity, and the distance from the receiver. Conservatively, no topographical or structural shielding was assumed in the modeling. Appendix G presents these input parameters that yield the summarized prediction results presented in Table 3.11-5.
Table 3.11-5
Predicted Construction Noise Levels per Activity Phase
Construction Phase (and Equipment Types Involved)
8-Hour Leq at Nearest
Existing Hughes
Circuits Building (dBA)
8-Hour Leq at Northern
Off-Site Occupied
Structure (dBA)
Site preparation (scraper, backhoe, grader) 64.8 62.6
Grading (grader, dozer, backhoe) 64.5 62.3
Building construction (crane, man-lift, generator,
backhoe, welder/torch)
59.9 57.7
Architectural finishes (air compressor) 53.6 51.4
Paving (paver, roller, concrete mixer truck, backhoe,
other equipment)
65.3 63.1
Notes: Leq = equivalent noise level; dBA = A-weighted decibels.
As presented in Table 3.11 -5, the estimated construction noise exposure levels for each of the five expected sequential phases are not predicted to exceed 75 dBA L eq over an 8 -hour period at the nearest occupied properties to the north and south of the project site. The predicted construction noise levels ranging from 54 to 65 dBA L eq over an 8 -hour period at the nearest Hughes Circuits existing building façade are also comparable to (or less than) the measured baseline outdoor sound level of 64 dBA at surv ey position “ST2” shown in Table 3.11 -2. For these reasons, temporary construction - related noise impacts would be considered less than significant.
Long-Term Operational Noise
Increase of Off-Site Roadway Traffic Noise
The project would result in the creation of additional vehicle trips on local roadways (i.e., Linda Vista Drive and South Pacific Street), which could result in increased traffic noise levels at adjacent noise - sensitive land uses. Appendix C, Traffic Noise Modeling Input and Output, of Appendix G contains a set of Federal Highway Administration Traffic Noise Model (version 2.5 ) ( FHWA 2004) input/output spreadsheets showing studied traffic volume data (average daily traffic expressed as vehicles per hour) for the existing and existing-plus-project modeled scenarios. Information used in the Traffic Noise Model included the roadway geometry and posted traffic speeds.
According to acoustical principles, the increase in traffic noise level relates directly to the increase in volumes by the following expression: 10*LOG(V f/Ve), where V f is the future traffic volume, V e is the
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existing traffic volume, and vehicle speeds and proportion of vehicle types are essentially unchanged.
The project would therefore have to roughly double the traffic volumes on nearby studied roadway segments in order to increase traffic noise by 3 dB, which would be considered a barely perceptible increase (Caltrans 2013).
Traffic noise levels were modeled at the same geographic positions ST1, ST2, and ST3 as shown in Figure 3.11-1. The receivers were modeled to be 5 feet above the local ground elevation. The traffic noise model results are summarized in Table 3.11-6 and represented by CNEL values. The predicted CNEL values for existing conditions shown in Table 3.11-6 for ST1 and ST3 are each within +/-3 dB of the measurement-based CNEL (approximated by the daytime Leq value samples, per FTA guidance [FTA 2018]) listed in Ta ble 3.11 -2, which suggests good agreement between empirical data and the estimation model, since a 3 dB difference is barely perceptible to human hearing outdoors. Validated by this value agreement for existing conditions, the same Traffic Noise Model was used to predict the future “existing plus project” traffic noise level associated with the studied project-attributed changes to local roadway traffic.
Table 3.11-6
Off-Site Roadway Traffic Noise Modeling Results
Modeled Receiver Tag (and Location Description)
Existing (2022)
Noise Level
(dBA CNEL)
Existing Plus
Project Noise
Level
(dBA CNEL)
Project-Related
Noise Level
Increase (dB)
ST1 (Tennis and basketball courts near 501 Beverly
Place)
44.1 44.4 0.3
ST2 (542 S. Pacific Street [Hughes Circuits existing
facility])
57.1 57.8 0.7
ST3 (Bradley Park baseball diamond across from
1520 Linda Vista Drive)
64.0 64.0 < 0.1
Notes: dBA = A-weighted decibel; CNEL = Community Noise Equivalent Level; dB = decibel.
Table 3.11-6 shows that at all three listed representative receivers, with particular attention to ST1 that adjoins noise -sensitive residential receptors, the addition of project traffic to the local roadway network would result in a CNEL increase of less than 1 dB, which is below the discernible level of change for the average healthy human ear. Thus, a less-than-significant impact is expected for project- related off-site traffic noise increases affecting existing residences in the vicinity.
Stationary Project Operations Noise
The completion of a new light industrial building on the project site will add a variety of noise-producing mechanical equipment that include those presented and discussed in the following paragraphs. Most of these noise -producing equipment or sound sources would be considered stationary, or limited in mobility t o a defined area. Using a Microsoft Excel –based outdoor sound propagation prediction
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model, project-attributed operational noise at nearby community receptors was predicted on the assumption that noise -producing equipment are point -type sources with point -source geometric divergence (i.e., 6 dB noise reduction per doubling of distance) that conservatively ignores acoustical absorption from atmospheric and ground surface effects. Please see Appendix G for quantitative details of the modeling inputs.
The project building would be served by air -conditioning equipment that includes outdoor -exposed packaged air -handling units or —at a minimum —air-cooled condensers that provide the expected cooling demand (expressed as refrigeration “tonnage”) for the building. For a building of 67,410 total square feet that could be described as largely having a “factory -assembly area” intended interior usage, this cooling demand can be estimated with industry check figures (Loren Cook 1999).
Based on the available architec t plans of the project, the roof deck is expected to be 43 feet above grade and would feature a typical parapet (assumed to be 3 feet in height, measured from its top edge to the roof deck). The roof plan depicts two potential air-cooled condenser equipment locations, which this analysis will treat as two point -source positions for rooftop noise emission behind the aforesaid parapet.
The operation noise model also includes noise emission from the idling engine of a single truck parked along the north façade of the project building. For this assessment, the analysis conservatively assumes that over the course of an hour on site, an average of one truck would be present and idling for up to 5 minutes as allowed by California emission regulations. This noise emission contributor, described as a point-type source, was also considered a point-type source.
Sound propagation from these two rooftop HVAC noise emission sources and the idling truck engine near grade was predictively modeled with a three-dimensional technique based on pertinent ISO 9613- 2 algorithms and reference data. Assuming all the HVAC equipment is operating simultaneously for a minimum period of 1 hour, the predicted noise levels at each of three afore -studied locations are as follows: ST1 = 32.4 dBA, ST2 = 42.5 dBA, and ST3 = 33.1 dBA. These predicted levels are all less than the City’s exterior noise limits per Table 3.11-3. Figure 3.11-2 displays predicted operation noise levels across a horizontal plane 5 feet above grade, and visually helps support the assertion of compliance with City standards. Hence, under such conditions, predicted project stationary noise source emission would result in a less-than-significant noise impact.
Threshold #2: Would the project result in the generation of excessive groundborne vibration or groundborne noise levels?
Construction activities may expose persons to excessive groundborne vibration or groundborne noise, causing a potentially significant impact. Caltrans has collected groundborne vibration information related to construction activities (Caltrans 2020). Information from Caltrans indicates that continuous vibrations with a PPV of approximately 0.2 ips generates a human response of annoyance. For context,
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heavier pieces of construction equipment, such as a bulldozer that may be expected on the project site, have peak particle velocities of approximately 0.089 ips or less at a reference distance of 25 feet (FTA 2018).
Groundborne vibration attenuates rapidly, even over short distances. 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 gui dance. By way of example, for a vibratory roller operating on site and as close as the southern project boundary (i.e., 65 feet from the nearest occupied building) when involved in the paving phase of project construction, the estimated vibration velocity level would be 0.05 ips PPV per the equation as follows (FTA 2018):
PPVrcvr = PPVref * (25/D)^1.5 = 0.05 = 0.21 * (25/65)^1.5 In the above equation, PPV rcvr is the predicted vibration velocity at the receiver position, PPV ref is the reference value at 25 feet from the vibration source (the roller), and D is the actual horizontal distance to the receiver. For purposes of assessing building damage risk, this estimated 0.05 ips PPV at the nearest commercial structure would be les s than the 0.3 ips PPV limit for commercial buildings as presented in the preceding Section 3.11.3 , Thresholds of Significance . Because the predicted vibration level at 65 feet is less than this guidance criterion, the risk of vibration damage to such nearby structures is considered less than significant.
To assess human annoyance for occupants of these nearest buildings, in which office functions are assumed, this 0.05 ips PPV value can be converted to an RMS -based Lv decibel value (VdB) per the following expression:
Lv = 20 * LOG(PPVrcvr/(4*Vref)) = 20 * LOG(0.05/0.000004) = 82 VdB In the above expression, V ref is reference vibration amplitude of 1 micro-inch per second, and it is multiplied by a “crest factor” of 4 per FTA guidance (FTA 2018). The calculated RMS vibration velocity of 82 VdB is what impinges upon the foundation of the receiving building, after being attenuated via groundborne propag ation through intervening soils and rock strata as estimated by the previous expression to calculate PPV exposure at the receptor distance from the source. Then, at the interface of the rec eiving building foundation, there is an additional “coupling loss” relating to further energy dissipation as the vibration transfers to the mass and form of the building foundation and connected structure. According to FTA guidance, this coupling loss is -5 VdB for wood-framed houses, -7 VdB for 1-to-2-story masonry structures, and -10 dB for 3-to-4-story masonry buildings (FTA 2018). Hence, with the receiving commercial building to the south being a representative of at least this one- to two-story masonry type, the predicted vibration velocity exposure to office occupants would only be 75 VdB (i.e., the difference of 7 from 82) and thus compliant with the afore -stated Caltrans-based guidance threshold of 80 VdB per Section 3.11.3. Therefore, the potential impact on nearby commercial building occupants would be considered less than significant.
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Residential buildings are much further from the project site than the buildings on these nearby commercial land uses, so their exposures to potential groundborne project -attributed construction vibration would be much less than the 0.05 ips PPV and 82 VdB values discussed in the preceding paragraphs. For example, the closest multifamily residences near ST1 are over 450 feet from the project boundary, which means the calculated PPV at this distance from a vibratory roller would
0.003 ips and yield only 57 VdB. Hence, daytime (or potential nighttime) vibration impacts at nearest receiving off-site residential buildings and their occupants would be less than significant.
Once operational, the project would not be expected to feature major producers of groundborne vibration. Anticipated mechanical systems like heating, ventilation, and air -conditioning units are designed and manufactured to feature rotating (fans, motors) a nd reciprocating (compressors) components that are well-balanced with isolated vibration within or external to the equipment casings.
On this basis, potential vibration impacts due to project operation would be less than significant.
Threshold #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 is the McClellan Palomar Airport, approximately 4 miles west of the site. According to the Comprehensive Land Use for McClellan-Palomar Airport (SDCRAA 2011) the project site is not located within a noise exposure contour and would therefore not expose people residing or working in the project area to excessive noise levels. Impacts from aviation overflight noise exposure would be less than significant.
3.11.5 Cumulative Impact Analysis
Noise levels tend to diminish quickly with distance from a source. Therefore, the 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 Impact Analysis, above, project implementation would result in less than significant noise impacts. No mitigation is required.
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, included 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 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, design 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.
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3.11.6 Mitigation Measures
As analyzed in Section 3.11.4 above, potential noise impacts during construction and operation of the project would be less than significant. No mitigation is required.
3.11.7 Conclusion
As discussed above, potential noise impacts during construction would be less than significant. Noise impacts due to operation of the project would be less than significant and no further mitigation is required. Project impacts related to noise would be less than significant.
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Baseline Outdoor Ambient Sound Level Measurement Positions Hughes Circuits Project Environmental Impact Report
SOURCE: SANGIS 2019
0 500 250
Feet
Project Boundary
Short Term Noise Measurement Locations
FIGURE 3.11-1
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Hughes Circuits Project (Project No.: 13383)
Predicted Stationary Source Operations Noise - with Idling Truck SOURCE: Dudek 2022
0 189 378 Feet
FIGURE 3
Color High Low
85 80
80 75
75 70
70 65
65 60
60 55
55 50
50 45
45 40
40 35
dBA range
Predicted Aggregate Hourly
Sound Pressure Level (SPL)
STX = Studied Offsite Receptor
Idling Truck
(up to 5 minutes within an hour)
Rooftop HVAC Units
(continuous for full hour)
ST3
ST1
ST2
Predicted Stationary Source Operations Noise – with Idling Truck Hughes Circuits Project Environmental Impact Report
FIGURE 3.11-2
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3.12 Population and Housing
Hughes Circuits Project Environmental Impact Report March 2024 City of San Marcos 3.12-1
3.12 POPULATION AND HOUSING
This section describes the existing setting of the proposed Hughes Circuits 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.
Tab le 3.12 -1
Population and Housing Summary of Impacts
Threshold of Significance
Project Direct
Impact
Project Cumulative
Impact
Significance
Determination
#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
#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’s Housing Element (20 21–2029), adopted July 13, 2021 .
Currently, the project site is undeveloped, and does not support residential uses as it is zoned for industrial uses . During site surveys, a homeless encampment was observed in the bushes on the northwestern portion of the project site.
Population
According to the City of San Marcos General Plan Housing Element, San Marcos has been one of the fastest growing cities in the San Diego region since the 1980s (City of San Marcos 20 21). As of 2020, the City of San Marcos has an estimated population of 97,209 , an increase of approximately 16% since 2010 (City of San Marcos 2021 ). Based on growth projections provided by the Series 1 4: 2050 Regional Growth Forecast prepared by SANDAG, it is estimated that the City’s population growth will reach 104,365 persons by 2035 , and 119,098 persons by 2050 (SANDAG 2021).
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The City’s growth has outpaced 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 (City of San Marcos 2021) .
Housing
As of 2022, the City of San Marcos had 32,000 housing units. The housing stock is comp osed of approximately 58.69% single-family detached and attached units, and approximately 31 .16% multifamily units (DOF 202 2). Approximately 10.15% of the housing stock as of 2022 consisted of mobile homes (DOF 2022). Based on the Series 1 4: 2050 Regional Growth Forecast, the City is expected to have 36,113 housing units by 2035, and 42,050 housing units by 2050 (SANDAG 20 21).
According to the Series 14: 2050 Regional Growth Forecast , between 201 6 and 2050 the City of San Marcos is expected to see an increase of 26.4% in housing stock. In comparison, the region is expected to grow by 13.2% between 2016 and 2050 .
3.12 .2 Regulatory Setting
This section describes the local regulatory setting as it relates to population and housing for the 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 (Sections 65000 through 66499.58 of the California Government Code). Under that law, each c ounty 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 mand atory 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 measure s.
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 frequently reviews 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 cont ains 11 parts: Electrical Code, Plumbing
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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 a nd ensure that safe and decent housing is constructed in the County’s unincorporated areas.
Senate Bill 375
Senate Bill 375 (codified in the Government Code and 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. Senate Bill 375 requires metropolitan planning organizations to incorporate a Sustainable Communities Strategy (SCS) 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 Regional Housing Needs Assessment (RHNA) is mandated by State Housing Law as part of the periodic process of updating local housing elements of the General Plan. The RHNA quantifies the need for housing within each jurisdiction during specified planning pe riods.
Communities use the RHNA in land use planning, prioritizing local resource allocation, and in 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, promotes transportation mobility, and addresses social equity, 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, which 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,
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mixed-use development in urbanized communities that already have existing and planned infrastructure, and then connecting those communities with a variety of transportation choices.
In 2011, SANDAG approved the 2050 Regional Transportation Plan and Sustainable Communities Strategy (RTP/SCS) (SANDAG 2011) . This approval marked the first time SANDAG’s RTP included a sustainable communities strategy, 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 the 2008 Sustainable Communities and Climate Protection Act. In 2010, CARB established targets for each region in Californ ia 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 a nd other metropolitan planning organizations are required to develop a n SCS as an element of its RTP. The SANDAG SCS integrates land use and transportation plans to achieve reductions in greenhouse gas emissions and meet the CARB -required targets.
San Diego Forward: The Regional Plan
SANDAG’s San Diego Forward: The Regional Plan (Regional Plan) combines the region’s two most important existing planning documents —the Regional Comprehensive Plan and the RTP/SCS. The Regional Comprehensive Plan, adopted in 2004, laid out key principles for managing the region’s growth while preservin g 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 RTP/SCS 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. The 2021 Regional Plan combines the RTP, SCS, and Region al Comprehensive Plan. As such, the 2021 Regional Plan must comply with specific state and feral mandates. These include an SCS, per California Senate Bill 375, that achieves greenhouse gas emissions reduction targets set by the California Air Resources Bo ard, compliance with federal civil rights requirements (Title VI); environmental justice considerations; air quality conformity; and public participation (SANDAG 2021).
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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. SANDAG accepted the Series 1 4:
2050 Regional Growth Forecast in 2021 (SANDAG 2021) . This forecast serves as the foundation for San Diego Forward: The Regional Plan and other planning documents across the region . SANDAG growth projections for the region and for the City of San Marcos are outlined in Table 3 .12-2, Forecasted Growth in the San Diego Region and the City of San Marcos . The City of San Marcos is expected to experience a higher growth rate for population, housing, and employment when compared to the entire region of San Diego. The 2050 Regional Growth Forecast is not intended to be an exact formula utilized to determine growth in the region and comprising jurisdictions; rather , it should be used 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 6–2050
2016 2025 2035 2050 Numeric Percent
Population
San Diego
Regional
3,309,510 3,470,838 3,620,329 3,746,054 436,544 13.2
City of San Marcos 94,258 101,707 104,365 119,098 24,840 26.4 Housing
San Diego
Regional
1,190,555 1,288,207 1,409,853 1,471,286 280,731 23.6
City of San Marcos 30,539 34,250 36,113 42,050 11,511 37.7 Employment
San Diego
Regional
1,629,948 1,788,970 1,935,565 2,094,017 464,069 28.5
City of San Marcos 41,096 45,786 51,523 63,031 21,935 53.4 Source: SANDAG 2021.
Regional Housing Needs Assessment
The Regional Housing Needs Assessment 6th Housing Element Cycle, 2021 –2029, was approved on July 10, 2020 (SANDAG 2020). Based on a methodology that weighs a number of factors (i.e., projected population growth, employment, commute patterns, and available sites), SANDAG determined quantifiable needs for housing units in the region according to various income categories.
In its final RHNA 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).
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Local
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 2021–2029 planning period. The following goals and policies from the Housing Element of the City of San Marcos General Plan pertain to population and housing (City of San Marcos 20 21):
• Goal H -1: Provide a broad range of housing opportunities with emphasis on providing housing which meets the special needs of the community.
o 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 concentrati ons of employment opportunities.
• Goal H -2: Protect, encourage, and provide housing opportunities for persons of lower and moderate incomes.
• Goal H -4: Reduce or remove governmental and nongovernmental constraints to the development, improvement, and maintenance of housing where feasible and legally permissible. o Policy 4.4: Balance the need to protect and preserve the natural environment with the need to provide housing and employment opportunities.
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 #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).
• Threshold #2: Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.
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3.12 .4 Project Impact Analysis
Threshold #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, Project Description, the project consists of development of a 67,410 -square- foot light industrial building on approximately 2.6 1 acres of the 10.46 -acre project site. The project would require a temporary construction workforce and a permanent operational workforce, both of which could potentially induce population growth in the project area. The temporary workforce would be needed to construct the light industrial building. The number of construction workers needed during any given period would largely depend on the specific stage of construction, but would likely range from a dozen to several dozen workers on a daily basis.
The project is proposed to support the expansion of the existing operations of Hughes Circuits Inc., currently located adjacent to the project site to the south, at 546 S. Pacific Street. As such, the project’s temporary and permanent employment requirements could likely be met by the City’s existing labor force without people needing to relocate into the project region, and the project would not stimulate population growth or a population concentration above what is assumed in local and regional land use plans.
