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Attachment D - Appendix C-2 - Biological Memo RPSPA

San Marcos City Council
July 23, 2024

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Attachment D - Appendix C-2 - Biological Memo RPSPA
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July 23, 2024
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Appendix C-2
Biological Technical Memorandum for the
Pacific Specific Plan Project Alternative

Memorandum

HELIX

Environmental Planning, Inc.

7578 El Cajon Boulevard

La Mesa, CA 91942

619.462.1515
tel

619.462.0552
fax

www.
helixepi
.com

Date:

May
1 3
, 2024

To:

Greg Waite, The Las Posas Owner LPV, LLC

c
c:

Gill Miltenberger
,
The Las Posas Owner LPV, LLC

Vanessa Schiedel
,
DUDEK

Matt Simmons, CCI

Jason Gremminger, CCI

Kimber
l
y Foy, Gatzke Dillon & Ballance LLP

From:

Thomas Liddicoat
,
HELIX Environmental Planning, Inc.

Subject:

Comparison of the Pacific Specific Plan Development Project Draft EIR Proposed Project and the
Reduced
Pacific Specific Plan Project Alternative

HELIX Proj
ect:

00 357
.00
040
.001

Message:

This memorandum serves to document a “Reduced Project Alternative” for the Pacific Specific Plan Development Project (project). Details of the project were initially outlined in the Pacific Development Project Biological Resources Technical Report (HELIX 2
023a) as well as the Draft Environmental Impact
Report (EIR; Dudek 2023) for the project. Revisions to the project site plan were made to address Wildlife Agency (i.e., U.S. Fish and Wildlife Service [USFWS] and California Department of Fish and Game [CDFW
]) comment to further reduce development footprint impacts on -
site.

Thus, this memorandum provides a comparison

of impacts to biological resources
,
between

1)

the
proposed project in the Draft EIR and 2) a Reduced
Pacific
Specific Plan
Project
Alternative (R
P
SP
P
A).

The biological resources data from the Draft EIR, the engineering refinements associated with roadway dedications and improvements, and additional biological surveys conducted by HELIX in response to draft EIR comments were used for the comparison discusse d herein
.

Figure 1

attached to this
memorandum
depicts

the
disturbance area footprints for
proposed project
in the Draft EIR

and the
RPSPPA
.

Impacts within the 33.22
-
acre site as well as off
-
site impacts
(i.e., outside of the project
site
boundary)
associated with roadway dedications and improvements are presented in

Figure 1.

As seen in
Figure 1, the footprint of off
-
site impacts
is

nearly
the same
for both the proposed project in the
Draft
EIR and the
RPSPPA
.

The
proposed project
presented in Section
2 t
he Draft EIR
would
provide
449

units
occupying a
development

footprint
area
of
approximately

15.09 acres

of the 33.22
-
acre site
.

The proposed project
in

Memorandum to

Greg Waite

Page
2 of
3 May

1 3
, 2024

the Draft EIR
also includes 0.17 acres of roadway dedications on
-
site, for an overall disturbance
impact
of 15.26 acres (approximately 46%) of the 33.22
-
acre site.

Based on engineering refinements and
associated with the off
-
site roadway dedications and improvements, the proposed project presented in the Draft EIR would impact 15.33 acres (approximately 46%) of the 33.22 -
acre site and 1.53 acres off
-
site, for a total

disturbance footprint of 16.86 acres.

In comparison,

the
RPSPPA

proposes

299 units and
would result in im
pact
s

to

13.5 2

acres (approximately 41%
) of the

33.22 -
acre site

by implementation

of

the
project
development
footprint
and on
-
site roadway dedications
.

Implementation of the
RPSPPA

would also result in

1.52 acres of impacts off
-
site, for an overall disturbance footprint totaling

15.04 acres.

Ultimately
, the
RPSPPA

would result in approximately
5 %
less

(

1.81 acres

less
)

disturbance
impact
area
to the

33.22 -
acre
site
, while providing
150

fewer residential housing units
.

Table 1 below presents a
comparison of

impacts by the proposed project in the Draft EIR and the RPSPPA
.

Table 1.

Proposed
Project
Footprint
Impacts

Project Alternative

On
-
Site Disturbance
Footprint
1 Off
-
Site
Disturbance
Footprint
2 Total

Draft EIR

Proposed Project

(449 units)

15.33 acres

1.53 acres

16.86 acres

Reduced Pacific Specific Plan Project
Alternative (299 units)

13.52 acres

1.52 acres

15.04 acres

1 Reflects
residential
development and on
-
site roadway dedications.

2 Consists of off
-
site roadway dedications and roadway improvements.

When comparing impacts to biological resources,
the proposed project in the Draft EIR and the
RPSPPA

would
both
impact
native vegetation,
including
vernal pools,
as well as listed
special
-
status plants and
animal species
.

The impacts to vegetation
types
are nearly the same
;

the

proposed project in the Draft
EIR and the
RPSPPA

would
both
result in impacts
to Diegan coastal sage scrub, grassland, and vernal
pool vegetation, although impacts
to the 33.22
-
acre site
would be approximately

1.81 acres less
as a
result of

implementation

of the
RPSPPA
.