As discussed above , the City of San Marcos is forecasted to grow from 94,258 persons in 20 16 to 119,098 persons in 205 0, which is a population increase of 24,840 (SANDAG 2021). As such, the project-related increase of approximately 60 employees would represent a nominal percentage of the City’s projected future populatio n.
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 an d services are, or will be, provided to serve future residential development anticipated by the RHNA.
As the project would be required to comply with City regulations and applicable fees outlined above, impacts associated with the project are determined to be less than significant .
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Thresholds #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. Although a homeless encampment is present on the project site, it cannot be determined how many individuals would be located on the project site at the time of project construction due to the transient nature of these individuals. Since there is no existing housing on the project site, it is not necessary to construct replacement housing elsewhere.
Implementation of the project would not displace any existing housing or people or necessitate the construction of replacement housing elsewhere. Therefore, there would be no impact.
3.12.5 Cumulative Impact Analysis
Cumulative projects in addition to the project could result in both direct and indirect cumulative impacts to population and housing in the City . Projects 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 residential, non -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 population 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 housing, and wou ld be subject to applicable development fees. Compliance with City regulations and fees would ensure that cumulative impacts related to population and housing are ad equately addressed.
As discussed above, the project would not generate a permanent increase in population within the project areas, and the approximately 60 employees generated by the project is consistent with anticipated future employment projections within the City. Overall, the project would not induce substantial unplanned population growth in the City, and would have a less than significant cumulative impact to population and housing.
3.12 .6 Mitigation Measures
No significant impacts are identified; therefore, no mitigation measures are required.
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3.12 .7 Conclusion
The project is proposed to support the expansion of the existing operations of Hughes Circuits Inc., currently located adjacent to the project site to the south, at 546 S. Pacific Street. As such, the project’s temporary and permanent employment requirements could likely be met by the City’s existing labor force without people needing to relocate into the project region, and the project would not stimulate population growth or a population concentration above what is assumed in local and regional land use plans.
The project would be required to comply with goals and policies outlined in the City’s Housing Element and applicable City regulations and applicable fees as outlined above. 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. Therefore, there would be no impact .
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3.13 PUBLIC SERVICES
This section describes the existing setting of the Hughes Circuits Project ( project) site, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to public services, including fire protection services, police protection services, schools, parks, and libraries. This section incorporates information from the Fire and Medical Response Analysis prepared for the project (by Dudek in January 2023 ), and is included as Appendix H to this environmental impact report (EIR).
Table 3.13 -1, Public Services Summary of Impacts, 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 Direct Impact Project Cumulative Impact Significance
Determination
#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:
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 No Impact No Impact No Impact
Parks No Impact No Impact No Impact
Other public facilities No Impact No Impact No Impact
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 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. While the San Marcos Fire Protection District provides primary service to the City of San Marcos (City), the San Marcos Fire Protection District also has an existing automatic mutual aid fire agreement in place with the cities of Carlsbad, Vista, Escondido, Encinitas, and the Rancho Santa Fe Fire Protection District.
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
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California/Office of Emergency Services wildland fire engine (City of San Marcos 2022a). The SMFD Station 2, located at 1250 S Rancho Santa Fe Road, San Marcos, CA 92078, is the closest station to the project site and would likely serve the project site should fire response or emergency services be needed. SMFD Station 2 is located approximat ely 1.3 miles southwest, or 5 minutes away, from the project site. SMFD Station 2 houses one paramedic engine company and one paramedic ambulance in addition to fire response service equipment (City of San Marcos 2022b).
Police Protection
According to the City’s General Plan – Land Use and Community Design Element, the City contracts their law enforcement services from the San Diego 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 2012 a). This sheriff station is located approximately 4 miles east, or 9 minutes, from the project site.
The sheriff’s San Marcos Station 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 n.d.). Law enfo rcement 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 over 100 deputies, volunteers, and professional staff members (SDCSD n.d.). Additionally, Community Oriented Police and Problem Solving (COPPS) teams are assigned to investigate community quality of life issues (SDCSD n.d.). Lastly, the Sheriff’s San Marcos Station has the only ASTREA (Sheriff’s Aviation) landing pad in the County, providing assistance to ground units and extending the range deputies can patrol (SDCSD n.d.).
The San Diego 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 t o 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 by the San Marcos Unified School District (SMUSD) (City of San Marcos 2012a). The SMUSD is approximately 44 square miles and encompasses the City of San Marcos, portions of the cities of Carlsbad, Escondido, Vista, and unincorporated areas of San Diego County
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lying between these cities (SMUSD 2021). As of 2021, there were ten elementary schools, one K –8 school, one K–8 International Baccalaureate World School, three middle schools, two comprehensive high schools, and two alternative high school program s that are a part of the SMUSD. There are currently 19,767 students enrolled in the SMUSD (SMUSD 2021).
Parks
The purpose of the City’s Parks, Recreation, and 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).
There are 16 major community parks and 18 mini parks located throughout the City. The City residents in the project area are currently served by several nearby parks. Specifically, t he closest park to the project site is Bradley Park located at 1587 Linda Vista Drive, which is adjacent to the project site to the west. Bradley Park consists of lighted soccer fields, ball fields, picnic tables, picnic shelters, a turf play area, a tot-lot, an on-site caretaker, and horseshoe courts (City of San Marcos 2012b).
Other nearby parks include Mission Sports Park, located 1 mile northeast of the project site, Innovation Park, located approximately 1 mile northeast of the project site, and Sunset Park, located approximately 1 mile northwest of the project site.
Refer to Section 3.14, Recreation, for a more in-depth discussion of existing park and recreation facilities.
Libraries
The City is served by the San Diego County Library, San Marcos Branch located at 2 Civic Center Drive, approximately 2.3 miles east of the project site (City of San Marcos 2022c). The San Marcos Branch is 15,394 square feet (City of San Marcos 2012a), and contains a MakerBot 3D printer, a 28-person capacity meeting room, is Americans with Disabilities Act (ADA) accessible, and is open 7 days a week (San Diego County Library 2022).
3.13.2 Regulatory Setting
This section provides an overview of the applicable state and local regulations governing public services.
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State
Quimby 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 improvements. Reve nues 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 and Office of the State Fire Marshal provides regulations and guidance for local agencies in the development and enforcement of fire safety standards. The California Fire Code 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 Facilities 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. Payment of 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 cost impacts associated with new developments, which result primarily from costs of additional facilities, related furnishings and equipment, and projected capital maintenance requireme nts. 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
City’s Municipal Code Chapter 17.36 – Park and Recreational Development Construction Unit Fee The City’s Municipal Code 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 towards the City for the planning, acquisition, improvement, expansion and operation of public parks, playgrounds, and recreational facilities to help mitigate the potential impacts on recreational facilities due to population increases (City of San Marcos 2022d). The payment of fees shall be collected prior to the issuance of building permit by the City.
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City’s Municipal Code Chapter 17.44 – Development Services and Public Facilities Exactions, Fees and/or Costs
The City’s Municipal Code Chapter 17.44, Development Services and Public Facilities Exactions, Fees and/or Costs, describes the payment of fees towards 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 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 2022d).
City’s Municipal Code Chapter 17.52 – School Fees and Land Dedication The City’s Municipal Code 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 2022d).
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 purpose 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 will be limited to the needs of the community for interim elementary, junior high or high school facilities and shall be rea sonably 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.
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City of San Marcos General Plan
Land Use and Community Design Element
The following are applicable goals and policies from the City of San Marcos 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.
o Policy LU-8.1: New development shall pay its fair share of required improvements to public facilities and services.
o 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.
o 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. o Policy LU-10.2: Work closely with the County of San Diego Sherriff’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. o Policy LU-10.3: Continue to conduct Public Outreach and education regarding fire safety and crime prevention within San Marcos.
Safety Element
The following are applicable goals and policies from the City of San 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.
o 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.
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o 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.
o 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. o 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. o Policy S-6.1: Continue to maintain demand-based law enforcement service levels to reduce the risk of criminal activity.
o Policy S-6.2: Continue public education efforts and community outreach programs to promote community involvement in crime and drug prevention. o 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 of San Marcos General Plan, Parks, 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. o 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.
o 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. o 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.
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o 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.
o Policy PR-1.6: Require new infill development to provide plazas, mini parks, or other civic spaces as part of their parkland requirement.
o 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 3.10.4, 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 Appendix 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 #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:
o Fire protection
o Police protection
o Schools
o Parks
o Other public facilities
3.13.4 Project Impact Analysis
Threshold #1: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause si gnificant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
Fire protection?
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According to the City’s General Plan Safety Element, a 3-mile distance between fire stations is sufficient to achieve response time objectives (City of San Marcos 2012c). Based on the proximity of the project site to the existing SMFD facilities, the average response times in the project area, and the fact that the project site is already located within SMFD’s service area, the project could be adequately served by the SMFD without the construction of new, or the expansion of existing, facilities.
In addition, as previously analyzed in Section 3.12, Population and Housing, the project would not directly or indirectly induce unplanned population growth in the City. Although the project could potentially result in an incremental increase in calls for service to the project site compared to existing conditions, this increase is expected to be nominal (as opposed to new residential or commercial/retail land uses, which do result in greater increase in calls for service) and would not result in the need for new fire protection facilities. Overall, it is anticipated that the project would be adequately served by existing SMFD facilities, equipment, and personnel.
However, the project would be required to comply with SMFD and California Fire Code 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 City’s Municipal Code. Pay ment of the Development Services Fees go towards City services, which include the Fire Protection District, to ensure adequate fire protection facilities are provided.
A Fire Service Response Analysis prepared for the project (Appendix H) determined that SMFD could provide emergency response to the project site within its internal 7-minute response time from SMFD Station 2. Based on the conservative modeling in this anal ysis 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 2 would be able to adequately respond within the City’s response time standard.
For the reasons stated above, it is determined that potential impacts to fire protection as a result of the project would be less than significant.
Police protection?
As previously addressed, the project would not directly or indirectly induce unplanned population growth in the City. Although the project could potentially result in a slight incremental increase in calls for service to the project site compared to existing conditions, this increase is expected to be nominal (as opposed to new residential or commercial/retail land uses, which do result in greater increase in calls for service) and would not result in the need for new police protection facilities. Overall, it is anticipated that the project would be adequately served by existing police department facilities, equipment, and personnel.
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Additionally, the project would be required to comply with the City’s Development Services Fees outlined in Section 17.44.030 of the City’s Municipal Code. 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 protection resulting from the project would be less than significant.
Schools?
As previously discussed, the project would not directly or indirectly induce unplanned population growth in the City. Although the project would require employees to construct and operate the project, these short-term and long-term employees would likely already reside within the broader project area.
As such, it is not anticipated that many people would relocate to the City as a result of the project, and an increase in school-age children requiring public education is not expected to occur as a result.
Similar to other development projects in the City, the project would be subject to SB 50, which requires payment of mandatory impact fees to offset any impact to school services or facilities. The provisions of S B 50 are deemed to provide full and complete mitigation of school facilities impacts, notwithstanding any contrary provisions in CEQA or other state or local laws (Government Code Section 65996). In accordance with SB 50, the project Applicant would pay its fair share of impact fees based on the pro ject’s square footage per Government Code Section 65995(h). These impact fees are required of most residential, commercial, and industrial development projects in the City.
As such, with contribution of required development fees, no impacts to schools as a result of the project would occur.
Parks?
The project would construct a light industrial building in the City. The project does not propose any residential uses, and would not directly or indirectly induce unplanned population growth in the City.
As such, the project would not increase the use of existing neighborhood parks or regional parks in the City and surrounding area.
The project would be required to pay the City’s Public Facility Fees (PFF s), which is 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. Therefore, with payment of applicable fees, no impacts related to the use of park facilities would occur. Further details regarding parks and recreation can be found in Section 3.14.
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Other public facilities?
Given the industrial nature of the project and the lack of population growth that would result from the project, it is unlikely that the project would increase the use of libraries and other public facilities.
Therefore, no impacts to other public facilities in the City as a result of the project would occur.
3.13.5 Cumulative Impact Analysis
A cumulative impact refers to two or more individual effects that, when considered together, are considerable or that 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 (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, region al, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the project’s cumulative impact with respect to public services, the cumulative analysis is based upon a list a pproach to determine the project’s contributing effect on potential cumulative impacts related to public services (see Table 2-1, Cumulative Projects).
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 San Marcos Fire Protection District. The cumulative projects that fall within this geographic area would add to the increase in demand for fire protection and emergency services. The San Marcos Fire Protection District provides service to the City of San Marcos 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.
As discussed in Section 3.13.4, Project Impact Analysis, above, the project could potentially result in an incremental increase in calls for service to the project site compared to existing conditions, this increase is expected to be nominal (as opposed to new residential or commercial/retail land uses, which do result in greater increase in calls for service). 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 2 , which w ould serve the project site.
However, similar to the project, cumulative projects would be required to comply with SMFD and California Fire Code 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 City’s Municipal Code. Payment of the Development Services Fees fund City services, which include the Fire Protection District.
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Therefore, the project would not result in substantial adverse physical impacts associated with the provision of new or physically altered facilities. Cumulative projects are anticipated to prepare similar analyses and provide mitigation if the response time cannot be met. Therefore, it is determined that 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 increase in 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, cumulative projects could result in additional demand of 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 towards City services, which include 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 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 San Marcos Unified School District, 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. SB 50 states that the fees imposed by school distr icts 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, no cumulative impacts to schools would occur.
Parks
As discussed in Section 3.13.4 , the project developer/applicant would be required to pay the City’s PFF, required to 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
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fees. With payment into the City’s PFF and dedication of open space , no cumulative impacts on recreational facilities in the City would occur.
Libraries
Cumulative projects within the services area of the San Marcos Branch Library could potentially result in an increase in 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 CSUSM campus and the Palomar Community College. These additional library resources provide over 200,000 square feet of additional library space. Therefore, it is determined that no cumulative impacts to library facilities in the City as a result of the project would occur.
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 a light industrial building in the City. This would result in a nominal increase in 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 the City’s Municipal Code Section 17.52.050; payment towards the City’s Development Services Fees outlined in Section 17.44.030 of the City’s Municipal Code, which goes toward City services, which include the Fire and Police services; and payment of the City’s PFF required to all projects that increase the demand for park and recreation needs in the City.
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.
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INTENTIONALLY LEFT BLANK
3.14 Recreation
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3.14 RECREATION
This section describes the existing recreation setting of the Hughes Circuits Project ( project) site, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the 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
#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.
No Impact No Impact No Impact
#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.
No Impact No Impact No Impact
3.14.1 Existing Conditions
This section describes existing park, recreation facilities, and trails on the project site and in the project vicinity. The City of San Marcos (City) has over 290 acres of park land and 37 parks (City of San Marcos 2022a). The City of San Marcos’s Parks Master Plan classified parks into 8 different categories:
Regional Parks, Community Parks, Neighborhood Parks, Mini (Urban) Parks, Special Use Facilities, Historical, Monuments, and Memorials, Recreation Centers, and Aquatic Centers (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 size of 10 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,
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Discovery/Lakeview Park, and Double Peak Park. Bradley Park and Discovery/Lakeview Park would serve the project site, as the project site is located within the service area of these two parks. Bradley Park is located immediately adjacent to the project site to the west, and Discovery/Lakeview Park is located approximately 1.5 miles southeast of the project site.
Bradley Park
Bradley Park is the City’s oldest park , comprising a total of 34 acres located at the intersection of Rancho Santa Fe Road and Linda Vista Drive. It is a sports -oriented facility with 26 acres already developed, leaving a final 10 acres for future planning, design and construction. The site contains two flat areas divided by a short, steep slope. The “Upper Mesa” contains the area currently under construction for new active recreation facilities and yet to be planned acreages, whil e the already developed acreage is on the “Lower Mesa.” The existing emphasis of the park is active sports facilities.
This park is the primary site for active sports in the City. This park includes, tot lots, picnic areas, artificial turf areas and an indoor soccer arena (by permit only) (City of San Marcos 2018).
Discovery/Lakeview Park
Lakeview Park is at the corner of Foxhall and Poppy Road. Lake View Park (at Discovery Lake) is 23 acres of open space and a 5-acre lake. This park has a trail around the lake (City of San Marcos 2018).
Neighborhood Parks
Neighborhood Parks are defined as parks that are generally 5 acres, although 7 to 10 acres are 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 the City: Buelow Park, Connors Park, Hollandia Park, Innovation Park, Knob Hill Park, Jacks Pond Park, Cerros de Las 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 between 2,500 square feet and 1 acre in size, although a park area 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 in a residential setting. There are 18 Mini (Urban) Parks in the City: 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.
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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, 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 complexes, sports stadiums, skateboard parks, and bark parks.
The size and service area of a Special Use Facility varies greatly.
Historical, Monuments, and Memorials
A Historical, Monuments, and Memorials parks preserve monuments and memorials, provides programmed historic 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, 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 the residents of San Marcos.
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).
Trails
The 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 two-fold: (1) to serve as a recreational amenity and (2) provide an alternative means of circulation for non-motorized travelers through an inter -linked citywide system of trails connecting residential neighborhoods to pa rks,
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schools, colleges, stores, restaurants, movie theaters, other important destinations within the City, and with the wider regional trails system in adjacent cities.
3.14.2 Regulatory Setting
This section describes the state and local laws and regulations that are applicable to recreation and the project.
State
Quimby 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 improvements. Reve nues 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.
The Landscape and Lighting Act of 1972
The Landscape and Lighting Act of 1972 enables cities, counties and special districts to acquire land for parks, recreation and open space. A local government may also use the assessments to pay for improvements and maintenance in these areas.
The Mello-Roos Community Facilities Act
The Mello-Roos Community Facilities Act (California 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 special tax and any related bond issue requires approval by two-thirds of the district electorate.
Local
City’s Municipal Code Chapter 17.36 – Park and Recreational Development Construction Fee As described in Chapter 17.36 in the City’s Municipal Code, the continued increase in the development of dwelling units and population within the City has created the need for planning, acquisition, improvement, expansion and operation of public parks, playgrounds, recreational facilities in the City, and thus the need for additional revenues with which to finance such facilities. This chapter of the Municipal Code requires that each builder of each dwelling unit to be constructed within the City of
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San Marcos shall, prior to the construction, pay a fee, as adopted by Resolution by the City Council (City of San Marcos 2022b).
City’s 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 shall, prior to the issuance of such permit or entitlement, pay Public Facilities Fees. The funds generated by the payment of fees described Chapter 17.44 shall be deposited into separate accounts established for the purposes of maintaining, expanding, and installing public infrastructure. Such public infrastructure includes active or passive open space and parks (City of San Marcos 2022b).
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. o 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.
o 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. o 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.
o 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.
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o Policy PR-1.6: Require new infill development to provide plazas, mini parks, or other civic spaces as part of their parkland requirement.
o 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 3.10.4, Project Impact Analysis, 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 2017. The goal of the Parks Master Plan Update is to identify potential improvements 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 the City. To meet this goal, the Master Trails Plan recommends the creation of 72 miles of trails 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 2018).
3.14.3 Thresholds of Significance
The significance criteria used to evaluate the 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.
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3.14.4 Project Impact Analysis
Threshold #1: Would the project 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 ?
The project would construct a light industrial building and associated improvements. The project does not propose any residential uses, and would not directly or indirectly result in a substantial and unplanned increase in population growth within the project area. Although development of the project would employee approximately 60 people, all employees are not expected to be new to the area, nor would employees reside on site. The introduction of 60 new workers to the area is not considered substantial, and is not expected to result in substantial deterioration on existing recreational facilities within the City. As such, the project would not increase the use of existing neighborhood parks or regional parks in the City and surrounding area. In addition, as an industrial use, the project does not propose recreational facilities or require the construction or expans ion of recreational facilities.
Therefore, no impacts to existing neighborhood and regional parks would occur.
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 construct a light industrial building and associated improvements. The project would preserve 7.85 acres of the site as open space but does not propose the construction or expansion of recreational facilities. Therefore, no impacts related to the construction or expansion of recreational facilities would occur.
3.14.5 Cumulative Impact Analysis
A “cumulative impact” refers to two or more individual effects that, when considered together, are considerable or that 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 (1) a list of past, present, and probable future producing related impacts; or (2) a summary of projections contained in an adopted local, regi onal, or statewide plan, or a related planning document that describes conditions contributing to the cumulative effect. For purposes of assessing the project’s cumulative impact with respect to recreation, the cumulative analysis is based upon a list approach to determine the project’s contributing effect on potential cumulative impacts related to recreation. Cumulative projects are outlined in Table 2-1 in Chapter 2, Project Description, of this environmental impact report.
The project would not increase the demand for park and recreation facilities in the City. All cumulative projects that increase the demand for park and recreation needs would be required to provide park space and/or pay the City’s Public Facilities Fees . Furthermore, any substantial expansion or development of new recreational facilities would be subject to the appropriate CEQA environmental
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review, which would identify and address any site -specific impacts. Therefore, with payment of the City’s Public Facilities Fees and project-specific environmental review, no cumulative impacts to recreational facilities would occur.
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, above, the project would not increase the use of existing neighborhood parks or regional parks in the City and surrounding area. Therefore, no impacts related to recreation would occur.
3.15 Transportation
Hughes Circuits Project Environmental Impact Report March 2024 City of San Marcos 3.15-1
3.15 TRANSPORTATION
This section describes the transportation impact analysis for the Hughes Circuits Project ( project). It includes a description of existing traffic conditions, trip generation for the project, traffic modeling, and identification of mitigation measures. The section is based on the following technical reports prepared for the project:
• Local Transportation Analysis (LTA), prepared by CR Associates in December 2023 (included as Appendix I-1 to this environmental impact report [EIR]). • Vehicle Miles Traveled Analysis Technical Memorandum, prepared by CR Associates in December 2023 (included as Appendix I-2 to this EIR).
The traffic reports prepared for the project is consistent with the objectives and requirements of the City of San Marcos’s General Plan Mobility Element and applicable provisions of the California Environmental Quality Act (CEQA), including disclosure of project impacts in both existing and cumulative horizon years.
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
#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
#2 – Conflict or be inconsistent with CEQA
Guideline section 15064.3, subdivision (b).
Significant and
Unavoidable
Significant and
Unavoidable
Significant and
Unavoidable
#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
#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, as well as the methodology used to prepare the transportation analysis.
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Project Location
The approximately 10.46-acre project site is located in the western portion of the City of San Marcos, located at the northeast corner of South Pacific Street. South Pacific Street abuts the site’s western and southern boundaries. The project site is immediately bordered by South Pacific Street to the south and west. Adjacent land uses include industrial and mixed commercial development to the north and south, a public recreational park (Bradley Park) to the west, and undeveloped la nd to the east. The closest freeway is State Route (SR) 78, approximately 0.7 miles north of the project site.
Access to the project from the regional transportation network will be provided via California SR -78, South Rancho Santa Fe Road, Linda Vista Drive, South Pacific Street, South Las Posas Road, and West San Marcos Boulevard. These facilities will either provide a direct connection to the project, via a project driveway, or will provide a critical link between the project and the regional transportation network.
Methodology
Local Transportation Analysis Approach and Methodology
As part of the LTA prepared for the project (Appendix I-1), the vehicle miles traveled (VMT) analysis was prepared to satisfy the requirements of the CEQA. The level of service (LOS) analysis conducted as a part of this study was used to evaluate the effects of the project on the circulation network. Per the City of San Marcos Transportation Impact Analysis Guidelines (TIAG) (City of San Marcos 2020), the City of San Marcos (City) strives to maintain intersection and roadway segment operations based on LOS standards outlined in the General Plan Mobility Element (City of San Marcos 2012a).
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 LTA, consider consistency with programs addressing the circulation system and for information 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 impact under CEQA. For informational purposes, trip generation rates and distribution information is provided from the LTA. However, the potential CEQA environmental impact of the project in terms of vehicle trips is analyzed in terms of VMT below.
VMT Metrics
Consistent with the City’s TIAG, the project shall be analyzed by the following VMT metric (City of San Marcos 2020):
• VMT/Employee which includes all daily work tour automobile vehicle-trips and associated VMT made by employed persons who work in the San Diego Association of Governments (SANDAG) Region traced back to the workplace of the trip-maker.
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The City’s TIAG 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 les s-than-significant impact without conducting a detailed VMT study. Relevant screening criteria for the project is described below:
• Map-Based Screening – Residential and employment 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 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.
Based on the project site location, land use characteristics, and trip generation of the project, none of the above listed screening criteria are anticipated to be applicable and therefore a detailed VMT analysis is required. This project analysis uses the VMT metric and impact thresholds developed by the City’s TIAG (City of San Marcos 2020), which provides a significant impact will occur if the project generates VMT per resident exceeding a level of 15 % below the existing countywide average. Project VMT modeled results are included as part of Appendix I-2, and summarized in the analysis below.
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 p eople make their transportation decisions and help people use the infrastructure in place for transit, ridesharing, walking, biking, and telework. 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 VM T is then compared to the threshold of significance to determine if the project’s VMT impact has been mitigated.
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Level of service
Level of service (LOS) is the term used to denote the different operating conditions which occur on a given roadway segment under various traffic volume loads. It is a qualitative measure used to describe a quantitative analysis taking into account factors such as roadway geometries, signal phasing, speed, travel delay, freedom to maneuver, and safety. Level of service provides an index to the operational qualities of a roadway segment or an intersection. Level of service designations range from A to F, with LOS A representing the best operating conditions and LOS F representing the worst operating conditions. Level of service designation is reported differently for signalized and unsignalized intersections, as well as for roadway segments. The City strives to maintain intersection and roadway segment operations based on LOS standards outlined in the General Plan Mobility Element.
As described above, the potential CEQA environmental impact of the project in terms of vehicle trips is analyzed in terms of VMT. LOS is provided herein and in the LTA (Appendix I-1) for information purposes only.
Intersections and Street Segments
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 using the methodology found in Chapter 19 of the Highway Capacity Manual 6th Edition (HCM 6) (TRB 2016), with the assistance of the Synchro 10 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 HCM 6 with the assistance of the Synchro 10 computer software.
Street Segments: Street segment analysis is based on the comparison of average daily traffic volumes to the City’s roadway classification, LOS (City of San Marcos 2012a), and average daily traffic (City of San Marcos 2019) tables. This table provides segment capacities for different street classifications, based on traffic volumes and roadway characteristics.
Study Scenarios
Study scenarios used for the LTA are outlined below:
• Existing Conditions: Used to establish the existing baseline of traffic operations within the study area.
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• Near-Term (Interim Year 2023) Conditions: Based on the SANDAG pre-established interim year scenario closest to the project’s anticipated opening year. • Near-Term (Interim Year 2023) Plus Project Conditions: Include project-generated traffic added to interim year volumes.
• Horizon Year Conditions: 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 I-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, bas ed on the anticipated distribution traffic to/from the project site.
Intersections:
1. South Pacific Street and Linda Vista Drive
2. South Pacific Street and West San Marcos Boulevard
3. South Pacific Street and Project Driveway #1
4. Project Driveway #2 and South Pacific Street
Roadway Segments:
• South Pacific Street, between Linda Vista Drive and West San Marcos Boulevard • Linda Vista Drive, between South Rancho Santa Fe Road and South Pacific Street • Linda Vista Drive, between South Pacific Street and South Las Posas Road The number associated with each intersection is referenced in the existing conditions analysis and project analysis throughout this EIR section.
The principal roadways in the project study area are described briefly below within Table 3.15 -2.
Roadway classification was determined from a review of the City of San Marcos Mobility Element (City of San Marcos 2012a) and information gathered from field observations.
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Table 3.15-2
Existing Transportation Network Characteristics
Street Segment
Number
of Lanes
Median
Type
Posted
Speed
Limit Sidewalk? Bike lanes?
Transit
Route
Linda Vista Drive
S Rancho Santa Fe
Road to S Pacific Street
1 EB/1
WB
CLTL 35 North Side:
Intermittently
Contiguous
South Side:
Contiguous
North Side:
Class II
South Side:
None
None
S Pacific Street to Las
Posas Road
2 EB/2
WB
CLTL 35 North Side: None
South Side:
Intermittently
Contiguous
None None
South Pacific Street
Linda Vista Drive to W
San Marcos Blvd
1 NB/1
SB
None 35 Intermittently
Contiguous
None None
Source: LTA, included as Appendix I-1 to this EIR.
Notes:
EB = East Bound
WB = West Bound
NB = North Bound
SB = South Bound
CLTL = Center Left Turn Lane
Existing Traffic Volumes
Traffic counts for study roadway segments and intersections were conducted on June 23, 2022, by Elite Traffic Dynamics LLC. A count validation was conducted to ensure that recently collected counts reflect the following:
• Traffic conditions prior to the COVID-19 restrictions • Traffic conditions during the peak season, including school-related traffic Historical (November 2017 and May 2018) counts conducted in the vicinity of the project study area were compared against recently collected (May 2022) counts. Based on the comparison, recently collected counts (2022) are greater than pre -pandemic counts. T hus, June 2022 counts were not adjusted for the purpose of reflecting pre-pandemic conditions.
Similarly, recently collected (May 2022) counts conducted in the vicinity of the project study area were compared against June 2022 counts. Based on the comparison, recently collected counts are greater than June 2022 counts. In other words, June 2022 coun ts do not reflect the higher volumes that occurred during the peak season when schools were in session. However, it is important to note that the traffic counts u sed for this part of the count validation were conducted at intersections where school traffic is more likely to travel through, such as the intersection of Via Vera Cruz and West
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San Marcos Boulevard. These roadways are part of the regional network and provide direct connections to SR -78. In contrast, the project’s study facilities (Linda Vista Drive and South Pacific Street) are not likely to receive a significant amount of school traffic, and thus do not merit the need for adjustments to reflect peak conditions. However, as a conservative approach, June 20 22 counts for study facilities were adjusted as if to reflect a school -related growth. Based on count validation results, June 2022 counts were adjusted as follows:
• Daily traffic volumes (roadway segments) – 5% overall increase • AM/PM peak hour turning movements (intersections) – 13% overall increase Traffic count worksheets, including study area counts, historical counts, and other recently collected counts, are provided in Appendix I-1. Figure 5.2 within Appendix I-1 displays existing daily traffic volumes for study roadway segments and AM/PM peak-hour turning movements for study intersections.
Existing Transit Conditions
The North County Transit District provides public transportation within the City and San Diego County for Coaster rail service, Sprinter light rail service, and Breeze bus service (City of San Marcos 2012a).
Sprinter service operates between Escondido and Oceanside, with connections to Interstate 5 and the Coaster rail service operating out of Oceanside. The North County Transit District operates the Palomar College Station Sprinter and Breeze transit station located approximately 1 mile from the project site.
Transit service is provided to the project area via North County Transit District bus routes 304, 347, and 445.
Bus Route 304 – This bus route is serviced along West Mission Road in the eastbound/westbound direction within the project study area. This bus route connects the Palomar College Transit Center to the Encinitas Transit Station. Operations starts at 4:53 AM and ends at 8:23 PM between Monday and Friday with 30-minute intervals. On Saturdays, operations start at 6:53 AM and ends at 9:05 PM with 60-minute intervals. This route does not operate on Sundays.
Bus Route 347 – This bus route is serviced along West Mission Road and North Las Posas Road within the project study area. This bus route connects the Palomar College Transit Center to the C alifornia State University San Marcos SPRINTER Station. Operations starts at 5:31 AM and ends at 7:21 PM between Monday and Friday with 30-minute intervals. On Saturdays, operations start at 7:22 AM and ends at 7:08 PM with 60-minute intervals. This route does not operate on Sundays.
Bus Route 445 – This bus route is serviced along West Mission Road and North Las Posas Road within the project study area. This bus route connects the Palomar College Transit Center to the Carlsbad Poinsettia Station (COASTER Connection). Between Monday and Friday, operat ions start at 6:34 AM and ends at 10:19 AM with 30 -minute intervals for the morning period. Similarly, between Monday and Friday, operates start at 3:36 PM and ends at 7:19 PM with 30-minute intervals for the afternoon period. This route does not operate on Saturdays or Sundays.
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SPRINTER – This light rail line runs between Oceanside Transit Center and Escondido Transit Center (eastbound and westbound direction). The nearest stop to the project site is the Palomar College Transit Center. Operation starts at 4:17 AM and ends at 9:10 PM between Monday and Sunday with 30- to 60-minute intervals.
Existing Bicycle Network
Under existing conditions, there are no bicycle facilities along the project frontage. The nearest planned bicycle facilities, per the City’s General Plan, are a Class I Bike Path and Class II Bike Lanes along Linda Vista Drive, just north of the project site, and a Class I Bike Path along West San Marcos Boulevard, just south of the project site (City of San Marcos 2012a).
Analysis of Existing Conditions
Intersection Levels of Service
Table 3.15-3 displays intersection LOS and average vehicle delay results for the study intersections under Existing conditions. LOS calculation worksheets for existing conditions are provided in Appendix I-1. As shown, the intersection of South Pacific Street and Linda Vista Drive currently operates at unacceptable LOS F during the PM peak hour.
As explained above, LOS information is provided as part of the LTA, not in support of the CEQA analysis.
LOS or 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 is provided from the LTA. The potential CEQA environmental impact of the project in terms of vehicle trips is analyzed in terms of VMT.
Table 3.15-3
Peak Hour Intersection LOS Results – Existing Conditions Intersection Control
Type
Peak
Hour
Existing
Delaya LOS
1 – South Pacific Street and Linda Vista Drive AWSC AM 17.1 C PM 59.4 F
2 – South Pacific Street and West San Marcos
Boulevard
Signal AM 17.3 B
PM 8.0 A
Notes:
a Average delay expressed in seconds per vehicle.
LOS = Level of Service.
AWSC = All-Way Stop Controlled intersection.
Bold indicates LOS E or F
Source: LTA, included as Appendix I-1 to this EIR.
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Roadway Segment Levels of Service
Table 3.15-4 displays roadway segment and LOS analysis results for study roadway segments under existing conditions. As shown, all study roadway segments currently operate at acceptable LOS D or better under Existing conditions.
Table 3.15-4
Roadway Segment LOS Results – Existing Conditions
Street Segment
Functional
Classification
Roadway
Capacity
Daily
Volume V/C LOS
Linda Vista Drive
S Rancho Santa Fe Rd to S Pacific St 2-Lane Collector
(w/CLTL)
15,000 11,422 0.761 D
S Pacific St to S Las Posas Rd 4-Lane Secondary
Arterial/Collector
(w/CLTL)
30,000 9,099 0.303 A
South Pacific Street
Linda Vista Dr to W San Marcos Blvd 2-Lane Collector
(w/Commercial
Fronting)
8,000 2,055 0.257 A
Notes:
CLTL = Center Left Turn Lane
V/C = Volume to Capacity.
LOS = Level of Service.
Source: LTA, included as Appendix I-1 to this EIR.
Cumulative Project Traffic
The following 11 projects were identified by City staff as cumulative projects, since they are anticipated to contribute traffic near the project study area by the project’s opening year:
1. Pacific Commercial – This project is located at the northeast corner of the Grand Avenue and Pacific Street intersection. This project proposes to construct a 122-room hotel.
2. San Marcos Highlands – This project is located at the north end of Las Posas Road. This project proposes to construct 187 single -family residential dwelling units as well as a 21.68 -acre passive park.
3. El Dorado II Specific Plan – This project is located at the southwest corner of the Richmar Avenue and Pleasant Way intersection. This project proposes to construct 72 multi -family dwelling units as well as 2,000 square feet of specialty retail.
4. Villa Serena – This project is located the northwest corner of the Richmar Avenue and Marcos Street intersection. This project proposes to construct 12 multi-family dwelling units.
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5. Mariposa (Phase 1) – This project is located at the northeast corner of the Richmar Avenue and Los Olivos Drive intersection. This project proposes to develop 60 multi-family dwelling units.
6. Murai Subdivision – This project is located at the north end of Las Posas Road. This project proposes to construct 89 single-family residential dwelling units.
7. Pacifica San Marcos – This project is located at the southeast corner of the Rancho Santa Fe Road and 9th Street intersection. This project proposes to construct 31 multi -family dwelling units as well as 4,375 square feet of commercial use.
8. Karl Strauss Brewery – This project is located at the southeast corner of the North Las Posas Road and Armorlite Drive intersection. This project proposes to construct 10,528 square feet of uses that include a tasting room, commercial kitchen, and entertainment room.
9. Gran Vista Multi-Family – This project is located 250 feet northwest of the West Mission Road and North Las Posas Road intersection. This project proposes to construct 120 multi -family dwelling units.
10. Marcos Specific Plan – This project is located at the northwest corner of Linda Vista Drive and Grand Avenue. This project proposes to construct 102 multi -family dwelling units, 15,086 SF of office space, and 49,266 SF of specialty retail space.
11. Upham Pacific Residential Project – This project is located at the northwest corner of the Linda Vista Drive and Las Posas Road Intersection. This project proposes to construct 449 residential units. Based on discussions with City of San Marcos staff, this project will signalize the intersection of Linda Vista Drive and S outh Pacific Street as part of project frontage improvements. However, due to the uncertainty of the opening year, the intersection was assumed to remain unsignalized under Near-Term Year 2024 Base conditions.
The traffic generated from the projects listed above are not likely to result in trips along study roadway segments and study intersections. Since there are no cumulative project trips anticipated to occur within the project study area, an ambient growth r ate for project study area as determined by comparing traffic volumes from SANDAG’s Transportation Forecast Information Center Series 14 ABM2+/2021 RP Forecast Year 2025 Model (scenario ID#462) with those in the Series 14 Forecast Year 2050 Model (scenario ID#459) (SANDAG 2022), as outlined in detail in Appendix I-1. An annual growth rate of 0.16% was observed over the 25-year period (Appendix I-1).
3.15.2 Regulatory Setting
The following provides a general description of the applicable regulatory requirements and guidelines for the project area.
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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.
AB 1358 – California Complete Streets Act of 2008
The California Complete Streets Act of 2008 (Assembly Bill [AB] 1358) requires circulation elements as of January 1, 2011 , to accommodate the transportation system from a multi -modal perspective, including public transit, walking, and biking, which have traditionally been marginalized in comparison to autos in contemporary American urban planning.
SB 743, CEQA Guidelines Update
In December 2018, the California Natural Resources Agency certified and adopted the CEQA Guidelines update package, including CEQA Guidelines Section 15063.4, which implements Senate Bill (SB) 743. SB 743 required new metrics for analyzing transportation impacts under CEQA to provide an alternative to LOS. Measurements of transportation impacts may include VMT, 1 vehicle miles traveled per capita, automobile trip generation rates, or automobile trips generated. In most cases, a project’s effect on automobile delay will no longer constitute a significant environmental impact.2 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 that 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 traffic, 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.
1 VMT refers to the amount and distance of automobile travel attributable to a project. 2 SB 743 also amends congestion management law to allow cities and counties to opt out of LOS standar ds within certain infill areas.
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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 ( City of San Marcos 2020), which, relevant to this project proposing a residential land use, provides a significant impact will occur if a project generates 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. Potential transportation impacts of the project are analyzed using these standards established pursuant to CEQA Guidelines Section 15063.4(b) in Section 3.15.3, Thresholds of Significance, Threshold #2.