Both
the proposed project in the Draft EIR and the
RPSPPA

would impact
vernal pools

and other features known to be occupied by
the federally l
isted endangered
San Diego
f
airy
s
hrimp

(
Branchinecta sandiegonensis
)
; however, implementation of the
RPSPPA

would
impact slightly less
. Table 2 below presents a comparison of impacts to vernal pools and San Diego fairy shrimp
with implementation of
the
proposed project in the Draft EIR

versus
the
RPSPPA
,
of which all are
within the 33.22
-
acre site. No impacts to vernal pools or other features occupied by San Diego fairy shrimp would result with implementation of the off
-
site roadway dedications and
improvements.

Table
2 .

Proposed
Project Impacts

to Vernal Pools and San Diego Fairy Shrimp

Project Alternative

Vernal Pools

San Diego Fairy Shrimp

Draft EIR

Proposed Project

(449 units)

0.15 -
acre

8 features

Reduced Pacific Specific Plan Project
Alternative (299 units)

0. 14
-
acre

6 features

In regard to

listed special
-
status plants,

both the

proposed project in the Draft EIR

and the
RPSPPA

would impact
two
listed plant species
. Specifically,
both project footprints

would impact
t
he federally

Memorandum to

Greg Waite

Page
3 of
3 May

1 3
, 2024

listed threatened
and state listed endangered
thread
-
leaved brodiaea

(
Brodiaea filifolia
)

and the
federally listed
endangered

and state listed endangered San Diego button celery (
Eryngium aristulatum

var.
parishii
)
.

As reflected in
Table
3 below
, the
impacts to listed plant species by
implementation of the
proposed project in the Draft EIR

and the
RPSPPA

are the same
.

Table
3 .

Proposed
Project Impacts

to Listed Plant Species

Project Alternative

Thread
-
leaved Brodiaea

San Diego Button
Celery

Draft EIR

Proposed Project

(449 units)

33,
879

plants

103 plants

Reduced Pacific Specific Plan Project
Alternative (299 units)

33,879

plants

103

plants

In addition to the reduction of footprint impacts by implementation of the RPSPPA
, the
RPSPPA

also
provides
less

development
interfaces

adjacent
to proposed biological resources
preservation areas

on
-
site
.

This
reduction of development interface
theoretically
w
ould result in a reduction of potential
indirect
impacts
“edge effects”
on those
adjacent
biological preservation
areas
.

In conclusion,
both
the
proposed project
in the Draft EIR
and the
RPSPPA

would
result

in significant

impact
s

to sensitive biological resources (i.e.,
native
vegetation, vernal pools,
San Diego fairy shrimp,
San Diego button celery,
and thread
-
leaved brodiaea)

and
both would
be required to incorporate
mitigation measures
(MM)

MM
-
BIO
-
1a through MM
-
BIO
-
8b
in the Draft EIR
to reduce impact
s to less
than significant
.

These MMs have been revised in response to comments on the Draft EIR, which are presented in the Final EIR Errata for Biological Resources. The MMs in the Final EIR would adequately reduce project impacts

to less than significant.

Overall, t
he primary difference
s

in impacts to sensitive biological resources
between the
proposed
project
in the Draft EIR
and the
RPSPPA

are

that
:

1)

The
RPSPPA

would result in

0.01 -
acre less impacts to vernal pools and would avoid two vernal pools occupied by San Diego fairy shrimp, which would be impacted by implementation of
the
proposed project in the Draft EIR

2)

The
RPSPPA

would provide for a larger
(approximately

1.81 acres more)
biological preservation
are
a

of the site.

Approximately

19.70 acres of biological preservation would be provided with
implementation of

the
RPSPPA

project whereas
approximately 17.
89 acres

of biological
preservation would be provided with implementation
of the
proposed project in the Draft EIR
.

Attachments
:

Figure 1
–

Footprint
Comparison of
Draft EIR Proposed Project and
the Reduced Pacific Specific Plan
Alternative

References

Cited
:

Dudek.
2023.

Draft E
IR

f
or City
o
f San Marcos Pacific Specific Plan Project
. March.

U.S. Fish and
Wildlife Service

(USFWS)
. 2023. Comments on the Environmental Impact Report for the Pacific Specific Plan, City of San Marcos, San Diego County, California. April 13.

S Pacific St
S Las Posas Rd
Linda Vista Dr
La Mirada Dr
I:\PROJECTS\I\IntegralCommunities_00357\IPQ-40_SanMarcosUpham\Map\EIR_Errata\Fig1_BTRvsRedNorthImpacts.mxd 00357.40.1 5/13/2024 - SAB Figure 1

Source: Aerial (NearMap, 2023)0 150Feet
Pacific Residential
K

Project Boundary
Draft EIR Proposed Project Impacts
Permanent Impact
T emporary Impact
Reduced Pacific Specific Plan Project Alternative
Permanent Impact
T emporary Impact
Footprint Comparison of Draft EIR Proposed Project and the Reduced Pacific Specific Plan Alternative

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