Local
SANDAG’s San Diego Forward: The Regional Plan
The SANDAG San Diego Forward: The Regional Plan (Regional Plan) (SANDAG 2015) combines the region’s two most important existing planning documents—the Regional Comprehensive Plan and the Regional Transportation Plan and its Sustainable Communities Strategy. 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 (SANDAG 2021).
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. 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 specific requirements associated with this project in the Congestion Management Program . However, to ensure the region’s continued compliance with the federal congestion management process, SANDAG prepared San Diego Forward:
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The Regional Plan (SANDAG 2021) in compliance with 23 Code of Federal Regulations 450.320. The Regional Plan incorporates performance monitoring and measurement of the regional transportation system, multimodal alternatives to single -occupancy vehicles, land use impact analysis, congesti on management tools, and Integration with the Regional Transportation Improvement Program process.
The City of San Marcos Bikeway Master Plan
The Bikeway Master Plan (City of San Marcos 2015) 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.
City of San Marcos General Plan
Land Use 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 2012b):
o Policy LU-3.7: Require new development to prepare traffic demand management programs. o 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 2012a):
• 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. o 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. o 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.
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o 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.
o 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 congestion 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).
o 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. o Policy M-1.7: Strive to ensure that streets 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.
o Policy M-2.1: Work with new development to design roadways that minimize traffic volumes and/or speed, as appropriate within residential neighborhoods; while maintaining the City’s desire to provide connectivity on the roadway network. o 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. o 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.
o 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.
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o 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.
o 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.
o Policy M-3.9: Create a pleasant walking 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 #1: Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. • Threshold #2: Conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b). • Threshold #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 #4: Result in inadequate emergency access.
3.15.4 Project Impact Analysis
The following discussion summarizes the findings of the LTA (Appendix I-1) as it relates to project trip generation, project trip distribution and assignment, Near -Term (Year 2023) Scenarios with and without the project, and Horizon Year (Year 2050) Scenarios with and without the 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 a light industrial building and associated improvements. Per the City’s TIAG, trip generation rates should be derived from SANDAG’s (not so) Brief Guide to Vehicular Traffic Generation Rates for the San Diego Region ( SANDAG 2002). However, the project is acting as an “expansion” of the existing Hughes Circuits facility located across the street from the project site, with similar operations except the project would operate with two shifts instead of three (two 8 -hour shifts, 5 days a week). Therefore, a trip generation study was conducted at the existing Hughes Circuits facility.
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Table 3.15-5 tabulates the total project traffic generation. The project is estimated to generate a net total of 348 daily trips with 38 AM peak-hour trips (32 inbound and 6 outbound) and 43 PM peak hour trips (9 inbound and 34 outbound).
Table 3.15-5
Project Trip Generation
Land Use
Average Daily
Traffic
AM Peak Hour PM Peak Hour
Trips In Out Trips In Out
Hughes
Circuits
348 38 32 6 43 9 34
Source: LTA, included as Appendix I-1 to this EIR.
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 to which proje ct trips would originate or terminate, such as employment, housing, schools, recreation and shopping.
The project trip distribution was manually developed based on the geographical location of the project, as well as the characteristics of the proposed and surrounding land uses. Figure 3.1 in the LTA (Appendix I-1) shows the regional trip distribution patterns for project trips; Figure 3.2 in Appendix I-1 shows the daily and AM/PM peak hour project trip assignment.
Additionally, please refer to Table 6.1 through Table 6.4 in Appendix I-1, which show intersection and street segment operations both with and without the project.
Near Term Year 2024 Conditions
This section describes Near-Term Year 2024 Base traffic conditions both with and without the project.
The adjacent Upham/Pacific project will install a traffic signal at the study intersection of South Pacific Street and Linda Vista Drive, as well as convert Linda Vista Drive, between South Pacific Street and Las Posas Road to a 3-lane roadway with a 12-foot urban trail (shared use path). However, due to the uncertainty of the opening year for the Upham/Pacific project, these roadway and intersection modifications were not assumed under Near -Term Year 2024 Base conditions. Roadway segment functional classifications and intersection geometrics under Near -Term Year 2024 Base conditions were assumed to be identical to Existing conditions (Appendix I -1). As outlined in the LTA (Appendix I-1), all study roadway segments are projected to operate at acceptable LOS D or better under Near- Term Year 2024 Base conditions. Additionally, the intersection of South Pacific Street and Linda Vista Drive is projected to operate at unacceptable LOS F during the PM peak hour.
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Near Term (Interim Year 2023) with Project Conditions
Roadway segment functional classifications and intersection geometrics under Near-Term Year 2024 Base with Project conditions were assumed to be identical to Near-Term Year 2024 Base conditions, with the exception of the two project driveways along South Pacific Street. These new driveways will operate as side -street stop -controlled intersections, with the South Pacific Street approaches as uncontrolled and the project driveways as stop-controlled.
Traffic volumes for Near-Term Year 2024 Base with Project conditions were derived by combining the project trips (Figure 3.2 in Appendix I-1) to the Near-Term Year 2024 Base traffic volumes (Figure 6.2 in Appendix I -1). Figure 6. 3 in Appendix I -1 displays the projected daily traffic volumes for study roadway segments and projected AM/PM peak-hour turning movements for study intersections under Near-Term Year 2024 Base with Project conditions. As outlined in Section 6.5 of Appendix I-1, all study roadway segments are projected to operate at acceptable LOS D or better under Near-Term Year 2024 Base with Project conditions. Additionally, both study intersections are projected to operate at acceptable LOS C or better under Near -Term Year 202 4 Base with Project conditions, with the exception of the following:
• South Pacific Street and Linda Vista Drive – LOS F during the PM peak hour.
This intersection is projected to operate at unacceptable LOS F prior to the implementation of the project. Project traffic would not increase the overall average delay at this intersection by more than 2 seconds. Therefore, no study intersections are anticipated to degrade in LOS to unacceptable levels with implementation of the project and no improvements will be required.
Horizon Year 2050 Conditions
Horizon Year 2050 average daily traffic forecasts were obtained from the SANDAG Series 14 ABM2+/2021 RP Forecast Year 2050 Model (scenario ID#459) (SANDAG 2022) . The model represents a conservative scenario where the study segments of Linda Vista Drive and South Pacific Street are assumed to be four -lane roadways. As a result, the model’s traffic volumes at these segments are significantly higher than under Existing and Near-Term Year 2023 Base conditions.
The General Plan Mobility Element identifies Linda Vista Drive as a 4 -Lane Arterial Roadway, but it does not identify South Pacific Street as a 4 -lane roadway or circulation element road (City of San Marcos 2012a). However, the Forecast Year 2050 Model identifies both Linda Vista Drive and South Pacific Street as 4-Lane roadways. While the Forecast Year 2050 Model is consistent with the City’s General Plan for the segment of Linda Vista Drive west of South Pacific Street, the current right-of-way is already being used to provide needed parking for Bradley Park along the south side and a Class II bike lane along the north side. Converting or widening Linda Vista Drive or South Pacific Street to four- lane roadways would require additional right-of-way, which would need to be acquired via eminent
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domain or by removing existing parking and/or active transportation facilities. This approach would be inconsistent with the City’s General Plan Mobility Element Policy M-1.6 and M-1.7, as well as potentially cause an environmental impact due to the induced growth associated with a roadway widening. Linda Vista Drive and South Pacific Street have the potential to act as cut -through roadways and add ing through capacity may encourage additional vehicular trips and increase VMT.
Roadway segment functional classifications and intersection geometrics under Horizon Year 2050 conditions were assumed to be identical to Existing conditions ( see Figure 7.1 in Appendix I-1). As a conservative approach, Forecast Year 2050 Model traffic volumes were u sed as-is for the roadway segment LOS analysis. Intersection turning movement volumes were developed by determining the growth per approach based on existing and forecasted average daily traffic. Projected AM/PM peak hour turning movements were then distributed based on existing travel patterns and balanced utilizing engineering judgement.
Figure 7.1 in Appendix I-1 displays the projected daily traffic volumes for study roadway segments and the projected AM/PM peak hour turning movements for study intersections under Horizon Year 2050 conditions. As outlined in Section 7.2 of Appendix I -1, the following study roadway segments are projected to operate at unacceptable LOS F under Horizon Year 2050 conditions:
• Linda Vista Drive, between South Rancho Santa Fe Road and South Pacific Street • South Pacific Street, between Linda Vista Drive and West San Marcos Boulevard Additionally, the intersection of South Pacific Street and Linda Vista Drive is projected to operate at unacceptable LOS F during the PM peak hour under Horizon Year 2050 conditions.
Horizon Year 2050 with Project Conditions
Roadway segment functional classifications and intersection geometrics under Horizon Year 2050 with Project conditions were assumed to be identical to Horizon Year 2050 conditions, with the exception of the project driveways along South Pacific Street, as discussed previously under Near - Term Year 2023 Base with Project conditions. Traffic volumes for the Horizon Year 2050 with Project Conditions were derived by combining the project trips (see Figure 3.1 in Appendix I-1) to the Horizon Year 2050 traffic volumes (see Figure 7.1 in Appendix I -1). Figure 7.2 in Appendix I -1 displays the projected daily traffic volumes for study roadway segments and the projected AM/PM peak hour turning movements for study intersections under Horizon Year 2050 with Project conditions.
As outlined in Appendix I -1, the following study roadway segments are projected to operate at unacceptable LOS F under Horizon Year 2050 conditions:
• Linda Vista Drive, between South Rancho Santa Fe Road and South Pacific Street • South Pacific Street, between Linda Vista Drive and Project Driveway #1
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• South Pacific Street, between Project Driveway #1 and Project Driveway #2 • South Pacific Street, between Project Driveway #2 and West San Marcos Boulevard The roadway segments of Linda Vista Drive, between South Rancho Santa Fe Road and South Pacific Street, and South Pacific Street, between Project Driveway #1 and Project Driveway #2, are projected to continue operating unacceptable LOS F. However, since th e increase in vehicle -to-capacity ratio does not exceed 0.02, these study roadway segments would not experience a decrease in performance by the implementation of the project.
As for the remaining two segments projected to operate at LOS F, the project would result in an increase in vehicle-to-capacity ratio exceeding 0.02. Therefore, the project would require improvements to increase performance to acceptable or pre-project conditions.
Table 3.15 -6 displays roadway segment LOS analysis results for study roadway segments under Horizon Year 2050 with Project Conditions.
Table 3.15-6
Roadway Segment LOS Results – Horizon Year 2050 with Project Conditions Roadway Segment
Functional
Classification
Roadway
Capacity
Horizon Year 2050 with
Project
Horizon Year 2050
Without Project
ΔV/C
Daily
Volume V/C LOS
Daily
Volume V/C LOS
Linda Vista
Drive
South Rancho
Santa Fe Road
to South Pacific
Street
2-Lane Collector
(w/CLTL)
15,000 19,370 1,291 F 19,300 1.287 F 0.004
Linda Vista
Drive
South Pacific
Street to South
Las Posas
Road
3-Lane
Secondary
Arterial Collector
(w/CLTL)
22,5001 17,104 0.760 D 17,000 0.756 D 0.004
South
Pacific
Street
Linda Vista
Drive to Project
Parkway #1
2-Lane Collector
(w/Commercial
Fronting)
8,000 8,674 1.084 F 8,500 1.063 F 0.021
South
Pacific
Street
Project
Driveway #1 to
Project
Driveway #2
2-Lane Collector
(w/Commercial
Fronting)
8,000 8,500 1.063 F 8,500 1.063 F 0.000
South
Pacific
Street
Project
Driveway #2 to
West San
Marcos
Boulevard
2-Lane Collector
(w/Commercial
Fronting)
8,000 8,674 1.084 F 8,500 1.063 F 0.021
Notes: V/C = vehicle-to-capacity; LOS = level of service Bold indicates LOS E or F
1 Based on the capacity of a 4-Lane Secondary Arterial/Collector, reduced to exclude a lane. (3/4*30,000 = 22,500)
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As shown, the intersection of South Pacific Street and Linda Vista Drive is projected to operate at unacceptable LOS F during the PM peak hour under Horizon Year 2050 with Project conditions.
Because the project would add more than 2 seconds of delay to this intersection already operating at LOS F, implementation of the project would degrade performance at this intersection and would require improvements to increase performance to acceptable or pre-project conditions.
As outlined in Appendix I -1, since these study roadway segments are projected to operate efficiently during peak hours, implementation of the project would not result in adverse effects on traffic operations and no improvements are required. For the studied intersections, the recommended traffic signal would improve traffic operations during the PM peak hour to better than pre-project conditions.
To determine if signalizing the intersection of South Pacific Street and Linda Vista Drive is warranted, a signal warrant analysis was conducted in accordance with the California Manual on Uniform Traffic Control Devices ( Caltrans 2023 ). U sing the traffic volumes projected under Horizon Year 2050 conditions, this intersection would meet the requirements for the installation of a traffic signal.
Therefore, it is recommended that the project pay a 1.6% fair share contribution toward the installation of a traffic signal.
However, if the Upham/Pacific project constructs a traffic signal at the intersection of South Pacific Street and Linda Vista Drive as part of their project, the project would not be required to pay a 1.6% fair share contribution toward the installation of a traffic signal at this intersection.
Threshold #1. Conflict with a program plan, ordinance or policy addressing the circulation system , including transit, roadway, bicycle, and pedestrian facilities.
The project site is immediately bordered by South Pacific Street to the south and west. Adjacent land uses include industrial and mixed commercial development to the north and south, a public recreational park (Bradley Park) to the west, and undeveloped land to the east. The closest freeway is SR-78, located approximately 0.7 miles north of the project site.
Access to the project from the regional transportation network will be provided via SR -78, South Rancho Santa Fe Road, Linda Vista Drive, South Pacific Street, South Las Posas Road, and West San Marcos Boulevard. These facilities will either provide a direct connection t o the project, via a project driveway, or will provide a critical link between the project and the regional transportation network.
Project site access would be provided via the following new project driveways:
• Project Driveway #1 – This new full-access driveway will be located along the east side of South Pacific Street to the west of the project site. This driveway will be a new side -street stop- controlled intersection with South Pacific Street as the uncontrolled approach and the project
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driveway as the stop -controlled approach. This driveway is projected to operate at LOS A or under all “with project” scenarios.
• Project Driveway #2 – This new full-access driveway will be located along the north side of South Pacific Street to the south of the project site. This driveway will be a new side -street stop-controlled intersection with South Pacific Street as the uncontrolled approach and the project driveway as the stop -controlled approach. This driveway is projected to operate at LOS B or better under all “with project” scenarios.
A 95th percentile queue analysis was conducted to determine the extent of queueing at the project driveway intersections under Near -Term Year 2023 Base with Project conditions and Horizon Year 2050 with Project conditions. The queue analysis was conducted for the project driveways and the movements along South Pacific Street. The 95th percentile queues at project driveways are projected to fit within the available storage and would not impede traffic at the driveways or adjacent roadway system. As outlined in Appendix I-1, it is recommended that the project driveways are constructed in accordance with City standards, and that stop signs are installed at project driveways.
The internal roadway on the project site would allow for two -way flow of vehicle traffic. The LTA recommends that the project incorporate appropriate signage to warn drivers of pedestrian foot traffic, and consider installation of speed cushions/bumps along the internal roadway to calm traffic.
Sidewalks are proposed along the segment of South Pacific Street fronting the project. Sidewalks are also proposed throughout the internal roadways providing direct access to the proposed building. The LTA recommends that the project construct curb ramps located along project driveways to include detectable surface warning tactiles (yellow truncated domes) and meet all Americans with Disabilities (ADA) requirements.
The project would implement Class II bicycle facilities along South Pacific Street between Linda Vista Drive and West San Marcos Boulevard. This bicycle facility would increase the number of opportunities to ride within the City and provide a direct connection between the Class I Bike Paths proposed along Linda Vista Drive and West San Marcos Boulevard. The proposed Class II bicycle lanes will have a 1.5-foot buffer where on-street parking is allowed and a 3-foot buffer where on-street parking is prohibited.
Implementation of the recommendations in the LTA would enhance the walkability and safety of the overall pedestrian environment and would not result in any impacts to pedestrian facilities. The project would incorporate all recommendations of the LTA (Appendix I -1). Furthermore, as outlined under Section 3.15.1 , Existing Conditions , the project would not conflict with existing or planned transit facilities and would not result in any impacts to transit facilities; similarly, the project would not conflict with existing or planned bicycle facilities and would not result in any impacts to bicycle facilities.
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The site is located in an area with moderately high employment density given the surrounding commercial and light industrial land uses. The project site is located within close proximity (less than a mile) from bus stops serving two separate routes with connections to Sprinter service at Palomar College Station.
Parking for the proposed building would include 72 parking spaces, including 4 electric vehicle (EV) charging stations, 3 EV-ready parking spaces, 9 clean air vehicle parking stalls, 5 accessible stalls, and 1 U.S. Postal Service parking stall. Additionally, 4 short -term bicycle parking spaces and 4 long - term bicycle parking spaces would be provided.
As discussed above, a Local Transportation Analysis (see Appendix I-1) has been prepared for the project consistent with City requirements to evaluate the effects of the project on the circulation network (LOS), and improvements have been recommended that would increase performance of unacceptable roadways/intersections to acceptable or pre-project conditions.
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 infill area, and the project would incorporate safe access to/from the project site and surrounding roadways. The project would also not preclude the development of any specific improvement projects identified in the Regional Pla n to reduce regional congestion. Therefore, impacts would be less than significant.
Threshold #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), vehicle miles traveled 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 Public Resource Code Section 21064.3, a “Major transit stop means a site containing an existing rail station ”). Despite the project being consistent with the designated land use and zoning for the project site, the project is not located within 0.5 miles of a major transit stop (Palomar Station), and the project would not be screened out of a quantitative VMT analysis. The North County Transit District Palomar College Station Sprinter and Breeze transit station is located approximately 1.2 miles northeast of the project site, while the closest bus sto ps on West San Marcos Boulevard are located approximately 0.25 mile s south. Furthermore, based on the screening criteria in the City’s TIAG, the project does not fall under any of the VMT screening criteria and requires a detailed VMT analysis (Appendix I-2).
As outlined in Appendix I -2, the project’s VMT per employee was obtained from the SANDAG VMT screening maps. Per the City’s TIAG, an employee project is determined to have a significant impact if
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the project generates VMT per employee greater than 85% of the regional average. The regional average VMT was determined using the SANDAG Series 14 ABM2+/2021 RP Year 2016 Base model.
As shown in Table 3.15-7, the project is anticipated to generate a VMT per employee of 16.80 miles, which exceeds the significance threshold of 16.07 miles. Therefore, the project would have a significant VMT impact and mitigation measures are required to reduce the VMT per employee (Impact TRA-1).
Table 3.15-7
Vehicle Miles Traveled Impact Analysis
Metric
Regional
Average 1
Significance
Threshold
(15% below
Average)2 Project1
Transportation
Impact?
(Over Threshold)
Vehicle Miles Traveled per Employee 18.90 16.07 16.80 Yes Notes:
1 Source = SANDAG Series 14 ABM2+/2021 RP Year 2016 Base Model 2 Regional Average x 85%
The project’s VMT per employee is not anticipated to fall under the significance threshold as the project site is located in an area primarily composed of industrial and commercial land uses where employees travel longer-than-average distances for work compared to the region. The project’s total VMT per employee is 16.80 miles. To mitigate the project’s VMT to less -than-significant levels, mitigation measures would need to reduce the total VMT per employee by 4.4% from 16.80 miles to 16.07 miles.
As described in Appendix I -2, to reduce the average VMT per employee, it is recommended that the project implements 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, the California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity is a more recent document (CAPCOA 2021) and was deemed appropriate to use for the project’s mitigation evaluation.
Mitigation Measure (MM-)TRA-1, MM-TRA-2, and MM-TRA-3 are proposed for the project, as outlined in Section 3.15.6, Mitigation Measures. Based on the VMT reduction results, implementation of the TDM Program is anticipated to reduce the VMT per -capita generated by 2.6 %. Thus, with implementation of the TDM Program, the project is anticipated to generate 16.36 VMT per employee.
The resulting 16.36 miles per employee exceeds the 16.07 miles threshold. Therefore, since the mitigation measures would not reduce the VMT per employee to less-than-significant levels, the impact is only partially mitigated, and the project is considered to have a significant and partially mitigated
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impact. Therefore, despite implementation of MM -TRA-1, MM-TRA-2, and MM -TRA-3, impacts would be significant and unavoidable.
Threshold #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, off South Pacific Street. As described under Threshold #1, the project would be served by two driveways. Project Driveway #1 would be located along the east side of South Pacific Street to the west of the project site. This driveway would be a new side -street stop -controlled intersection with South Pacific Street as the uncontrolled approach and the project d riveway as the stop -controlled approach. Project Driveway #2 would be located along the north side of South Pacific Street to the south of the project site. This driveway will be a new side -street stop -controlled intersection with South Pacific Street as the uncontrolled approach and the project driveway as the stop -controlled approach. As outlined in Appendix I -1, the project would not impede traffic at the driveways or adjacent roadway system. It is recommended that the project driveways are constructed in accordance with City standards, and that stop signs are installed at project driveways.
The internal roadway on the project site would allow for two -way flow of vehicle traffic. The LTA recommends that the project incorporate appropriate signage to warn drivers of pedestrian foot traffic, and consider installation of speed cushions/bumps along the internal roadway to calm traffic.
Furthermore, sidewalks are proposed along the segment of South Pacific Street fronting the project.
Sidewalks are also proposed throughout the internal roadways providing direct access to the proposed building. The LTA recommends that the project construct curb ramps located along project driveways to include detectable surface warning tactiles (yellow truncated domes) and meet all ADA requirements.
Implementation of the recommendations in the LTA would enhance the walkability and safety of the overall pedestrian environment and would not result in any impacts to pedestrian facilities. The project would incorporate all recommendations of the LTA (Appendix I -1). Furthermore, as outlined under Section 3.15.1, the project would not conflict with existing or planned transit facilities and would not result in any impacts to transit facilities; similarly, the project would not conflict with existing or planned bicycle facilities and would not result in any impacts to bicycle facilities.
All final project plans and the LTA prepared for the project (included as Appendix I-1 to this EIR) 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. All uses on site, including vehicle, pedestrian and bicycle circulation would be typical of such a development, and no incompatible uses, or equipment is proposed. As such, impacts would be less than significant.
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Threshold #4: Would the project result in inadequate emergency access? As described in response to Threshold #3, the project would be served by two driveways located on South Pacific Street. All driveways would provide for full turning movements. 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 Section 3.13, Public Services, of this EIR, the Preliminary Fire Emergency Response Analysis prepared for the project (Appendix H) determined that the San Marcos Fire Department would arrive at the project site between 3:37 - and 3:50-minute travel time (6:07 - to 6:40-minute total response time).
This results in up to 53 seconds to drive within the project site to the most remote unit, which is achievable based on the project site’s roads and smaller overall size. The Fire Service Response Analysis prepared for the project (Appendix H) determined that the San Marcos Fire Department could provide emergency response to the pr oject site within its internal 7 -minute response time from Stations 1 and 2.
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 and surfaces (Chapter 5, Section 503.1 through 503.4 of the California Fire Code), an adequate number of emergency rated entrances to the community (Appendix D, Section D106 of the California Fire Code). All final project plans and the LTA prepared for the project 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. Therefore, for the reasons outlined above, it is determined that 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 study area could result in cumulative impacts related to transportation and circulation. However, t he preceding analysis of the project in Section
3.15.4, Project Impact Analysis, as well as the LTA prepared for the project (Appendix I-1) is based on methodologies that incorporate the cumulative impacts of traffic from forecasted grow within the project area. Cumulative project traffic was assigned to the project study area as identified within their respective traffic studies provided by the City. Cumulative project traffic without completed traffic studies were assigned to the project study area utilizing the same methodology used for the project, consistent with the City’s TIAG.
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It is expected that traffic impact analyses, local transportation analyses, and vehicle miles traveled analyses would be prepared for cumulative projects consistent with City Guidelines, to fully analyze project-specific impacts on -site and in the 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 transportatio n 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 study area. For this reason, it is determined that cumulative impacts to transportation as a result of proj ect implementation would similarly be significant and unavoidable.
3.15.6 Mitigation Measures
As analyzed in Section 3.15.4, implementation of the project would result in significant impacts related to VMT per employee. MM -TRA-1, MM-TRA-2, and MM -TRA-3 outlined below 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.
MM-TRA-1 Provide Ridesharing Program (CAPCOA T -8). This measure would implement a ridesharing program for employees. The program shall include desirable parking spaces for ridesharing vehicles, adequate passenger loading/unloading and waiting areas for ridesharing vehicles, and an app/website for ride coordination. This measure would reduce up to 2.0% Employee VMT with 50% employee eligibility.
MM-TRA-2 Provide End-of-Trip Bicycle Facilities (CAPCOA T -10). This measure would install and maintain end-of-trip facilities for employee use, including bike parking, bike lockers, showers, and personal lockers. This measure would reduce up to 0.6% Employee VMT.
MM-TRA-3 Expand Bikeway Network (CAPCOA T-20). This measure would increase the length of a city or community bikeway network by providing bicycle infrastructure (Class I, Class II, or Class IV). More specifically, the project would construct 0.5 miles of Class II bicycle facilities along South Pacific Street between Linda Vista Drive and West San Marcos Boulevard. This bicycle facility would increase the existing bicycle lane miles within the City of San Marcos from 41.1 miles to 41.6 miles. The bike facility would provide additional opportunities to ride within the City and provide a direct connection between the Class I Bike Paths proposed along Linda Vista Drive and West San Marcos Boulevard. The proposed Class II bicycle lanes would have a 1 ½- foot buffer where on-street parking is allowed and a 3-foot buffer where on-street parking is prohibited. This measure would reduce up to 0.0001% Employee VMT.
In addition to MM -TRA-1, MM-TRA-2, and MM -TRA3, the following improvement recommendation proposed by the VMT Analysis Memorandum (Appendix I-2) would be incorporated as conditions of
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approval which have the potential to reduce greenhouse gas emissions; however, it is not considered a mitigation measure because it would not reduce VMT:
• Provide Electric Vehicle Charging Infrastructure (CAPCOA T -14) – Install electric vehicle charging stations at EV parking spaces. The project would install 4 electric vehicle charging stations and 3 EV-ready parking spaces. There are also 9 parking spaces designated for clean air vehicles.
3.15.7 Conclusion
The project would develop an industrial building in an infill area, taking advantage of the site’s location near transit, and compatible land uses, consistent with the land use and zoning designation for the project site. The project would be consistent with programs, plans, ordinances and policies 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, wo uld not increase hazards, and would not result in inadequate emergency access. Impacts related to Thresholds # 1, 3, and 4 would be less than significant.
As described in response to Threshold #2, based on the VMT reduction results, implementation of the TDM Program is anticipated to reduce the VMT per-capita generated per employee by 2.6%. Thus, with implementation of the TDM Program, the project is anticipated to generate 16.36 VMT per employee.
The resulting 16.36 miles per employee exceeds the 16.07 miles threshold. Therefore, since the mitigation measures would not fully reduce the VMT per employee to less than significant levels, the impact is only part ially mitigated, and the project is considered to have a significant and partially mitigated impact. Therefore, even with implementation of MM-TRA-1 and MM-TRA-2, impacts related to VMT would be significant and unavoidable . As such, cumulative impacts related to traffic would similarly be significant and unavoidable.
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3.16 Tribal Cultural Resources
Hughes Circuits Project Environmental Impact Report March 2024 City of San Marcos 3.16-1
3.16 TRIBAL CULTURAL RESOURCES
This section describes the existing tribal cultural resources of the Hughes Circuits 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 tribal cultural resource 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, and that is (1) either on or eligible for the California Register of Historical Resources (CRHR) or a local historic register, or (2) determined by the City of San Marcos (City), at its discretion to treat the resources as a tribal cultural resource (PRC Section 5024.1).
The analysis in this section relies, in part, on the Archaeological Resource Inventory Report for the Hughes Circuits Project, City of San Marcos, California (Archaeological Resources Report), prepared by Dudek on January 13, 202 3. 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. The Archaeological Resources Report is included as Appendix D to this environmental impact report (EIR).
Table 3.16-1 summarizes the tribal cultural resources 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
#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
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3.16.1 Existing Conditions
The project area, as analyzed in the Archaeological Resources Report, consists of the entire of the project site, approximately 10.46 acres (Assessor’s Parcel Numbers 219-223-20-00 and 219-223-22- 00) (Figure 3.16-1). The entire project area is undeveloped and contains no structures.
The project area predominantly contains grass, thistles, Hardy ice plants, and sage. Modern debris (e.g., refuse) is strewn throughout the project area and a homeless encampment was observed in the bushes on the northwestern portion of the project area. Adjacent land uses include mixed commercial development to the north and south, a public recreation park (Bradley Park) to the west, and undeveloped land to the east. The project area is relatively flat;, and a parcel of land owned by the San Diego County Water Authority right-of-way and a dirt walking path bisect the site. Elevation ranges from approximately 520 feet above mean sea level in the eastern portion of the project area to 535 feet above mean sea level in the northwest portion of the project area. The Las Posas Branch tributary to San Marcos Creek is located on the border of the western section of the project area, and a second tributary runs through the project area on the eastern side to San Marcos Creek.
The information herein describes the existing archeological context of the project area. It also provides information on the outreach and consultation efforts with local tribes, as required by existing regulations.
Prehistoric Context
Evidence for continuous human occupation in the San Diego County region spans the last 12,000 years. Various attempts to parse out variability in archaeological assemblages over this broad time frame have led to the development of several cultural chronologies; some of these are based on geologic time, most are based on temporal trends in archaeolo gical assemblages, and others are interpretive reconstructions. Each of these reconstructions describes essentially similar trends in assemblage composition in more or less detail. This research employs a common set of generalized terms used to describe chronological trends in assemblage composition from an archaeological perspective: Paleoindian (pre-5500 BC), Archaic (8000 BC–AD 500), Late Prehistoric (AD 500–1750), and Ethnohistoric (post -AD 1750). Native American aboriginal lifeways did not cease at European contact. “Protohistoric” refers to the chronological trend of continued Native American aboriginal lifeways at the cusp of the recorded historic period in t he Americas. The tribal cultural context spans all of the archaeologically based chronologies further described below.
Paleoindian Period (pre-5500 BC)
Evidence for Paleoindian occupation in coastal Southern California is tenuous, especially considering the fact that the oldest dated archaeological assemblages look nothing like the Paleoindian artifacts from the Great Basin. One of the earliest dated arch aeological assemblages in coastal Southern California (excluding the Channel Islands) derives from P -37-004669 (CA-SDI-4669), in La Jolla. A
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human burial from P -37-004669 was radiocarbon dated to 9,590 –9,920 years before present (approximately 95% probability) (Hector 2007). The burial is part of a larger site complex that contained more than 29 human burials associated with an assemblage that fits the Archaic profile (i.e., large amounts of groundstone, battered cobbles, and expedient flake tools). In contrast, typical Paleoindian assemblages include large stemmed projectile points, high proportions of formal lithic tools, bifacial lithic reduction strategies, and relatively small proportions of groundstone tools. Prime examples of this pattern are sites that were studied by Emma Lou Davis (1978) on China Lake Naval Air Weapons Station near Ridgecrest, California. These sites contained fluted an d unfluted stemmed points and large numbers of formal flake tools (e.g., shaped scrapers, blades). Other typical Paleoindian sites include the Komodo site (MNO-679)—a multicomponent fluted point site, and MNO- 680—a single component Great Basin stemmed point site (Basgall et al. 2002). At MNO-679 and MNO- 680, groundstone tools were rare while finely made projectile points were common.
Turning back to coastal Southern California, the fact that some of the earliest dated assemblages are dominated by processing tools runs counter to traditional notions of mobile hunter –gatherers traversing the landscape for highly valued prey. Evidence for the latter—that is, typical Paleoindian assemblages—may have been located along the coastal margin at one time, prior to glacial desiccation and a rapid rise in sea level during the early Holocene (pre-7500 Before Present [BP]) that submerged as much as 1 .8 kilometers of the San Diego coastline. If this were true, however, it would also be expected that such sites would be located on older landforms near the current coastline. Some sites, such as P-37-000210 (CA-SDI-210) along Agua Hedionda Lagoon, contained stemmed points similar in form to Silver Lake and Lake Mojave projectile points (pre -8000 BP) that are commonly found at sites in California’s high desert (Basgall and Hall 1990). P -37-000210 yielded one corrected radiocarbon date of 8520–9520 BP (Warren et al. 2004). However, sites of this nature are extremely rare and cannot be separated from large numbers of milling tools that intermingle with old projectile point forms.
Warren et al. (2004) claimed that a biface manufacturing tradition present at the Harris site complex P-37-000149 (CA-SDI-149) is representative of typical Paleoindian occupation in the San Diego County region that possibly dates between 10,365 and 8200 BC (Warren et al. 2004, p. 26). Termed San Dieguito (Rogers 1945), assemblages at the Harris site are qualitatively distinct from most others in the San Diego County region because the site has large numbers of finely made bifaces (including projectile points), formal flake tools, a biface reduction trajectory, and relatively small amounts of processing tools (Warren 1964, 1968). Despite the unique assemblage composition, the definition of San Dieguito as a separate cultural tradition is hotly debated. Galleg os (1987) suggested that the San Dieguito pattern is simply an inland manifestation of a broader economic pattern. Gallegos’ interpretation of San Dieguito has been widely accepted in recent years, in part because of the difficulty in distinguishing San Di eguito components from other assemblage constituents. In other words, it is easier to ignore San Dieguito as a distinct socioeconomic pattern than it is to draw it out of mixed assemblages.
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The large number of finished bifaces (i.e., projectile points and non-projectile blades), along with large numbers of formal flake tools at the Harris site complex, is very different than nearly all other assemblages throughout the San Diego County region, regardless of age. Warren et al. (2004) made this point, tabulating basic assemblage constituents for key early Holocene sites. Producing finely made bifaces and formal flake tools implies that relatively large amounts of time were spent for tool manufacture. Such a strategy contrasts with the expedient flake -based tools and cobble -core reduction strategy that typifies non-San Dieguito Archaic sites. It can be inferred from the uniquely high degree of San Dieguito assemblage formality that the Harris site complex represents a distinct economic strategy from non-San Dieguito assemblages.
If San Dieguito truly represents a distinct socioeconomic strategy from the non -San Dieguito Archaic processing regime, its rarity implies that it was not only short-lived, but that it was not as economically successful as the Archaic strategy. Such a conclusion would fit with other trends in southern California deserts, wherein hunting -related tools are replaced by processing tools during the early Holocene (Basgall and Hall 1993).
Archaic Period (8,000 BC – AD 500)
The more than 2 ,500-year overlap between the presumed age of Paleoindian occupations and the Archaic period highlights the difficulty in defining a cultural chronology in the San Diego County region.
If San Dieguito is the only recognized Paleoindian component in the San Diego County region, then the dominance of hunting tools implies that it derives from Great Basin adaptive strategies and is not necessarily a local adaptation. Warren et al. (2004) admitted as much, citing strong desert connections with San Dieguito. Thus, the Archaic pattern is the earliest local socioeconomic adaptation in the San Diego County region (Hale 2001, 2009).
The Archaic pattern is relatively easy to define with assemblages that consist primarily of processing tools: millingstones, handstones, battered cobbles, heavy crude scrapers, incipient flake-based tools, and cobble-core reduction. These assemblages occur in all environments across the San Diego County region, with little variability in tool composition. Low assemblage variability over time and space among Archaic sites has been equated with cultural conservatism (Byrd and Reddy 2002; Warren 1968; Warren et al. 2004). Despite enormous amounts of archaeological work at Archaic sites, little change in assemblage composition occurs until the bow and arrow is adopted at around AD 500, as well as ceramics at approximately the same time (Griset 1996; Hale 2009). Even then, assemblage formality remains low. After the bow is adopted, small arrow points appear in large quantities and already low amounts of formal flake tools are replaced by increasing amounts of expedient flake tools. Similarly, shaped millingstones and handstones decrease in proportion relative to expedient, unshaped groundstone tools (Hale 2009). Thus, the terminus of the Archaic period is equally as hard to define as its beginning because basic assemblage constituents and patterns of manufacturing investment remain stable, complimented only by the addition of the bow and ceramics.
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Late Prehistoric Period (AD 500 – 1769)
The period of time following the Archaic and prior to Ethnohistoric times (AD 1750) is commonly referred to as the Late Prehistoric (Rogers 1945; Wallace 1955; Warren et al. 2004). However, several other subdivisions continue to be used to describe various shifts in assemblage composition, including the addition of ceramics and cremation practices. In northern San Diego County, the post -AD 1450 period is called the San Luis Rey Complex (True 1978). Rogers (1929) also subdivided the last 1,000 years into the Yuman II and III cultures, based on the distribution of ceramics. Despite these regional complexes, each is defined by the addition of arrow points and ceramics, and the widespread use of bedrock mortars. Vagaries in the appearance of the bow and arrow an d ceramics make the temporal resolution of the San Luis Rey complex difficult. For this reason, the term Late Prehistoric is well-suited to describe the last 1,500 years of prehistory in the San Diego region.
Temporal trends in socioeconomic adaptations during the Late Prehistoric period are poorly understood. This is partly due to the fact that the fundamental Late Prehistoric assemblage is very similar to the Archaic pattern, but includes arrow points and lar ge quantities of fine debitage from producing arrow points, ceramics, and cremations. The appearance of mortars and pestles is difficult to place in time because most mortars are on bedrock surfaces; bowl mortars are actually rare in the San Diego County region. Some argue that the Ethnohistoric intensive acorn economy extends as far back as AD 500 (Bean and Shipek 1978). However, there is no substantial evidence that reliance on acorns, and the accompanying use of mortars and pestles, occurred prior to AD 1400. True (1980) argued that acorn processing and ceramic use in the northern San Diego region did not occur until the San Luis Rey pattern emerged after approximately AD 1450.
Ethnohistoric Period (post-AD 1769)
Early descriptions of the lifeways of Southern California ethnohistoric groups were provided by explorers, missionaries, administrators, and other travelers, who gave particular attention to the coastal populations (Boscana 1846; Fages 1937; Geiger and Mei ghan 1976; Harrington 1934; Laylander 2000). Subsequent ethnographers in the early twentieth century were able to give much more objective, detailed, and penetrating accounts. Most of the ethnographers attempted to distinguish between observations of the customs of surviving Native Americans and orally transmitted or inferred information concerning the lifeways of native groups prior to European intrusion into the region. The second of these subjects provides a terminal baseline for discussing the cultures of the region’s prehistory. Despite the relatively rich ethnographic record, attempts to distinguish between the archaeological residues that were produced by the linguistically unrelated but culturally similar Luiseño and Ipai/Kumeyaay have been largely unsuccessful (Pigniolo 2004; True 1966).
The first systematic ethnographic work in California was done in 1871 and 1872 by Stephen Powers (Heizer 1978); in 1877, Powers collected and printed his ethnographic observations in Tribes of
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California (Powers 1877). Prior to the work of Powers, there were limited records and accounts that might be broadly considered as ethnohistorical data, such as Boscana (1846). At the beginning of the twentieth century, Alfred L. Kroeber and others began f our decades of systematic documentation of tribal ethnographies. Kroeber’s (1925) monumental work on the Indians of California continues to be an authoritative source of information. It is important to note that even though there were many informants for t hese early ethnographies who were able to provide information from personal experiences about native life before the Europeans, a significantly large proportion of these informants were born after 1850 (Heizer and Nissen 1973); therefore, the documentation of pre -contact, aboriginal culture was being increasingly supplied by individuals born in California after considerable contact with Europeans. As Robert F. Heizer (1978) stated, this is an important issue to note when examining these ethnographies, since considerable culture change had undoubtedly occurred by 1850 among the Native American survivors of California. Nonetheless, the enormous value of the ethnographies done under Kroeber’s guidance is obvious. The major sources for this review include Lowell John Bean and Florence C. Shipek (1978), Kroeber (1925), Philip S. Sparkman (1908), and Raymond White (1963).
San Marcos is situated within the ethnohistoric territory of the Native American Luiseño cultural group, according to Kroeber’s study (1925; see also Rivers 1993). The Luiseño language belongs to the Cupan group of the Takic language branch of the Uto-Aztecan language family. Luiseño is a term given to Native Americans under the administration of Mission San Luis Rey, and later applied specifically to the Payomkawichum ethnic nation who were present in the region where the mission was founded.
Meaning the “western people,” the name Payomkawichum can also be applied to the closely related coastal Luiseño who lived north of the mission.
Luiseño territory was situated in the north half of San Diego County and the western edge of Riverside County. Their lands encompassed the southern Santa Margarita Mountains and the Palomar Mountains, and their foothills to the Pacific Ocean. The territory extended eastward into the San Jacinto Valley and the western foothills of the San Jacinto Mountains. Their neighbors to the north were the Juaneño (Acjachemen) who spoke a Luiseño dialect, the Cahuilla and Cupeño to the east who spoke other Takic Cupan l anguages, and the Ipai (Kumeyaay) to the south who spoke a California -Delta Yuman language.
The Luiseño resided in permanent villages and associated seasonal camps. Village population ranged from 50 –400 with social structure based on lineages and clans. A single lineage was generally represented in smaller villages, while multiple lineages and a dominant clan presided in larger villages.
Each clan/village owned a resource territory and was politically independent, yet maintained ties to others through economic, religious, and social networks in the immediate region. There were contact period villages in the vicinity of this segment, near what is now of Vista, San Marcos, and Escondido, but researchers have been unable to place rancheria names from the mission registers with these locations.
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Like other Indigenous California groups, the primary food staple was the acorn (Bean and Shipek 1978), supplemented by other plant resources, fish, shellfish, waterfowl, and marine and terrestrial mammals. Villages were situated near reliable sources of water, needed for the daily leaching of milled acorn flour. Other plant foods included pine nuts and grass seeds, manzanita, sunflower, sage, chia, lemonade berry, wild rose, holly -leaf cherry, prickly pear, and lamb’s quarter. Large and small prey included deer, antelope, rabbit, jackrabbit, wood rat, mice, and ground squirrel, as well as quail, ducks, and other birds. Fish, such as trout, were caught in rivers and creeks.
The first direct European contact with the Luiseño occurred in July 1769 with the Spanish expedition led by Gaspar de Portolá. During the next 6 years, eight missions and forts were founded north and south of Luiseño territory. In 1776, Mission San Juan Capistrano was founded less than 10 miles north, and the populations of five northern Luiseño villages had been halved within 15 years. In 1798, Mission San Luis Rey was established within Luiseño territory, and the proselytizing among the Payomkawichum began in earnest.
Several Luiseño leaders signed the statewide 1852 treaty, locally known as the Treaty of Temecula (an interior Luiseño village), but the U.S. Congress never ratified it. By 1875, however, reservations for the Luiseño were established in the Palomar Mountai ns and nearby valleys, including Pala, Pauma, Rincon, Pechanga, and La Jolla.
Methodology
Records Search
Dudek conducted a California Historical Resources Information Systems records search of the project area and a one-mile radius buffer at the South Coastal Information Center (SCIC) on January 31, 2022.
The records search results indicate that 53 previous cultural resources studies have been conducted within 1-mile of the project area. Of the 53 previous studies, 5 studies intersect the project area. These studies consist primarily of an archaeological inventory report, two cultural resource reconnaissance reports, an EIR, and a records search and literature review. Overall, 100% of the project area has been previously studied.
The SCIC records search did not identify any cultural resources within the project area. The records search did identify eight cultural resources within the one-mile search radius buffer of the project area.
Of the total eight resources identified in the one-mile buffer, six are prehistoric resources and two are historic resources. No historic addresses are located within the project area, however, two are located within the one-mile search radius. Refer to Appendix D for further details.
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Archival Research
Dudek conducted an on-line review of historic aerial photographs of the project area and general vicinity, to help determine the possible development and land use of the project area in the past. Historic aerial photographs of the project area were available for 1938, 1947, 1953, 1964, 1967, 1980-1991, 1993- 2000, 2002, 2003, 2005, 2009, 2010, 2012, 2014, 2016, and 2018 ( Appendix D). The historical aerials from 1938 to 1967 revealed that project area was undeveloped. By 1978, some dirt trails can be observed within the area and to the north of the area, grading was observed, and two structures were developed. By 1980, the road for South Pacific Street is developed, the surrounding properties have been graded, and residential/commercial development is present. The aerials from 1981 to 1984 do not reveal any changes to the area. By 1985, some light surface disturbance is observed within a small section of the southern area. The 1986 aerial shows some slight disturbance to the area in the form of dirt trails. The aerials from 1987 to 1994 do not reveal any changes to the area. The 1993 aerial shows some disturbance to the eastern portion of the area, and by 1996, dirt trails or a dirt road become more prominent within the area. The aerials from 1997 to 2018 do not reveal any changes to the area. The entire portion of the project area has remained undeveloped. No historic structures are located within the project area. The review of the aerial photographs reveals that a majority of the project area has not been highly disturbed by earth-moving activities.
Historic topographic maps of the project area were reviewed (earliest map available is 1893). A creek is observed within the western section of the project area, however, on the 1979 topographic map, the creek is no longer observed within the project area. The historic topographic maps do not reveal any historic structures located within the project area.
Dudek reviewed a geotechnical report prepared for the project area (Appendix E to this EIR). The report details the results of six exploratory trenches to a maximum depth of 14 feet on September 1, 2021, however, the report only covered a small portion of the western section of the project area.
Undocumented fill was encountered to a depth of approximately 2 feet. Alluvium was encountered in all trenches to depths ranging between 3.5 to 10 feet. Tertiary -age Santiago Formation was encountered below the undocumented fill and alluvium across the site, at depths between 3.5 and 10 feet below existing grade.
According to the U.S. Department of Agriculture Natural Resources Conservation Services (USDA 2022), three soil types are mapped in the project area, including Las Flores loamy fine sand, 2% to 9% slopes, located in the central section of the project area, Las Flores -Urban land complex, 2 % to 9% slopes, located along the western border of the project area, and Placentia sandy loam, thick surface, 0% to 2% slopes, located along the southern and eastern sections of the project area. The Las Flores soil series generally occurs on hillslopes, formed in residuum weathered from siliceous calcareous sandstone, and are typically at an elevation of 700 feet, The Placentia soil series generally occur in settings with alluvial fans, formed in alluvium derived from gran ite, and are typically at elevations
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ranging from 50 to 2,500 feet. Reoccurring alluvial action and flooding serve to support the development and presence of cultural deposits in the area. Since there are alluvial soils present throughout the project area, there is moderate potential for subsurface cultural resources.
Native American Heritage Commission and Native American Outreach Letters Dudek requested a Native American Heritage Commission (NAHC) search of the Sacred Lands File on January 31, 2022, for the project area. The Sacred Lands File consists of a database of known Native American resources. These resources may not be included in the SCIC database. The NAHC replied on March 24, 2022, with negative results (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.
Thirty-one outreach letters were mailed on March 24, 2022 , to all Native American group representatives included on the NAHC contact list (Appendix D). These letters solicited, or attempted to elicit 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 area. Three responses have been received to date. A response was received from the Rincon Band of Luiseño Indians on April 25, 2022, stating that the project is located within a culturally sensitive area and the potential exists that the project may impact tangible Tribal Cultural Resources (TCRs), Traditional Cultural Landscapes, and potential Traditional Cultural Properties. A response was received from the San Luis Rey Band of Mission Indians on April 26, 2022, stating that they are aware of cultural resources within close proximity to the project and recommends including a Luiseño Native American mo nitor during all ground disturbing activities. A response was received from the San Pasqual Band of Mission Indians on May 5, 2022 , stating that the project is within their Traditional Use Area. The letters have been forwarded to the City. No other communications between Dudek and the tribes has occurred since then. The NAHC correspondence is included in Appendix D.
Assembly Bill 52 Consultation
In compliance with Assembly Bill (AB) 52, the City, as lead agency, is responsible for conducting government to government consultation with pertinent tribal entities. The City mailed AB 52 notifications on May 3, 2022 , to California Native American Tribal representatives (that have requested notification) who are traditionally or culturally affiliated with the geographic area of the project. Three tribes requested consultation under AB 52, including the Rincon Band of Luiseño Indians on May 20, 2022, San Luis Rey Band of Mission Indians on June 6, 2022, and San Pasqual Band of Mission Indians on May 11, 2023 . The Rincon Band of Luiseño Indians agreed with the mitigation measures proposed by Dudek in the archaeological resources report, which includes archaeological and tribal monitoring, and protocols for the discovery of cultural material and human
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remains. Additionally, the Rincon Band of Luiseño proposed that if export of soil is planned, consultation with the affiliated tribes will have to be initiated, and this was included in the mitigation measures. The Rincon Band of Luiseño concluded AB 52 co nsultation on December 20, 2022. The San Luis Rey Band agreed with the proposed measures for tribal cultural resources (MM-CUL-1 through MM-CUL-4) for the project’s environmental document. The San Luis Rey Band of Mission Indians concluded AB 52 consultati on on January 12, 2023. The San Pasqual Band of Mission Indians requested consultation on May 11, 2023. The City provided the San Pasqual Band of Diegueño Mission Indians with the project Cultural Reports on May 11, 2023. The San Pasqual Band of Diegueño Mission Indians requested inclusion of a Kumeyaay monitor during construction in a letter to the City on January 10, 2024. The City confirmed a Kumeyaay monitor would be included in the project’s conditions of approval, and the San Pasqual Band of Diegueño Mission Indians concluded AB 52 consultation on February 14, 2024. As of November 2, 2023, the City has not received a letter concluding consultation.
Intensive Pedestrian Survey
A Dudek archaeologist conducted an intensive level pedestrian survey of the project area on February 3, 2022. A Luiseño Native American monitor from Saving Sacred Sites participated in the pedestrian survey. All survey work was conducted employing standard archaeological procedures and techniques consistent with the Secretary of the Interior Standards. Five-meter interval survey transects were conducted in an east-west direction for the project area. Within the transects, the ground surface was examined for prehistoric artifacts (e.g., flaked stone tools, tool-making debris, stone milling tools, ceramics, fire-affected rock), soil discoloration that might indicate the presence of a cultural midden, soil depressions, features indicative of the current or former presence of structures or buildings (e.g., standing exterior walls, post holes, foundations), and historic artifacts (e.g., metal, glass, ceramics, building materials). Ground disturbances such as burrows, cut banks, and drainages were also visually inspected for exposed subsurface materials.
The project area is relatively flat and undeveloped. Some disturbances were observed, such as a dirt road on the eastern portion of the project area, and a drainage feature from a sewer running north to south. Ground visibility was poor (0 %–20%) in areas where the ground surface was obscured by vegetation. Approximately 75% of the area was obscured by grass, thistles, Hardy ice plants, and sage.
Modern debris (e.g., refuse) is strewn throughout the area and a homeless encampment was observed in the bushes on the northwestern portion of the project area. The pedestrian survey did not identify any cultural or built environment resources within the project area.
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3.16.2 Regulatory Setting
State
California Register of Historical Resources and the California Environmental Quality Act Under CEQA, 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 may be listed as an historical resource in the CRHR if it meets any of the following National Register of Historic Places 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 understand the historical importance of the resource (14 CCR 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 National Register of Historic Places , and properties listed or formally designated as eligible for listing on the National Register of Historic Places are automatically listed on the CRHR, as are the State Historical Landmarks numbered 770 or higher and California Points of Historical 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.
Assembly Bill 52
California Assembly Bill 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
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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, or determined by a lead agency to be a TCR.
California Native American Graves Protection and Repatriation Act The California Native American Graves Protection and Repatriation Act (California Repatriation Act), enacted in 2001, required 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.
Native American Historic Cultural Sites (California Public Resources Code Section 5097 et seq.) State law addresses the disposition of Native American burials in archaeological sites and protects such remains from disturbance, vandalism, or inadvertent destruction; 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 makes it a misdemeanor punishable by up to 1 year in jail to deface or destroy an Indian historic or cultural site that is listed or may be eligible for listing in the CRHR.
California Native American Graves Protection and Repatriation Act The California Native American Graves Protection and Repatriation Act (California Repatriation Act) (25 USC 32), enacted in 2001, requires all state agencies and museums that receive state funding and that have possession or control over collections of hum an 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.
California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98 CEQA Guidelines Section 150064.5 assigns special importance to human remains and specifies procedures to be used when Native American remains are discovered. As described below, these procedures are detailed in California Health and Safety Code Section 7050.5 and PRC Section 5097.98.
California law protects Native American burials, skeletal remains, and associated grave goods, regardless of their antiquity, and provides for the sensitive treatment and disposition of those remains.
Health and Safety Code Section 7050.5 requires that if human remains are discovered in any place
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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 (California Health and Safety Section 7050.5[b]). 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 (California Health and Safety Code Section 7050.5[c]). In accordance with PRC Section 5097.98(a), the NAHC will notify the most likely descendant. With the permission of the landowner, the most likely descendant may inspect the site of discovery. Within 48 hours of being granted access to the site, the most likely descendant may recommend means of treatment or disposition, with appropriate dignity, of the human remains and associated grave goods.
3.16.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to tribal cultural resources are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to tribal cultural resources would occur if the project would:
• Threshold #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 tribal cultural resources that may result from ground disturbing activities associated with the project are analyzed below.
Threshold #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 term s 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
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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.
Pursuant to AB 52, notification letters were mailed by the City on May 3, 2022, to California Native American Tribal representatives (that have requested notification) who are traditionally or culturally affiliated with the geographic area of the project. Three tribes requested consultation under AB 52, including the Rincon Band of Luiseño Indians on May 20, 2022, San Luis Rey Band of Mission Indians on June 6, 2022, and San Pasqual Band of Mission Indians on May 11, 2023 . The Rincon Band of Luiseño Indians agreed with the mitigation measures proposed by Dudek in the archaeological resources report, which includes archaeological and tribal monitoring, and protocols for the discovery of cultural material and human remains. Additionally, the Rincon Band of Lui seño proposed that if export of soil is planned, consultation with the affiliated tribes will have to be initiated, and this was included in the mitigation measures. The Rincon Band of Luiseño concluded AB 52 consultation on December 20, 2022. The San Luis Rey Band agreed with the proposed measures for tribal cultural resources (MM-CUL-1 through MM-CUL-4) for the project’s environmental document.
The San Luis Rey Band of Mission Indians concluded AB 52 consultation on January 12, 2023.
The San Pasqual Band of Mission Indians requested consultation on May 11, 2023. The City provided the San Pasqual Band of Diegueño Mission Indians with the project Cultural Reports on May 11, 2023. The San Pasqual Band of Diegueño Mission Indians requested inclusion of a Kumeyaay monitor during construction in a letter to the City on January 10, 2024. The City confirmed a Kumeyaay monitor would be included in the project’s conditions of approval, and the San Pasqual Band of Diegueño Mission Indians concluded AB 52 consultation on February 14, 2024.The Cultural Report was provided to San Pasqual Band of Mission Indians, and as of November 2, 2023, the City has not received a letter concluding consultation. Therefore, consultation with San Pasqual band of Mission Indians has not yet been closed.
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. Notwithstanding 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 March 24, 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 area. To date, no responses have been received.
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City AB 52 consultation is carried out by the City as the lead agency and is currently ongoing.
While considered unlikely based on the SCIC record’s search, 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 proposed project (Impact TCR-1).
Implementation of previously identified mitigation in Section 3.4, Cultural Resources, of this EIR (MM-CR-1 through MM-CR-4) would ensure potential impacts to tribal cultural resources as a result of ground-disturbing activities on the project site would remain less than significant.
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 below significance. With implementation of project-specific mitigation and compliance with applicable regulations related to Tribal Cultural Resources, cumulative impacts would be less than significant.
3.16.6 Mitigation Measures
Implementation of mitigation measures MM-CR-1 through MM-CR-4 outlined in Section 3.4, Cultural Resources of this EIR would be required to ensure any potentially significant impacts to unknown and unanticipated TCRs would remain less than significant.
3.16.7 Conclusion
For reasons described in Section 3.4.7, implementation of mitigation measures 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.
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3.17 Utilities and Service Systems
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3.17 UTILITIES AND SERVICE SYSTEMS
This section describes the existing utilities setting of the Hughes Circuits Project (project), identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures 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:
• Hydrology Study, prepared by Excel Engineering, June 3, 2022 (included as Appendix F-1 to this EIR)
• Storm Water Quality Management Plan, prepared by Excel Engineering, November 13, 2023 (included as Appendix F-2 to this EIR)
• Water and Sewer Study, prepared by Vallecitos Water District, February 21, 2023 (included as Appendix J to this EIR)
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
#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
#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
#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
#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
#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
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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.
Water Facilities
The project site is located within the Vallecitos Water District (VWD) for water services ( VWD 2022).
According to the City of San Marcos 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, store, 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 1 9 million people. MWD obtains water from 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 2045 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 in Table 3.17-2.
Table 3.17-2
Metropolitan Water District of Southern California Water Demands Average Year
Dates 2025 2030 2035 2040 2045
Total Demands (AFY) 4,925,000 5,032,000 5,156,000 5,261,000 5,374,000 Single Dry-Year
Dates 2025 2030 2035 2040 2045
Total Demands (AFY) 4,929,000 5,037,000 5,160,000 5,265,000 5,378,000 Multiple Dry-Years
Dates 2025 2030 2035 2040 2045
Total Demands (AFY) 4,877,000 5,064,000 5,182,000 5,299,000 5,410,000 Source: MWD 2021.
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
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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 additional 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 Sa n Diego Association of Governments (SANDAG) Series 14 Regional Growth Forecast, developed for its 2019 Federal Regional Transportation Plan adopted by SANDAG’s 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 total water demands are projected to reach 630,771 acre-feet. This projection accounts for planned future water conservation savings (SDCWA 2021).
There are existing 855 Zone and 920 Zone water facilities in the vicinity of the project site. The 920 Zone facilities consist of 24-inch-diameter and 30-inch-diameter transmission lines that do not provide direct service to properties in the area. Water service to existing development in the area is from connections to the 855 Zone which includes two 12-inch lines within Pacific Street, along the southern and western boundaries of the project site.
Wastewater
The project site is located within the VWD for sewer services ( VWD 2022). The VWD currently has a wastewater system that has a total liquids treatment capacity of 12.45 million gallons per day (MGD), and has an estimated maximum daily flow of approximately 9.54 MGD (City of San Marcos 2012 a).
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 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 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 is allocated to Carlsbad Municipal Water District, and 16 million gallons is allocated to Olivenhain Municipal Water District, leaving 6 MGD 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 e nsure flows to the Encina Water Pollution Control Facility would not exceed
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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 t o 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 within South Pacific Street and one line that runs through the project site.
Stormwater
The undeveloped project site surface slope is approximately 2% and runs generally from the north to the south. The majority of the existing off -site surface slopes generally from the north to the south.
When the water reaches South Pacific Street along the west border of the project, it flows into the existing dual 48-inch pipes then flow through vacant property before entering the project area. When off-site stormwater reaches the north edge of the project site, it flows along the slope until it reaches the project’s point of connection at the south edge of the property.
Solid Waste
Solid waste disposal in San Marcos 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 San Marcos (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 3,223 tons. Solid waste is consolidated here and trucked to a landfill for disposal. The Sycamore Sanitary Landfill has a daily permitted throughput of 5,000 tons per day of solid waste, a remaining capacity of approximately 113,972,637 cubic yards, and an anticipated closure date of 2042 (CalRecycle n.d.a.).
Electrical and Natural Gas
San Diego Gas & Electric (SDG&E) provides electric services to 3.7 million customers through
1.49 million electric meters located in a 4,100 -square-mile service area that includes San Diego County and southern Orange County (SDG&E 2022). SDG&E is a subsidiary of Sempra Energy and would provide electricity to the project. Electrical facilities throughout San Marcos include a
1 Despite a total capacity of 3 million gallons per day ( 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.
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combination of above-ground and underground electrical distribution lines and utilities structures. The California Public Utilities Commission regulates natural gas utility service for approximately 10.8 million customers who receive natural gas from Pacific Gas & Electric, Southern California Gas Company (SoCalGas), SDG&E, Southwest Gas, and several smaller natural gas utilities. The California Public Utilities Commission also regulates independent storage operators Lodi Gas Storage, Wild Goose Storage, Central Valley Storage, and Gill Ranch Storage (CPUC 2022). SDG&E provides natural gas service to the counties of San Diego and Orange and would provide natural gas to the project.
SDG&E is a wholesale customer of SoCalGas and currently receives all of its n atural gas from the SoCalGas system (CPUC 2022). Proposed development on -site would require constructing private utility lines to connect to existing electrical lines and natural gas within S outh Pacific Street. SDG&E maintains a natural gas distribution s ystem within South Pacific Street, which the project would connect to.
Telecommunications
Telecommunications services to the project site may be provided by various distributors . The fiber- optic network in San Marcos is facilitated by a 72 -strand fiber-optic line that runs on various streets throughout San Marcos. All major arterials in San Marcos have implemented fiber optics. Existing AT&T and Cox telecommunication lines surrounding 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 of San Marcos (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 indu strial solid waste. Subtitle D provides regulations for the generation, transportation, and treatment, storage, or disposal of hazardous wastes.
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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, such as those prepared by the Rincon and other water districts, are supplemental to the regional plans prepared by MWD. The Water Conservation Bill of 2009 (Senate Bill X7-7) requires each urban retail water supplier to develop an urban water use target and an interim urban water use target. Notably, Senate Bill 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 the site is provided by MWD. In accordance with this regulation, MWD prepared and their Board of Directors adopted its 2015 UWMP in 2016. MWD’s UWMP includes estimated future water demands until 2040, using updated population projections and a conservative assumption that, in the absence of mandatory water conservation measures, per-capita consumption could rebound to its 2020 target value. Demands provided in MWD UWMP have been coordinated with SDWCA, MWD’s wholesale supplier.
California Green Building Standards Code (CCR, Title 24, Part 11 – CALGreen) In 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as CALGreen, and establishes minimum mandatory standards a s well as 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 interior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground -up, new construction of commercial, low -rise residential and state -owned buildings and schools and hospitals. The CALGreen 201 9 standards became effective on January 1, 2020. 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 compliance 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 future charging stations
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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 energy requirements; str icter 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 standards 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.
Assembly Bill 939 and 341
In 1989, Assembly Bill 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. Assembly Bill 939 mandated a reduction of waste being disposed where jurisdictions were required to meet diversion goals of all solid waste through source reduction, recycling, and composting activities of 25% by 1995 and 50% by the year 2000.
Assembly Bill 341 (2011) amended the California Integrated Waste Management Act of 1989 to include a provision declaring that it is the policy goal of the state that not less than 75% of solid waste generated be source-reduced, recycled, or composted by 2020, and annual ly thereafter. In addition, Assembly Bill 341 required the California Department of Resources Recycling and Recovery (CalRecycle) to develop 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 County 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 2017.
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 jurisdictions 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,
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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.
City of San Marcos 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 matters concerning sanitation.
Title 14, Streets, Sidewalks, and Underground Utility Facilities SMMC Title 14, Chapter 14.15 , contains regulations concerning storm water 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 Landscaping Ordinance (WELO) 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 Landscaping Ordinance. In accordance with State law, SMMC Chapter 20.330 establishes specific standards for landscape and irrigation design and installation to ensure beneficial, efficient and responsible use of water resources within the City.
City of San Marcos Climate Action Plan
The City adopted its Climate Action Plan (CAP) on December 8, 2020 (City of San Marcos 2020). The CAP acts as a roadmap to address challenges of climate change within the City. The CAP builds on the efforts and strategies identified in the City’s 2013 CAP and establishes greenhouse gas ( GHG) emissions reduction targets and identifies achievable, locally based actions to reduce GHG emissions from municipal and community activities. The CAP includes a baseline GHG emissions inventory for 2012, GHG emissions f orecasts for 2020 and 2030, local GHG emissions reduction strategies and measures to help the City achieve the 2030 target, climate adaptation measures for the City, and implementation and monitoring mechanisms to ensure the City’s measures and targets are achieved.
The CAP established GHG emissions reduction goals of 4% below 2012 levels by 2020 and 42% below 2012 levels by 2030 (City of San Marcos 2020). The City has included energy reducing measures into its Climate Action Plan Consistency Review Checkli st to include electric vehicle charging stations,
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bicycle infrastructure, transportation demand management, reduced parking, electric or solar water heaters, photovoltaic systems, landscaping water use, and urban tree canopy.
City of San Marcos General Plan
The General Plan Conservation and Open Space Element includes one goal regarding water supply that is 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.
The General Plan Conservation and Open Space Element also includes one goal and associated policy regarding solid waste that is applicable to the project (City of San Marcos 2012b):
• Goal COS -10: Establish and maintain an innovative, sustainable solid waste collection, recycling, and disposal delivery system for present and future generations. o 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.
o Policy LU-8.1: New development shall pay its fair share of required improvements to public facilities and services.
o Policy LU -8.2: Promote development timing that is guided by the adequacy of existing and/or expandable infrastructure, services, and facilities. • 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.
o Policy LU-13.1: Work closely with local and regional water providers to ensure high quality water supplies are available for the community.
o Policy LU-13.2: Actively promote water conservation programs aimed at reducing demand. o Policy LU -13.3: Encourage exploration and use of deep underground wells to reduce reliance on treatable water.
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• Goal LU-14: Wastewater: Ensure a wastewater system for existing and future development. o Policy LU-14.1: Work closely with local service providers to ensure an adequate wastewater system for existing and future development is in place. o 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: Reduce the amount of waste material entering regional landfills with an efficient and innovative waste management program.
o Policy LU-16.1: Work closely with local service providers to ensure adequate solid waste disposal, collection, and recycling services.
o 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. o 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. o Policy LU-17.3: The City shall prohibit above ground utility equipment 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 responsible 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 a nd prior to submittal of building permits.
o Policy LU-17.4: Require utility location to be shown on all site development plans at the time of development/ project application.
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 utilities and service systems.
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 California Environmental Quality Act (CEQA) Guidelines. According to Appendix G
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of the CEQA Guidelines, a significant impact related to utilities and service systems would occur if the project would:
• Threshold #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.
• Threshold #2: Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years. • Threshold #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 #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 #5: Comply with federal, state, and local management and reduction statutes and regulations related to solid waste.
3.17.4 Project Impact Analysis
Threshold # 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. There are existing 855 Zone and 920 Zone water facilities in the vicinity of the project site. The 920 Zone facilities consist of 24 -inch and 30 -inch transmission lines that do not provide direct service to properties in the area. Water service to existing development in the area is from connections to the 855 Zone which includes two 12-inch lines within Pacific Street, along the southern and western boundaries of the project site. Water service for potable residential use and fire service to the project site would be provided by VWD. The project would connect to existing water lines in South Pacific Street.
As described in Section 3.17.1, VWD receives its water from the SDCWA. 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 additional 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
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SANDAG Series 14 Regional Growth Forecast, developed for its 2019 Federal Regional Transportation Plan adopted by SANDAG’s 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 total water demands are projected to reach 630,771 acre-feet. This projection accounts for planned future water conservation savings (SDCWA 2021).
A Water and Sewer Study has been prepared for the project and is included as Appendix J to this EIR.
The modeling focused on the infrastructure in the immediate vicinity of the project and determined that there would be no deficiencies in the distribution system under normal or peak demand conditions. The Master Plan from 2018 indicated that the maximum demand for this project would be three times the average demand, and peak hour demand would be over six times the average. The project is located entirely within the VWD 855 pressure zone, which has water storage located in the 920 zone and 1028 Twin Oaks pressure zones. The project is expected to increase the average water demand by 3,393 gallons per day, which equates to a 500% increase in storage requirements or 16,965 gallons. However, the analysis showed that the current water storage capacity would be sufficient to meet t he increased demand (Appendix J). As the project is situated in a pressure zone that does not rely on pumping, there w ould be no substantial impact on existing or planned pump stations as a result of this project. To provide service to the project, the applicant is required to pay all applicable Water and Wastewater Capacity Facility Fees, construct and obtain final acceptance of all on-site and off-site water and sewer facilities by the Board of Directors before service can be initiated, and install about 457 feet of 8-inch PVC Sewer Main along Pacific Street.
Considering the nature of the project, the project’s estimated water demand is expected to be adequately provided by VWD. However, a formal water study will be required by VWD for the project, which will outline capacity fees to be paid by the project appl icant and confirm adequate service connections.
Due to the location of the project site in an urbanized area that is currently served by existing facilities, and with confirmation of VWD approval of service, 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 a light industrial building , which would increase the intensity of uses on the project site and result in increased wastewater generation. There are existing gravity sewer lines within South Pacific Street and one line that runs through the project site. Sewer service to the project site would consist of constructing private on -site sewer lines and connecting to the public system at point locations.
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Wastewater generated by the project would be treated by the MRF. The 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 adequately 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 will conduct 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 above, a Water and Sewer Study was prepared for the project and is included as Appendix J to this EIR.
The project site is situated entirely within VWD sewer shed 27C. The City of San Marcos has designated the land use for the project site as Light Industrial. The 2018 Master Plan based its long-term planning for wastewater generation on Open Space. The Hughes Circuits project is expected to increase the average wastewater generation by 3,393 gallons per day compared to the 2018 Master Plan land use.
The modeling conducted not only focused on the sewer collection infrastructure within the immediate vicinity of the project but also on all downstream infrastructure up to Lift Station No. 1 on San Marcos Boulevard that would be impacted by the project flows. The modeling results revealed that there were no issues identified under the current approved density even under peak wet weather flows during ultimate build-out conditions (Appendix J).
Acceptance by VWD of all wastewater facilities required to be constructed to service the project would 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 would require construction of new private sewer lines to connect to existing City facilities, the construction of such infrastructure has been considered throughout this EIR (e.g., within the project description, construction assumptions, etc.), and would not cause significant environmental effects.
Therefore, impacts to wastewater services would be less than significant.
Storm Water Drainage
Development of the project would increase the impervious area on site and increase storm water runoff in comparison to existing conditions. However, as described in Section 3.9, Hydrology and Water Quality, of this EIR, storm drainage components recommended by the Hydrology Study (Appendix F-1) would properly handle runoff to meet regulatory requirements and to ensure that post -development run-off quantifies rates that are similar to or less than pre-development conditions.
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Water arrives on site via natural rainfall and off-site runoff. The majority of the existing off-site surface slopes generally from the north to the south. When the water reaches South Pacific Street along the west border of the project site, it flows into the existing dual 48-inch pipes then flow through vacant property before entering the project area. When water reaches the north edge of the project site, it flows along the slope until it reaches the point of connection at the southern edge of the proper ty at South Pacific Street. Per the Municipal Separate Storm Sewer System (MS4) requirements, stormwater flows on -site would be conveyed to best management practice dispersion area s located at the southeast corner of the project site (please refer to Section 3.9 of this EIR and Appendix F -2). The project would extend the existing dual 66 -inch culvert from the current terminus through the site to the development limits of the north side of the proposed parking lot. The proposed culvert routes stormwater to the point of connection at South Pacific Street. From here, the flows would follow the existing offsite flow path. Storm drainage components would properly handle runoff to meet regulatory requirements and to ensure that post-development run-off quantifies rates that 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 Hydrology Study (Appendix F-1) and development- specific drainage plans would ensure the project would not substantially exceed storm water 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, construction assumptions), and has not been identified to cause significant environmental effects. Therefore, impacts would be less than significant. Please refer to Section 3.9, Hydrology and Water Quality, for additional discussion related to drainage.
Electric Power
As discussed in Section 3.5, Energy, 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 used 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 261,832 kilowatt hours per year , with incorporation of PDF -GHG-1 outlined in
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Section 3.7 of this EIR (project installation of 9,700 s quare feet of photovoltaic panels). For context, SDG&E customers consumed approximately 17,445 million kilowatt hours of electricity in 2020 (CEC 2022a). In summary, although electricity consumption would increase at the project site due to project implementation, the project would be required to comply with the Title 24 and the City’s CAP Consistency Checklist by implementing energy -efficiency measures. Furthermore, the project will be subject to the Title 24 building code that is adopted at the time building permits are obtained and thus may be subject to a more stringent energy standard than what was assumed herein, and the additional electricity demand for the project would not be unusual or wasteful as compared to ove rall local and regional demand for energy resources.
Electricity and natural gas would be provided by SDG&E. Electrical facilities throughout the City include a combination of above-ground and below-ground electrical distribution lines and utilities structures.
Although electricity consumption would increase at the project site over current, vacant conditions , electrical power consumption would be consistent with that of an industrial development under the site’s current land use/zoning designations. The project is not expected to exceed existing capacity of servicing infrastructure. Electrical power lines are proposed to be relocated. The location of the relocated electrical power line will be determined by the Dry Utility Consultant. 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 operation would require natural gas for various purposes, including water heating and natural gas appliances. The project would consume approximately 1,118,553 kilo -British Thermal Units (kBtu) per year, including operation of the forklift. For context, SDG&E customers consumed approximately 505 million therms, which equates to about 50.5 billion kBtu of natural gas in 2020 (CEC 2022b). As previously discussed, the project would be subject to statewide mandatory energy requirements as outlined in Title 24, Part 6, of the California Code of Regulations. Prior to building permit application, the applicant would ensure that project plans would meet Title 24 requirements applicable at that time, as required by state regulations through their plan review proc ess, and the additional natural gas demand for the project would not be unusual or wasteful as compared to other warehouses and the overall local and regional demand for energy resources.
As described above, natural gas would be provided by SDG&E. The project would require constructing private utility lines to connect to existing infrastructure. 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.
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Telecommunications
Communications systems for telephones, computers, and cable television are serviced by utility providers such as AT&T, Cox, Spectrum (formerly Time Warner), and othe r independent cable companies. 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. No specific systems upgrades are proposed or anticipated for the project, but the location of the fiber-optic cable will be rel ocated. The location of the relocated fiber -optic cable along the right -of-way will be determined by the Dry Utility Consultant. 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 are determined to be less than significant.
Threshold #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 #1, above, the project would be served by VWD. 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 2045 under normal, single dry, and multiple dry water years (MWD 2021). The water demand generated by the project is expected to present an insignificant increase in water demand relative to the annual water demand projected by the MWD’s UWMP.
As described above, the VWD Sewer and Water Study prepared for the project determined that there would be no deficiencies in the distribution system under normal or peak demand conditions. The Master Plan from 2018 indicated that the maximum demand for this project would be three times the average demand, and peak hour demand would be over six times the average. The project is located entirely within the VWD 855 pressure zone, which has water storage located in the 920 zone and 1028 Twin Oaks pressure zones . The project is expected to increase the average water demand by 3,393 gallons per day, which equates to a 500% increase in storage requirements or 16,965 gallons.
However, the analysis showed that the current water storage capacity would be sufficient to meet the increased demand (Appendix J).
Further, the project site would be developed in compliance with the California Green Building Code , which implements water efficiency standards for appliances and fixtures . Compliance with the California Green Building Code 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 ability to service any development and capacity fees to be paid. A “Water Availability” letter wil l 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.
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Threshold #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 serve the project’s projected demand in addition to the provider’s existing commitments?
As discussed under Threshold # 1, above, wastewater generated by the project would be treated by the MRF. The 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 adequately treat wastewater flows from the project.
As described above, the project would increase the projected average wastewater generation from the 2018 Master Plan land use by 3,393 gallons per day. The modeling results of the Sewer and Water Study prepared for the project showed that no deficiencies w ere identified under the currently approved density under peak wet weather flows during ultimate build -out conditions. However, the study shows a new 8-inch PVC Sewer Main would have to be installed down Pacific Street (HC -1 and HC-2). It is determined tha t outfall capacity is currently available to serve the project’s proposed wastewater generation, and Wastewater Capital Facility Fees paid by the project would be used toward design and construction of a parallel land outfall to be sized to accommodate ult imate build -out wastewater flows (Appendix J).
As described above, sewer facilities to serve the project would require the construction of private on - site sewer lines connecting to the public system at one or more locations. 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.
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 was tewater 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, construction assumptions), and would not cause significant environmental effects. Therefore, impacts to wastewater services would be less than significant.
Threshold #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? Construction of the project would result in the generation of solid waste such as scrap lumber, concrete, residual wastes, pac king 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
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then be transferred to Sycamore 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 147,908,000 cubic yards, or approximately 40 million tons, with an anticipated closure date of 2042. Further, four other landfills in the County accept municipal solid waste, including Borrego Landfill, Miramar Landfill, Otay Landfill, and Romona Landfill.
The anticipated operational solid waste generation from the project was estimated using CalRecycle’s Estimated Solid Waste Generation Rates (CalRecycle 2019) . It is estimated that the project ( 60 employees) would generate approximately 536 pounds of solid waste per day. This does not consider any waste diversion through recycling. According to CalRecycle, the City of San Marcos 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 wi th the 50 % diversion requirement of A ssembly Bill 939. The most recent data from CalRecycle identifies the annual per capital disposal rate is 6.4 pounds per person per day (CalRecycle 2021). Thus, the City is exceeding their targets 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 otherwise impair the attainment of solid waste reduction goals , and i mpacts related to solid waste is determined to be less than significant.
Threshold #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 #4 above, the project would be required to comply with all federal, state, and local statues 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, Public Resources Code (Sections 44001-44018) and California Code of Regulations Title 27, Division 2, Subdivision 1, Chapter 4 (Section 21 440 et seq.) authorizes 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 stat ed 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 of multiple dry years through 2045. Not
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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 development. 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, required to go towards infrastructure improvements. Thus, cumulative impacts to water services would be less than significant.
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 assumptions 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, above, 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 required 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.
Stormwater
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 re sult in increased surface runoff, alteration of the regional drainage pattern, and flooding. However, like the project, each individual project applicant would be required to hydrologically engineer the respective cumulative project sites to ensure that post-development surface runoff flows can be accommodated by the regional drainage system.
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The project, in conjunction with cumulative projects that drain to the San Marcos Hydrologic Area, have the potential to increase the concentration of pollutants in surface runoff and downstream water quality. However, all cumulatively considered 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 stormwater pollution prevention plans per the National Pollutant Discharge Elimination System permit program and implementation of associated best management practices to prevent construction-related runoff from polluting receiving waters.
The project would incorporate bio-retention areas and best management practices 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 proj ect would not substantially contribute to a significant cumulative impact to water quality. Impacts would be less than significant.
Electrical and Natural Gas
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 mann er 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, 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 stations, installing solar, 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 CALGreen, 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 wasteful and inefficient use of energy. In additio n, 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.
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Telecommunication Facilities
Cumulative development projects would increase the demand on telecommunication services.
Communications systems for telephones, computers, and cable television are serviced by utility providers such as AT&T, Cox, Spectrum (formerly Time Warner), and other independent cable companies. The City’s 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. No specific systems upgrades are pro posed or anticipated for the project. Telecommunication demand and service is site and land use specific. All cumulative projects would be subject to CEQA and would require an analysis of impacts to utility services including telecommunication service. Due to the existing infrastructure served in the surrounding project area, the project would not result in cumulative impacts associated with the construction or expansion of telecommunications, As such, the project’s contribution to cumulative impacts relate d to telecommunications would be less than significant.
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 December 2016, the remaining capacity of Sycamore Sanitary Landfill is 147,908,000 cubic yards, or approximately 40 million tons, with an anticipated closure date of 2042 (CalRecycle n.d.a.). Further, five other landfills in the County accept municipal solid waste (County of San Diego 2005). This includes Borrego Landfill, with a remaining capacity of 111,504 cubic yards since March 2016 (CalRecycle n.d.c.); Otay Landfill, with a remaining capacity of 21.1 million cubic yards since June 2017 (CalRecycle n.d.d.); and Ramona Landfill , which is currently at capacity (CalRecycle n.d.e.). Therefore, it is determined there is adequate capacity throughout the County 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, telecommunications, natural gas, and solid waste services. However, as outlined in the project impact a nalysis above, Section 3.17.4, it is determined that there would be adequate existing facilities to service the project, and impacts to/from such utilities and service systems would be less than significant.
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3.18 Wildfire
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3.18 WILDFIRE
This section describes the existing wildfire conditions of the Hughes Circuits Project (project), identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures related to implementation of the project. This section is based on the Fire and Medical Response Analysis prepared by Dudek in February 2022, which is included as Appendix H to this environmental impact report (EIR).
Table 3.18-1 summarizes the project- and cumulative-level wildfire impacts, by threshold.
Table 3.18-1
Wildfire Summary of Impacts
Threshold of Significance Project Impact
Project
Cumulative
Impact
Significance
Determination
#1 – Substantially impair an adopted
emergency response plan or emergency
evacuation plan.
Less than
Significant
Less than
Significant
Less than
Significant
#2 – Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks, and thereby
expose project occupants to, pollutant
concentrations from a wildfire or the
uncontrolled spread of a wildfire.
Less than
Significant
Less than
Significant
Less than
Significant
#3 – Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines
or other utilities) that may exacerbate fire risk
or that may result in temporary or ongoing
impacts to the environment.
Less than
Significant
Less than
Significant
Less than
Significant
#4 – Expose people or structures to significant
risks, including downslope or downstream
flooding or landslides, as a result of runoff,
post-fire slope instability, or drainage changes.
Less than
Significant
Less than
Significant
Less than
Significant
3.18.1 Existing Conditions
Wildfire is a continuous threat in Southern California and is particularly concerning in the wildland - urban interface, the geographic area where urban development either abuts or intermingles with wildland or vegetative fuels. During the summer season, dry vegetation, prolonged periods of drought, and Santa Ana wind conditions can combine to increase the risk of wildfires in the County.
The project site is located within the jurisdiction of the San Marcos Fire Department . The fire department provides structural fire protection and advanced life support-level emergency medical services within the City of San Marcos (City) limits; unincorporated territory adjacent to the city’s
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northern boundary; discontinuous, unincorporated areas between the City of San Marcos and the City of Escondido; and the community of Lake San Marcos. The fire department operates two Fire Stations (Stations 1 and 2) that would respond to an incident at the project site, although primary response would be from Station 2, with Station 1 responding as necessary.
3.18.1.1 Fire History
The project site, like all of San Diego County, is subject to seasonal weather conditions that can heighten the likelihood of fire ignition and spread. Fire history is an important component of wildfire analysis. Wildfire history information can provide an understanding of fire frequency, fire type, most vulnerable project areas, and significant ignition sources, amongst others. The California Department of Forestry and Fire Protection (CAL FIRE) maintain the Fire and Resource Assessment Program database, which was used to evaluate the project site’s fire history to determine whether large fires have occurred in the project site, and thus the likelihood of future fires. Per the recorded fire history database, the site has not been subject to wildfire (CAL FIRE 2021). Recorded wildfire within 5 miles of the project site range from 39 acres (fire in 1982) to 40,247 acres (fire in 1943). The most notable, recent fire nearest to the project site was the Harmony fire in 1996, which consumed 9,359 acres.
3.18.1.2 Fire Hazard Mapping
CAL FIRE’s Fire and Resource Assessment Program database also includes map data documenting areas of significant fire hazards in the state. These maps categorize geographic areas of the state into different Fire Hazard Severity Zones, ranging from moderate to very high. CAL FIRE uses Fire Hazard Severity Zone s to classify anticipated fire -related hazards for the entire state, and includes classifications for State Responsibility Areas, Local Responsibility Areas, and Federal Responsibility Areas. Fire hazar d severity classifications take into account vegetation, topography, weather, crown fire production, and ember production and movement. As shown in Figure 3.18-1, Fire Hazard Severity Zones, the project site is not within a Very High Fire Hazard Severity Zone (VHFHSZ), but there is a VHFHSZ located approximately 0.4 miles southwest of the project site (CAL FIRE 2009).
3.18.1.3 Vegetation Communities and Land Covers
Variations in vegetative cover type and species composition have a direct effect on fire behavior. Some plant communities and their associated plant species have increased flammability based on plant physiology (resin content), biological function (floweri ng, retention of dead plant material), physical structure (leaf size, branching patterns), and overall fuel loading.
A critical factor to consider is the dynamic nature of vegetation communities. Fire presence and absence at varying cycles or regimes affect plant community succession. Succession of plant communities, most notably the gradual conversion of shrublands to g rasslands with high frequency fires and grasslands to shrublands with fire exclusion, is highly dependent on the fire regime. Further,
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biomass and associated fuel loading will increase over time if disturbance or fuel reduction effects are not diligently implemented.
The vegetation types and land covers in the project site were identified during field assessments conducted for the project site. As detailed in Section 3.3, Biological Resources, the project site is characterized by Arundo-dominated riparian, disturbed wetland, emergent wetland, San Diego mesa claypan vernal pool, southern willow scrub, tamarisk scrub, valley needlegrass grassland, wildflower field, Diegan coastal sage scrub, Diegan coastal sage scrub -Baccharis domina ted, non -native grassland (broadleaf dominated), eucalyptus woodland, and disturbed habitat . Figure 3.3-1 in Section 3.3 illustrates the distribution of vegetation communities and land covers in the study area.
3.18.1.4 Topography/Terrain
Topography influences fire risk by affecting fire spread rates. Typically, steep terrain results in faster fire spread up -slope and slower spread down -slope. Terrain that forms a funneling effect, such as chimneys, chutes, or saddles on the landscape can result in especially intense fire behavior, including faster spread and higher intensity. Conversely, flat terrain tends to have little effect on fire spread, resulting in fires that are driven by vegetation and wind. The project site is relatively flat and primarily consists of mostly undeveloped lands, with a mix of native and non-native vegetation communities.
3.18.1.5 Climate, Weather, and Wind
In the City, the summers are short, warm, arid, and clear and the winters are long, cool, and partly cloudy. During summer months (early July through late September), the average daily high temperature is above 77°F, and during the cooler, winter months (late November through early April), the average daily high temperature is below 67°F. The temperature varies throughout the year but is rarely below 39°F or above 8 8°F. Like much of Southern California, the City experience seasonal variation in monthly rainfall throughout the year, with the wetter months lasting from October through April.
The project site, like much of Southern California, is influenced by prevailing wind patterns. Prevailing winds are winds that blow from a single direction over a specific area of the Earth. The predominant average hourly wind speed and direction in the City varies throughout the year. The wind is most often from the west for 10 months, and the wind is most often from the northeast from early December to late January. The windier part of the year lasts for approximately 7 months (November to June), with average wind speeds of more than 7.3 miles per hour (WeatherSpark 2022).
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3.18.2 Regulatory Setting
Federal
National Fire Protection Association Codes, Standards, Practices, and Guides National Fire Protection Association codes, standards, recommended practices, and guides are developed through a consensus standards development process approved by the American National Standards Institute. This process brings together professionals repre senting varied viewpoints and interests to achieve consensus on fire and other safety issues. National Fire Protection Association standards are recommended guidelines and nationally accepted good practices in fire protection but are not law or “codes” unless adopted or referenced as such by the California Fire Code (CFC) or local fire agency.
State
California Fire Code
The CFC is Chapter 9 of Title 24 of the California Code of Regulations. It was created by the California Building Standards Commission and is based on the International Fire Code created by the International Code Council. It is the primary means for author izing 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 facili ties. The CFC and the California Building Code use a hazards classification system to determine what protective measures are required to protect fire and life safety. These measures may include construction standards, separations from property lines, and s pecialized 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. Chapter 17.46 (California Fire Code) of the City’s Municipal Code provides the City’s adopted amendments to the 2019 CFC.
California Department of Forestry and Fire Protection
CAL FIRE is tasked with reducing wildfire -related impacts and enhancing California’s resources. CAL FIRE responds to all types of emergencies including wildland fires and residential/commercial structure fires. In addition, CAL FIRE is responsible for the protection of approximately 31 million acres of private land within the state and, at the local level, is responsible for inspecting defensible space around private residences. CAL FIRE is responsible for enforcing State of California fire safety codes included in the California Code of Regulations and the California Public Resources Code.
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California Strategic Fire Plan
In 2010, the State Board of Forestry and Fire Protection issued the California Strategic Fire Plan, a statewide fire plan developed in concert between the State Board of Forestry and Fire Protection and CAL FIRE. Goals included improved availability and use of information on hazard and risk assessment, land use planning, development of shared vision in plans such as Community Wildlife Protection Plans, establishment of fire resistance in assets at risk, shared vision among fire protection jurisdictions and agencies, levels of suppression, and post-fire recovery.
In support of this plan, several policies are noted, including creation of defensible space, improving home fire resistance, fuel hazard reduction that creates resilient landscapes and protects wildland and natural resources, adequate and appropriate fire suppression, and commitment by individuals and communities to wildfire prevention and protection through local planning.
The California Strategic Fire Plan’s several objectives are as follows: the state will produce tools such as updates to the CAL FIRE VHFHSZ maps, fire history, and data on values and assets at risk; assist government bodies in the development of a comprehe nsive set of wildland and wildland/urban interface protection policies; identify minimum key components necessary to achieve a fire safe community; coordinate CAL FIRE Unit Fire Plans with Community Wildlife Protection Plan s; improve regulatory effectivene ss, compliance monitoring, and reporting pursuant to California Public Resources Code 4290 and 4291; and participate in public education efforts concerning regulation, prevention measures, and preplanning.
Local
California Disaster and Civil Defense Master Mutual Aid Agreement As provided for in the California Emergency Services Act, this agreement was developed in 1950 and adopted by all 58 California counties. This statewide mutual aid system is designed to ensure that adequate resources, facilities, and other support is provi ded to jurisdictions whenever their own resources prove to be inadequate to cope with a given situation. San Diego County is located in Mutual Aid Region 6 of the state system, which also includes Imperial, Riverside, San Bernardino, Inyo, and Mono counties.
San Diego County Emergency Plan
The San Diego County Emergency Plan is a comprehensive emergency management system that provides for a planned response to disaster situations associated with natural disasters, technological incidents and nuclear defense operations. The Plan includes operational concepts relating to various emergency situations, identifies components of the Emergency Management Organization and describes the overall responsibilities for protecting life and property and assuring the overall well-being
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of the population. The plan also identifies the source of outside support that might be provided (through mutual aid and specific statutory authorities) by other jurisdictions, state and federal agencies and the private sector.
City of San Marcos General Plan
The Conservation and Open Space Element of the City’s General Plan contains several policies pertaining to wildfire hazards (City of San Marcos 2012). The following goals and policies apply to the project:
• Goal S -3: Minimize injury, loss of life, and damage to property resulting from structural or wildland fire hazard.
o Policy S-3.1: Require development to be located, designed, and construction 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. o Policy S-3.2: Provide sufficient level of fire protection services to reduce risk from urban and wildland fire. Advocate and support regional coordination among fire protection and emergency service providers.
o 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. o Policy S-3.5: Support programs and plans, such as Strategic Fire Plans, consistent with state law that require fuel management/modification within established defensible space boundaries and when strategic fuel modification is necessary outside of defensible space, balance fuel management needs to protect structures with the preservation of native vegetation and sensitive habitats.
The project’s consistency with applicable General Plan goals and policies is discussed in Section 3.10, Land Use and Planning. As shown in Section 3.10.4, the project is consistent with the applicable goals and policies related to wildfire.
3.18.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to wildfire 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 wildfire would occur if the project would:
• Threshold #1: Substantially impair an adopted emergency response plan or emergency evacuation plan.
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• Threshold #2: Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire.
• Threshold #3: Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment. • Threshold #4: Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.
3.18.4 Project Impact Analysis
Threshold #1: Would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
The project site is not located within or adjacent to a State Responsibility Area or Local Responsibility Area VHFHSZ (CAL FIRE 2009). The project site is located within an urbanized and developed area of the City. Although the project site is on undeveloped land, this wildland is not in an area subject to high fire risk. The nearest VHRHSZ is a Local Responsibility Area located approximately 0.4 miles southwest of the project site (CAL FIRE 2009). As discussed in Section 3.8, Hazards and Hazardous Materials, the project would be required to comply with all applicable state and local fire codes, including compliance with the California Fire Code and the San Marcos Fire Department, which require a design that affords fire and emergency responders suitable fire a ccess roads dimensions and surfaces (Chapter 5, Sections 503.1 through 503.4 of the California Fire Code). As determined in the Fire Protection Technical Memorandum prepared for the project (Appendix H), the project would generate emergency calls, primarily medical, proportionally with its population and less than full -time on-site status. At build out, there may be as many as 0.014 calls per day generated by the on-site population.
The addition of one call per 2.5 months to a station that is currently running approximately 17.8 calls per day is not considered a significant increase. Based on the information provided by the San Marcos Fire Department, the Project’s additional call volume should not cause a signi ficant stress on the response capabilities.
It has been determined that San Marcos Fire Department ’s existing Station 2 (with support from Station 1, as needed), would adequately serve the project site while maintaining San Marcos Fire Department’s response goals (Appendix H) . Please refer to Sections 3.8, Hazards and Hazardous Materials; 3.13, Public Services; and 3.15, Transportation, for additional information related to fire risk and fire service. The project would not substantially impair an adopted emergency response plan or emergency evacuation plan and, therefore, impacts are determined to be less than significant.
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Threshold #2: Due to slope, prevailing winds, and other factors, would the project exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
The project site is located in a developed area of the City and is not located within or adjacent to a fire hazard severity zone. Although the project site includes native vegetation that could experience a relatively small-scale wildfire risk, the project land uses would not exacerbate that risk. The preliminary site plans and emergency access for the project have been reviewed by City Fire and would be in compliance with the Fire Code. It has been determined that the project would not exacerbate wildfire risks, exposing occupants to pollutants and, therefore, impacts would be less than significant.
Threshold #3: Would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? While the project would require the installation of water sources and other underground utilities to connect to the City’s existing infrastructure (refer to Section 3.17, Utilities and Service Systems), these would not exacerbate fire risks, as the project is not located within or adjacent to a fire hazard severity zone and these improvements would be constructed within an existing right-of-way or within the project site boundary. The project does not propose any new overhead utility lines nor construction of roads to serve the project site. The project would not require the installation or maintenance of such infrastructure that would exacerbate fire risk, and therefore, impacts would be less than significant.
Threshold #4: Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? The project is not located in a VHFHSZ and risk of wildfire is considered low within the project site due the relative size of the habitat area and location. The Geotechnical Report (Appendix E) also does not note any significant landslide risks based on the soil types. The project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post -fire slope instabili ty, or drainage changes. Therefore, impacts would be less than significant.
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3.18.5 Cumulative Impact Analysis
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 projects’ compliance with applicable regulations related to wildfire would ensure impacts related to wildfire risk would be less than significant.
3.18.6 Mitigation Measures
Based upon the analysis presented in Section s 3.18.4 and 3.18.5, no significant impacts were identified, and no mitigation measures are required.
3.18.7 Conclusion
As described throughout Section 3.18.5, the project site is not designated as located within a high fire severity zone, and all 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 wildfire would be less than significant.
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SOURCE: USGS National Map 2022; CAL FIRE 2022
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Fire Hazard Severity Zones
Non-Very High Fire Hazard Severity Zone
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FIGURE 3.18-1
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Hughes Circuits Project Environmental Impact Report March 2024 City of San Marcos 4-1
4 ALTERNATIVES
4.1 INTRODUCTION TO ALTERNATIVES
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 the project, and evaluate the comparative merits of the alternatives.”
The range of alternatives evaluated in an EIR is governed by the “rule of reason” that requires the EIR set forth only those alternatives necessary to permit a reasoned choice. An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose implementation is remote and speculative (Section 15126.6[a] of the CEQA Guidelines).
In developing the alternatives to be addressed in this EIR, the potential alternatives were evaluated in terms of their ability to meet the basic objectives of the Hughes Circuits Project (project) while reducing or avoiding the environmental impacts of the project identified in Chapter 3, Environmental Analysis, of the EIR.
In determining what alternatives should be considered in the EIR, it is important to acknowledge the objectives of the project, the project’s significant effects, and unique project considerations. These factors are crucial to the development of alternativ es that meet the criteria specified in Section 15126.6(a). Although, as noted above, EIRs must contain a discussion of “potentially feasible” alternatives, 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 (see PRC Section 21081[a] [3]).
4.2 PROJECT OBJECTIVES
The following objectives of the 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. Expand the existing Hughes Circuits facilities to a nearby location for ease of continued operation and access.
2. Concentrate non-residential uses near existing roadways, highways, and freeways in an effort to isolate and reduce any potential environmental impacts related to truck traffic congestion, air emissions, and industrial noise to the greatest extent feasible.
3. Develop a fiscally sound and employment-generating land use that maximizes the use of the light-industrial zoned area.
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4. Restore, manage, and conserve sensitive on -site biological resources, to the extent feasible, while accommodating and maximizing development on site consistent with the General Plan land use and zoning designation.
5. Promote infill development and develop a site that is served by existing utilities, services, and street access.
4.3 ALTERNATIVES CONSIDERED BUT REJECTED
State CEQA Guidelines Section 15126.6(c) provides guidance in selecting a range of reasonable alternatives for the project. The EIR should also identify any alternatives that were considered by the lead agency, but were rejected during the planning or scop ing process and briefly explain the reasons underlying the lead agency’s determination. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are (i) failure to meet most of the basic project objectives, (ii) in feasibility, or (iii) inability to avoid significant environmental impacts. State CEQA Guidelines Section 15126.6(c) provides the following guidance in selecting a range of reasonable alternatives for the project. There are many factors that may be taken into account when addressing the feasibility of range of potential alternatives for the project, such as site suitability, economic viability, availability 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 the proponent). The alternatives discussion shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects. The EIR should also identify any alternatives that were considered by the lead agency, but were rejected during the planning or scoping process and briefly explain the reasons underlying the lead agency's determination.
The EIR need not discuss every alternative to the project. A range of alternatives that are “reasonable” for analysis have been evaluated and are discussed below in Section 4.4, Project Alternatives Considered in this EIR. The following describes other alt ernatives considered by the City of San Marcos (City) but dismissed from further evaluation in this EIR, and a brief description of the reasons for their rejection.